Privacy Policy

Elite Tenants Inc. is a corporation incorporated in Ontario, Canada, with its business and mailing address at 122-64 Hurontario St, Collingwood, ON L9Y 2L6. This address receives all mail, including registered and couriered documents. We operate the website and applications at elitetenants.com.

Privacy Officer (designated under PIPEDA s.4.1):
Richard Campbell
Elite Tenants Inc.
122-64 Hurontario St
Collingwood, ON L9Y 2L6
privacy@elitetenants.com

You may contact our Privacy Officer at any time with questions, complaints, access requests, correction requests, or requests to withdraw consent. We acknowledge requests within 10 calendar days and respond fully within 30 calendar days.

Different parts of this policy apply depending on which service you use. Most users only use one.

Tenant credit-building. Tenants who want their verified rent payments — both on-time and missed — reported to a Canadian credit bureau (the bureau is named in the credit-reporting consent you give at enrolment). We connect to your bank read-only through Inverite (bank connections made before the move to Inverite in October 2026 were made through Plaid), detect monthly rent payments, verify them, and record Metro 2-format records. No records have been submitted to any credit bureau, and we have never reported anyone. We have asked a Canadian credit bureau to evaluate us as a data supplier. We have not been approved and there is no agreement under which we may report. We are not able to promise that any month recorded now will ever appear on a credit file.

Tenant screening. Prospective tenants who consent to be screened for a specific rental unit. We collect identity, address history, employment, income, and declarations through a guided questionnaire; pull a credit report from TransUnion with your express written consent; calculate a proprietary “Elite Score” based on credit, debt-service ratio, rental history, and tenure; and share the resulting report with the landlord or realtor who invited you (or whose listing you applied to), and with any other landlord or property manager only if you approve that person by name in your account.

We collect only what we need for the service you use (data minimization).

Identity & contact

• Full legal name, preferred name, date of birth, phone number, email address
• Social Insurance Number (SIN). Where you enrol in credit-building (and optionally during screening), we collect your nine-digit SIN because the credit bureaus require it to match your rent payments to the correct credit file. It is collected with your express consent, validated at entry, and immediately protected with envelope encryption — a unique data key per record, wrapped by a master key held outside the database — so a copy of the database alone cannot reveal it. Only the last four digits are ever displayed back to you or to our staff, the full SIN is never shown to landlords or included in screening reports, and it is used for no purpose other than credit-bureau consumer matching. If you do not provide a SIN we may be unable to report your rent payments to the bureau.
• For screening: address history (current + prior addresses with dates and previous landlord contact), employment history (employer, role, dates, monthly income, supervisor contact), self-reported declarations (e.g. past bankruptcy, eviction, criminal record)
• For screening, and for landlords, their team members and realtors before they can request one: identity verification through Inverite ID Verify (Inverite Verification Inc.). You photograph a government ID (driver’s licence, passport or provincial photo ID card) and take a live selfie on a page Inverite hosts. Inverite checks the document’s authenticity and compares your selfie to the photograph on it. The document image and the selfie are kept by Inverite; Elite Tenants never stores them, and Inverite’s dashboard may display them to Elite Tenants staff who hold a login. We keep only the pass/fail result and reason codes, the document type, the province or country that issued it and its expiry date, and the name and date of birth read from the document (the address on it, where there is one, is only offered to you as a suggestion and is not stored); the document number and sex in Inverite’s result are dropped on receipt. The facial comparison is a one-time check performed by the vendor; we do not build or hold a biometric database, and you may ask for an administrator review of your documents instead. Every such override is logged with a reason. Checks completed before the move to Inverite in October 2026 were run on the same basis by Stripe Identity, which keeps the images from those checks (Stripe’s dashboard can display them to the people who manage our Stripe account), and checks before September 22, 2026 by Plaid Identity Verification.

Financial & bank data

• Bank connection (through Inverite): read-only access to transaction history, account holder name, and institution. You sign in to your bank on Inverite’s page; we never see or store your banking credentials, login, or password, and we cannot initiate transfers from your account. Inverite keeps your bank sign-in so it can re-check your account each month; if your bank asks for a one-time code, we send you a link to sign in again. Connections made earlier through Plaid used an access token that is encrypted at rest and revoked when you disconnect.
• Bank income verification (optional): for screening, or for your Renter Passport, you may opt to verify your income from your bank. You sign in to your bank on Inverite’s page, and we read up to 12 months of your account history once, read-only, to work out a verified monthly income from your deposits and to check that the account is in your name. We store only the monthly income figure, how confident that reading is, the period it covers, the bank’s name, the last four digits of the account and the verification time — never your transactions, your payers or your account number. A Renter Passport shows only that your income was bank-verified and the date (and an affordability band if you have rent on file), never the figure; if a landlord screens you through Elite Tenants within 90 days, that screening may use the verified figure and show it to that landlord. To have the figure deleted, write to privacy@elitetenants.com. Earlier income checks used Plaid Income on the same basis.
• Stripe billing: if you subscribe to a paid plan, Stripe processes your card. We never store card numbers; we receive only a tokenised customer reference and subscription status from Stripe.

Credit bureau data

• For screening: with your express written consent, we request your credit report from TransUnion Canada. We receive your credit score, a list of trades (creditors with balances, payment history patterns, and trade types), recent credit inquiries, and certain risk factors. We use this data to calculate your Elite Score and to derive a Total Debt Service ratio using Canadian banking-standard rules. We retain this data only for the period set out in Section 9.
• For credit-building: once bureau reporting is active we will transmit your verified rent payments and required identifying details (name, address, DOB, account number, payment history) to the Canadian credit bureau named in your enrolment consent, in the Metro 2 format on the agreed reporting cadence. Nothing has been transmitted to a bureau to date.

Lease & document data

• Your signed lease agreement (PDF). We send it to our AI provider (OpenAI, United States) to extract the parties, address, rent amount and lease term and compare them with what you entered. Where that automated check, your bank connection and your identity data all agree, your lease may be approved automatically, without a person reviewing it; anything flagged is reviewed by an Elite Tenants reviewer, and you may ask for a manual review at support@elitetenants.com. The document is not used to train AI models. The PDF is stored in private, access-controlled storage with short-lived signed URLs.
• Optional supporting documents you choose to upload during screening (e.g. paystubs, pay stubs, bank letters).

Consent records (legally required)

• The version and a SHA-256 fingerprint of the exact consent text you saw, the date and time, your IP address and your browser, kept in an append-only ledger. This is your receipt that you agreed to a specific scope on a specific date.

Operational & security data

• App activity logs (sign-ins, key actions, IP addresses) — retained for security, fraud detection, and incident response.
• Audit logs of credit-data access (every read, view, export, pull, cache hit, purge) — retained indefinitely as a regulatory requirement.
• Error and performance data via Sentry (when enabled) — used to fix bugs.

We do not sell your personal information to anyone. We do not share your information for advertising. We do not use your information to train any third-party machine-learning model.

We use your information only for the following purposes:

• Verifying your identity and rental arrangement
• Detecting and verifying monthly rent payments via your bank feed
• Recording and verifying your monthly rent payments where you have enrolled in our credit-building service. Those payments would be reported to a Canadian credit bureau only if reporting ever becomes active, and it has not started
• Pulling a credit report from TransUnion Canada with your express written consent for a specific rental application
• Computing a proprietary screening score (the “Elite Score”) based on credit, total debt service ratio, on-platform rental history, and employment tenure
• Generating a screening report and sharing it with the landlord or realtor who requested it, and with any other landlord or property manager you approve by name
• Processing subscription payments through Stripe
• Sending transactional communications (account, payment, lease, dispute updates, adverse-action notices)
• Providing customer support
• Detecting and preventing fraud, abuse, and security incidents
• Complying with legal obligations (consumer reporting acts, anti-spam law, tax law, anti-money-laundering law where applicable)

We will not use your information for any new purpose without first obtaining your consent.

We rely on your express, informed consent for everything we do. You will be asked to consent at specific moments:

• When you first set up your account, whichever way you arrive: setting up a landlord or property-manager account, joining a company as a team member, accepting a screening invitation or applying to a listing, claiming a resident-portal invitation, or enrolling in credit-building. You accept our Terms and this Policy and consent to your information being processed outside Canada.
• When you enrol in credit-building (rent recording now, and reporting to a credit bureau once that is active) — a separate, express consent.
• When you submit a screening for a specific landlord — a separate, versioned consent that names the landlord, lists the fields shared, and authorises a credit inquiry from TransUnion Canada for that application only. You may see that inquiry when you view your own credit file.
• When you connect a bank account through Inverite (read-only; earlier connections used Plaid), when you verify your identity through Inverite ID Verify (earlier checks used Stripe Identity, under the consent shown at the time), and when you opt in to verify your income from your bank through Inverite (earlier income checks used Plaid Income).
• If we change the scope of what we collect, we ask again.

Each consent is recorded with the version and a fingerprint of the exact text you saw, the date and time, your IP address and your browser. You can request a copy of your consent records at any time; they are also included in the in-app data export (Settings → Data export).

Withdrawing consent. You may withdraw any consent at any time, subject to legal and contractual restrictions. Withdrawing consent for credit reporting will pause future reporting; it does not retroactively remove records already submitted to the bureaus (you must dispute those directly with us or with the bureau). Withdrawing consent for the bank connection will end automatic payment detection. To withdraw any consent, contact privacy@elitetenants.com.

We share your information only as described below, and only with providers whose data-processing terms limit their use of your information to providing their service to us.

Service providers (subprocessors)

Landlords / property managers

When you submit a screening for a specific landlord or unit, the landlord receives a screening report containing the data fields you consented to share. The exact fields are listed in the consent text shown to you at the time of submission. Landlords are bound by a Landlord Data-Sharing Agreement that prohibits them from sharing your screening report with any other party and requires them to retain it only for the duration permitted under provincial Consumer Reporting Acts.

If you approve sharing your report with a landlord or property manager through your account, they see only the items listed on the approval screen, for no more than 30 days. Before opening it they must confirm that they are deciding your rental application, and agree not to share it and to delete copies once they decide. You can withdraw an approval at any time from your application page; that stops the link but cannot undo what was already viewed. We keep a record of each approval, including the recipient’s name and phone number, and of when the report was opened, for at least one year, because you may ask us who received your report.

Renter Passport. If you build a Renter Passport, we show it only to a person you name in your account, for 7, 14 or 30 days as you choose, after that person confirms they are deciding your rental application and agrees not to share it and to delete copies once they decide. They see the items listed on the approval screen: your name and that your identity was verified, your credit band (never your exact score or file), your verified rent months, an affordability band as of the date your income was last bank-verified (never an income figure), and the month you joined. You can withdraw any Passport link at any time from your Passport page; that stops the link but cannot undo what was already viewed. We keep a record of each approval, including the recipient’s name and phone number, and of each time your Passport was opened, for at least one year, because you may ask us who received it. A credit band shown through your Passport is logged like every other credit read.

When required by law

We may disclose your information if compelled by a valid Canadian court order, subpoena, or other legal process, or where disclosure is necessary to protect Elite Tenants’ legal rights, prevent fraud, or protect the safety of any person.

Some of our service providers process data in jurisdictions outside Canada, primarily the United States. By using our service and granting consent to this policy, you expressly consent to your personal information being transferred to and processed in those jurisdictions. While those jurisdictions may have privacy laws different from Canada’s, we contractually require all processors to implement protections substantially equivalent to Canadian standards, including encryption, access controls, breach notification, and prohibitions on secondary use.

Your personal information is stored and processed in the United States. Our database and file storage run in Amazon Web Services’ us-west-2 region (Oregon, United States), operated for us by Supabase. While your information is in the United States, it is subject to United States law, and United States courts, law-enforcement agencies and national-security authorities may be able to obtain access to it under that law — including by means that do not require notice to you or to us. This disclosure is made so that your consent to cross-border processing is informed, as PIPEDA requires.

Application compute runs at Vercel’s global edge, handling transient request/response data only — there is no persistent customer data on Vercel infrastructure. If you would prefer your information not be processed in the United States, do not use the service; contact privacy@elitetenants.com with any questions first.

Not every provider is in the United States: TransUnion processes in Canada, Inverite processes in Canada and uses service providers in the United States and Brazil, and SMTP2GO processes in New Zealand. The providers that process your information outside Canada are listed in Section 6. Questions about processing outside Canada: our Privacy Officer can tell you how your information is handled outside Canada and how it is protected there — privacy@elitetenants.com, or by mail to the address in Section 1.

• Encryption in transit: TLS 1.2+ on all connections; HSTS preloaded for 2 years.
• Encryption at rest: AES-256 disk-level encryption (Supabase managed) on all database storage and file storage.
• Application-level encryption: the most sensitive identifier we store — your Social Insurance Number — is protected with envelope encryption: a unique data key per record, itself wrapped by a master key held in our application secrets manager, separate from the database. A copy of the database alone does not reveal it.
• Access control: every request is authorized in application code against your authenticated identity and role, so you can only access your own records. Administrative access to sensitive data additionally requires two-factor authentication, may be restricted to an allow-listed network, and is recorded in the append-only audit log described below.
• Authentication and access control: identity provided by Clerk, with mandatory two-factor authentication (TOTP or SMS) enforced on every administrative account. Landlord and property-manager accounts are prompted to enrol in two-factor authentication.
• Audit log: every credit-data access is recorded in an append-only log secured with cryptographic hash chaining, so any tampering is detectable.
• Kill switch: our operations team can disable all credit-data access platform-wide in seconds if a systemic issue is detected.
• Rate limits: credit-pull and report-view endpoints are rate-limited to deter scraping and credential-stuffing.
• Personnel: only named employees with a legitimate business need have production access. Access reviews occur quarterly. Access is revoked within 24 hours of role change or separation.
• Bank credentials: we never see, store, or have access to your banking login. You sign in to your bank on Inverite’s page (for older connections, Plaid’s), not ours.
• Card data: we never see, store, or have access to your card numbers. Stripe handles all payment authentication.

We retain your information only as long as necessary to fulfil the purposes for which it was collected, and never longer than is required by applicable law.

• Credit reports (screening): the credit report and its trade-level details are retained for up to 90 days from the date of pull, then automatically purged by a scheduled retention job. The same 90 days governs our reuse cache, so we do not request a duplicate report within the window unless you ask us to delete the one we hold. After 90 days, we keep only the audit trail of the pull (who, when, under what consent), not the credit data itself.
• Screening reports: retained for up to 90 days after the screening is approved or declined, or after it was submitted where no decision is made, then automatically reduced to a minimal record (status, consent receipt, approval/decline decision, and audit trail).
• Profile data (name, address, employment, declarations) for active users: retained while your account remains active. Deleted within 30 days of a verified account-deletion request.
• Payment, subscription, tax records: retained for 7 years as required by the Income Tax Act (Canada) and CRA guidelines. After the active period, these records are reduced to the minimum necessary for tax and audit purposes.
• Operational activity logs: automatically pruned on fixed schedules by category — notification and email-delivery logs after 180 days, account lifecycle events after 12 months, and landlord/property-manager team activity logs after 18 months.
• Audit logs of credit-data access: retained indefinitely. This is required by our agreements with the credit bureaus and by provincial Consumer Reporting Acts as the official record of every credit-data interaction. These logs do not contain credit-report content; they contain only metadata (who, when, where, under what consent, what action).
• Records of staff actions on your account (for example, recording a consent withdrawal, correcting your information, or pausing credit reporting) are kept as the record of what was done, by whom, when and why. When a correction replaces a value, the previous value is kept encrypted for 24 months and then deleted.
• Closed accounts (no deletion request): profile data is reviewed for deletion 90 days after subscription cancellation. This review is performed manually by our Privacy Officer rather than by an automated job, so the exact date varies. If you want your data deleted on a definite timeline, email privacy@elitetenants.com and we will complete it within 30 calendar days, as set out in Section 10.

You may request earlier deletion of your cached credit report at any time through the in-app “Delete my credit report” control or by emailing privacy@elitetenants.com.

Under PIPEDA and applicable provincial privacy laws, you have the right to:

• Access: request a copy of the personal information we hold about you.
• Correction: request correction of inaccurate or incomplete information.
• Deletion: request deletion of your personal information, subject to retention obligations (e.g. tax records). Credit data already submitted to the bureaus cannot be recalled by us; however, you may dispute any reported item.
• Portability: receive your data in a structured, commonly used, machine-readable format (export available in-app from Settings → Data export).
• Know which agency reported on you, and see your file: if a landlord has used a screening report about you, you may ask the landlord, or us at privacy@elitetenants.com, for the name and address of the consumer reporting agency; we answer within 10 calendar days. The agency we use is TransUnion Canada. You may obtain a free copy of your own credit file from TransUnion Canada and ask it to correct errors (1-800-663-9980 or transunion.ca); we will give you its current mailing address on request.
• Withdraw consent: withdraw any consent previously given by emailing our Privacy Officer at privacy@elitetenants.com with the word “withdraw” and which consent you are withdrawing. There is currently no in-app self-service control for this — withdrawal is handled manually. We acknowledge within 10 calendar days, action it within 30, record it against your account, and confirm in writing what stopped. Withdrawing consent for ongoing services may require account cancellation and cessation of rent recording and credit reporting. (Marketing email is the exception: use the unsubscribe link in any commercial message — that is instant and self-service.)
• Object to processing: object to specific uses of your data to the extent applicable provincial law grants such a right.
• Dispute reported credit data: if you believe a payment was reported in error, contact disputes@elitetenants.com; we will investigate within 30 days and submit a Metro 2 correction to the bureaus if the report was wrong.
• Lodge a complaint: file a complaint with the Office of the Privacy Commissioner of Canada (priv.gc.ca). Quebec residents may also contact the Commission d’accès à l’information du Québec (cai.gouv.qc.ca). Residents of Alberta and British Columbia may contact their respective provincial Information and Privacy Commissioners.

To exercise any of these rights, email privacy@elitetenants.com. We acknowledge requests within 10 calendar days and respond fully within 30 calendar days. There is no fee for these requests.

If you are a resident of Quebec, you have additional rights under Quebec’s Act Respecting the Protection of Personal Information in the Private Sector, including:

• The right to data portability in a structured, commonly used technological format.
• The right to be informed of any automated decision-making that significantly affects you. Our screening produces an “Elite Score” that is one input the landlord considers; the landlord — not Elite Tenants — makes the final approve/decline decision. You may request a human review of any automated processing on request.
• The right to request that your information no longer be communicated to third parties or used to contact you.
• Enhanced de-indexation rights (removal from search engines or automated profiles, where applicable).

To exercise Quebec-specific rights, email privacy@elitetenants.com with “Quebec Law 25 Request” in the subject line.

If a landlord declines your rental application based in whole or in part on information provided by us, you will receive an “adverse action” notice from us by email. The notice will identify the credit bureau whose information was used and inform you of your right to obtain a free copy of your credit report from that bureau, your right to dispute inaccurate information, and the contact information for relevant provincial human-rights tribunals if you believe you were declined for a prohibited reason.

Our screening process includes automated calculations: a credit-bureau-derived debt-service ratio and a weighted Elite Score combining credit, debt-service, on-platform rental history, and employment tenure. The score is presented to the landlord alongside the underlying data so the landlord can make an informed decision. The landlord — not Elite Tenants — decides whether to approve or decline a rental application. You may request human review of any automated calculation by emailing privacy@elitetenants.com. A short written summary of each screening report is also generated by an AI model (OpenAI) from the figures in the report, with the credit score given to it only as a range. It contains no recommendation, the landlord sees the underlying figures beside it, and you may ask for it to be reviewed or corrected by emailing privacy@elitetenants.com.

Elite Tenants is not for children. Do not use it if you are under 16. If we learn that we hold personal information about someone under 16, we will delete it, except anything the law requires us to keep.

If you are 16 or older but have not reached the age of majority in the province or territory where the rental home is (18, or 19 in British Columbia, New Brunswick, Newfoundland and Labrador, Nova Scotia, the Northwest Territories, Nunavut and Yukon), you can be screened for that home with an adult co-signer (guarantor) on your application. For you:

• We do not request a credit report about you. Your co-signer’s credit is used for the application instead.
• We do not use the online ID-and-selfie check on you. The landlord checks your photo ID in person instead.
• The landlord is told that you have not reached the age of majority and that your application needs a co-signer. We never give the landlord your date of birth or your exact age.
• Your co-signer completes their own screening. They do not see your screening. You see only their name and whether they have finished. If the landlord declines the application, we may send your co-signer a notice that their credit report was used.
• In Ontario, if you are 16 or 17 and have withdrawn from parental control, you can tell us so. Ontario law then lets a lease be enforced against you as if you were 18, and you are screened like any adult applicant, including a credit check, except that the landlord checks your photo ID in person. We keep your statement in our consent records and do not show it to the landlord.

The credit-building service and credit-bureau reporting are for adults only. We never report anyone’s rent to a credit bureau while they are under the age of majority.

We set a small number of first-party cookies. We do not use advertising cookies or third-party tracking pixels, and we do not sell or share what these cookies record.

Analytics. We use Vercel Web Analytics to count page views and understand which pages are used. It is cookieless — it sets no cookie, does not follow you across other websites, and does not build a profile of you. It is the only analytics on the service; we do not use Google Analytics, advertising pixels, or session-replay tools.

Why there is no cookie banner. None of the above tracks you across other websites or builds an advertising profile, and no cookie is set for advertising. Under Canadian law (CASL s.8 and its CRTC guidance) your browser settings are treated as your consent to ordinary cookies of this kind. You can delete or block any of them in your browser at any time; blocking the Clerk session cookie will sign you out, and blocking the others costs you only the small conveniences described above.

We send transactional communications (account notifications, payment receipts, lease and dispute updates, adverse-action notices) without separate consent because they are necessary for the contracted service.

We send commercial or promotional email only where we have express consent (the marketing checkbox at signup) or an existing business relationship that permits it. As required by Canada’s Anti-Spam Legislation, every commercial message we send identifies us, carries our physical mailing address (122-64 Hurontario St, Collingwood, ON L9Y 2L6, Canada), gives contact information that stays valid for at least 60 days, and includes a one-click unsubscribe link. We also set the standard List-Unsubscribe headers so your mail app’s own unsubscribe button works. Unsubscribe requests take effect immediately and in no case later than 10 business days.

Unsubscribing stops commercial email only. Transactional messages required to operate the service you contracted for — receipts, security notices, dispute outcomes, adverse-action notices, legal notices — continue, as CASL s.6(6) permits.

If we experience a breach of security safeguards involving personal information under our control that creates a real risk of significant harm to any individual, we will:

• Notify the Office of the Privacy Commissioner of Canada as soon as feasible.
• Notify each affected individual directly, by email or another reliable means, within 72 hours of confirming the breach.
• Maintain a record of all breaches as required by PIPEDA, regardless of whether they triggered notification obligations.
• If the breach involves credit-bureau data, also notify TransUnion Canada within 24 hours of confirmation, as we have committed to do.

If you believe your account has been compromised, contact security@elitetenants.com immediately.

We will notify registered users by email at least 30 days before any material change to this policy takes effect. The version number and last-updated date at the top of this page reflect the current version. You may request copies of any prior version at any time by emailing privacy@elitetenants.com. Continued use of the service after a change takes effect constitutes acceptance of the updated policy.

Elite Tenants Inc.

122-64 Hurontario St, Collingwood, ON L9Y 2L6, Canada

privacy@elitetenants.com — Privacy Officer (access, correction, deletion, complaints, consent withdrawal)
disputes@elitetenants.com — Credit-bureau report disputes
security@elitetenants.com — Security incidents
support@elitetenants.com — General support