How Estell collects, uses, and protects your information.

In providing our service, we handle two distinct types of personal information:

1. Your Information (Data Controller): When we collect your own personal information (as the broker/user) to set up your account, bill you, or communicate with you, Estell acts as the Data Controller. We are directly responsible for this data under privacy laws.
2. Your CRM Contacts' Information (Data Processor): When you upload, forward, or input information about your clients, leads, or other third parties into Estell, you remain the Data Controller of that information. Estell acts merely as a Data Processor or service provider. You are responsible for ensuring you have the necessary consent and legal right to collect, use, and share your contacts' information with Estell.

When you use Estell, you may share:

• Contact details: Your name, email address, phone number, WhatsApp number
• Messages you forward: WhatsApp messages, listings, and conversations you forward to Estell
• Voice notes: Audio recordings you send, which we transcribe using AI
• Contact lists (Third-Party Data): Names, phone numbers, and details of your professional contacts, clients, and leads
• Deal and property information: Property addresses, deal terms, transaction details, notes about deals
• Account information: Payment details (processed securely by our payment provider), subscription tier

• Usage data: How you interact with Estell (features used, frequency, timestamps)
• Device information: Type of device, operating system, WhatsApp version
• Log data: Error logs, system performance data to keep Estell running smoothly

When you create an account and begin using Estell, you consent to our collection and use of your contact details, account information, and usage data for the purposes listed above.

WhatsApp messages and voice transcriptions contain highly personal content. Canadian privacy law classifies this as sensitive information requiring your express consent.

Before we process your WhatsApp messages or transcribe voice notes, you must:

• Receive a clear explanation of what we will do with this data
• Actively agree (via checkbox, button click, or similar affirmative action)
• Be informed that you can decline and still use limited Estell features

What happens if you don't consent: You can still use Estell for manual contact entry and basic CRM features, but AI-powered message extraction and voice transcription will not be available.

To receive messages from Estell via WhatsApp Business, you must opt in. This means:

• You actively agree to receive Estell messages on WhatsApp
• You can opt out at any time by replying "STOP" or contacting us
• We clearly identify ourselves as Estell in all communications

You can withdraw your consent at any time by:

• Deleting your account
• Contacting us at privacy@estell.ai

What happens when you withdraw consent: We will stop processing your personal information for the purposes you've withdrawn consent from. This may limit or end your ability to use Estell. We will delete your data according to our retention schedule unless legally required to retain it.

1. Voice note transcription: Converts audio to text so you can search and reference voice messages
2. Message extraction: Identifies and extracts contact names, phone numbers, email addresses, and deal details from WhatsApp messages you forward
3. Data organization: Cross-references contacts with deals and properties
4. Search and retrieval: Enables you to find past conversations and deal information

• We do not make automated decisions that significantly affect you without human review
• We do not profile you for advertising or third-party purposes
• We do not share AI-processed insights with third parties without your consent

AI transcription and extraction may not be 100% accurate. You can:

• Review and edit all extracted data before it's saved
• Correct transcription errors at any time
• Delete any AI-processed content

All AI processing is performed by OpenAI under our Data Processing Agreement. OpenAI does not use your data to train their models. Your data is processed for the sole purpose of providing Estell's features to you.

What we share: Message content and voice note transcriptions you send to Estell

Why: To power AI extraction and transcription features

Data Processing Agreement: We have a formal Data Processing Agreement (DPA) with OpenAI that:

• Designates OpenAI as a data processor acting on our behalf
• Prohibits OpenAI from using your data to train their models
• Requires data deletion after processing (retained max 30 days for abuse monitoring)
• Includes security and confidentiality obligations

OpenAI's location: United States. See Cross-Border Data Transfers below.

What we share: Metadata required to send and receive messages through WhatsApp

Why: Estell runs inside WhatsApp, so we use Meta's infrastructure to deliver messages

Meta's policies: Meta's data practices are governed by their own Privacy Policy. We only share what's necessary to operate the messaging functionality.

End-to-end encryption: WhatsApp messages are end-to-end encrypted. Meta cannot read message content, only metadata (timestamps, delivery status).

What we share: Payment details (credit card information, billing address)

Why: To process your subscription payments

Our commitment: We don't store your full credit card number. Our payment provider handles that securely.

We may share data with other vendors who help us run Estell (hosting, analytics, customer support tools). These providers are:

• Contractually bound to protect your data
• Only permitted to use it to provide services to us
• Prohibited from selling or disclosing your data

We may disclose information if required by law or in response to valid legal requests from public authorities. We will notify you unless prohibited by law.

You can request a copy of the personal information we hold about you, or request corrections if it is inaccurate. Email us at privacy@estell.ai with "Access Request" or "Correction Request" in the subject line. We'll respond within 30 days and provide the information in a commonly used format.

If we receive a privacy request (access, correction, or deletion) from one of your clients or contacts whose information you have stored in Estell, we will direct that individual to contact you directly. As the Data Controller of your CRM data, you are responsible for fulfilling these requests. We will assist you as reasonably necessary to fulfill your obligations under privacy laws.

You can delete your account and personal information at any time through the app or by emailing privacy@estell.ai with "Deletion Request." We'll process your request within 30 days.

See the "Your Consent and How We Obtain It" section above for details on withdrawing consent.

If you have a complaint about how we handle your personal information:

1. Contact us first at privacy@estell.ai. We'll investigate and respond within 30 days.
2. If we can't resolve your concern, you have the right to complain to:
   • Office of the Privacy Commissioner of Canada: www.priv.gc.ca | 1-800-282-1376
   • British Columbia Office of the Information and Privacy Commissioner: www.oipc.bc.ca | 250-387-3354