GenLedge - Privacy Policy

Last Updated: February 7, 2026

1. Information We Collect

1.1 Personal Information

When you submit a mortgage application or use our services, we may collect the following personal information:

• Name and contact information (email address, phone number, mailing address)
• Financial information (income, assets, credit history, employment details)
• Identification information (date of birth, government-issued ID)
• Property information (purchase price, property address)
• Any other information you provide to help us deliver our services

1.2 Usage Data

We automatically collect certain information when you visit our website, including:

• Browser type and version
• Internet Protocol (IP) address
• Pages you visit on our site and time spent on each page
• Time and date of your visit
• Referring website or source
• Device information (operating system, screen resolution)

1.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website, including:

• Google Analytics: To measure site activity and understand user behavior
• Advertising Cookies: For Google Ads remarketing campaigns
• Essential Cookies: To enable core website functionality

1.4 Google Workspace Data

When you choose to connect your Google Workspace account (Gmail, Google Calendar, Google Drive) to GenLedge, we may access and use the data you authorize us to access. This access is always subject to your explicit consent and is limited to providing the specific features you request.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Providing Services: To process your mortgage applications, connect you with approved lenders and local agents, and deliver the financial services you request
• Communication: To respond to your inquiries, provide customer support, and send you important updates about our services
• Analytics and Improvement: To generate anonymized statistics, understand user needs, and improve our services and website
• Marketing: To send you information about our services (with your consent) and display relevant advertisements
• Legal Compliance: To comply with applicable laws, regulations, and legal processes
• Security: To detect, prevent, and address fraud, security issues, and technical problems

3. Google API Services Data Usage

3.1 Google API Services We Use

GenLedge integrates with the following Google services to enhance your experience:

• Google Workspace APIs: Gmail API, Google Calendar API, and Google Drive API (when you authorize access)
• Google Analytics: For website traffic analysis and user behavior insights
• Google Ads/AdWords: For advertising and remarketing campaigns

3.2 Limited Use Disclosure

3.3 How We Use Google Workspace Data

When you authorize GenLedge to access your Google Workspace data (Gmail, Calendar, Drive), we use this information only to:

• Provide or improve user-facing features that are prominent and visible in GenLedge's user interface
• Deliver the specific functionality you have requested and consented to
• Enhance your experience with our financial services platform

We guarantee that data received from Google Workspace APIs is:

• Never sold or transferred to third parties
• Never used for advertising purposes, including serving ads, retargeting, or personalized advertising
• Used only with your explicit consent
• Limited strictly to the practices disclosed in this Privacy Policy

3.4 Data Transfer Restrictions

Data received from Google APIs is transferred only in the following limited circumstances:

• Service Delivery: To provide or improve user-facing features that are visible and prominent in our application's user interface, and only with your consent
• Security Purposes: For investigating abuse, fraud, or security issues
• Legal Compliance: To comply with applicable laws, regulations, or valid legal processes
• Business Transfers: As part of a merger, acquisition, or sale of assets, and only after obtaining your explicit prior consent

3.5 Human Access to Google Data

We do not allow our employees, contractors, or any other persons to read data received from Google APIs unless one of the following conditions applies:

• Your Consent: We have obtained your affirmative agreement to view specific messages, files, or other data
• Security: It is necessary for security purposes, such as investigating a bug, abuse, or fraud
• Legal Requirement: It is necessary to comply with applicable law or legal process
• Aggregated Data: The data has been aggregated and anonymized for internal operations in accordance with applicable privacy and legal requirements

3.6 Prohibited Uses

GenLedge explicitly does NOT and will NOT:

• Transfer or sell user data to third parties such as advertising platforms, data brokers, or information resellers
• Use user data for serving ads, including retargeting, personalized advertising, or interest-based advertising
• Use user data to determine credit-worthiness or for lending purposes beyond the services you explicitly request
• Train artificial intelligence or machine learning models on your data (except for user-specific personalization features that directly benefit you)

3.7 Employee and Contractor Compliance

All GenLedge employees, agents, contractors, successors, and third-party service providers are required to comply with the Google API Services User Data Policy and this Privacy Policy. We ensure that anyone with access to user data is bound by confidentiality obligations and trained on data protection requirements.

4. How We Share Your Information

4.1 Service Providers and Partners

With your prior consent, we share your personal information with:

• Approved Lenders: Financial institutions that can provide you with mortgage and lending services
• Local Agents: Licensed agents in Canadian provinces who assist with your financial services needs
• Service Providers: Third-party companies that help us deliver our services (e.g., payment processors, hosting providers, customer support tools)

We restrict our service providers from using your personal information except to provide services on our behalf or as required by law.

4.2 Legal Requirements

We may disclose your information when required by law, court order, government request, or legal process, or when we believe disclosure is necessary to:

• Comply with legal obligations
• Protect our rights, property, or safety
• Protect the rights, property, or safety of our users or the public
• Investigate fraud or security issues

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity. We will provide notice and seek your consent before your information is transferred and becomes subject to a different privacy policy.

4.4 We Never Sell Your Data

GenLedge does not sell your personal information to third parties. We do not and will not sell, rent, or trade your personal data to advertisers, data brokers, or other third parties for their marketing purposes.

5. Data Security

We take the security of your personal information seriously and have implemented industry-standard security measures to protect your data, including:

• Encryption: We use SSL/TLS encryption to protect data transmitted between your browser and our servers
• Access Controls: We employ unique usernames and passwords to restrict access to personal information
• Firewalls: We use firewalls and other security technologies to protect against unauthorized access
• Limited Access: Only authorized employees and contractors with a legitimate need to access your information are granted access
• Security Audits: We regularly review and update our security practices
• SOC 2 Compliance: We follow security best practices aligned with industry standards

However, no data transmission over the Internet or electronic storage system can be guaranteed to be 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You transmit information to us at your own risk.

6. Data Retention

We retain your personal information for as long as necessary to provide our services and fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

• Account Data: We retain your profile information and credentials for as long as you maintain an active account with us
• Transaction Data: Financial and transaction records are retained as required by Canadian Anti-Money Laundering (AML) regulations and other applicable financial services laws
• Marketing Data: Data used for marketing purposes is retained until you opt out or withdraw consent
• Legal Obligations: Some data may be retained longer if required to comply with legal, regulatory, or contractual obligations

When we no longer need your personal information, we securely delete or anonymize it in accordance with our data retention policies and applicable law.

7. Your Privacy Rights

7.1 Rights Under GDPR (European Users)

If you are located in the European Economic Area (EEA), you have the following rights under the General Data Protection Regulation (GDPR):

• Right to Access: You can request a copy of the personal information we hold about you
• Right to Rectification: You can request that we correct inaccurate or incomplete personal information
• Right to Erasure ("Right to be Forgotten"): You can request that we delete your personal information, subject to certain legal exceptions
• Right to Restrict Processing: You can request that we limit how we use your personal information
• Right to Data Portability: You can request a copy of your personal information in a structured, machine-readable format
• Right to Object: You can object to our processing of your personal information for certain purposes, including direct marketing
• Rights Related to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing that significantly affects you

7.2 Rights Under CCPA/CPRA (California Users)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: You can request information about the categories and specific pieces of personal information we have collected about you in the past 12 months, including the sources of that information, our business purposes for collecting it, and the categories of third parties with whom we share it
• Right to Delete: You can request that we delete the personal information we have collected from you, subject to certain legal exceptions
• Right to Correct: You can request that we correct inaccurate personal information we maintain about you
• Right to Opt-Out of Sale: You have the right to opt out of the "sale" of your personal information (Note: GenLedge does not sell personal information)
• Right to Limit Use of Sensitive Personal Information: You can request that we limit our use of your sensitive personal information
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA/CPRA privacy rights

7.3 How to Exercise Your Rights

To exercise any of your privacy rights, please contact us at:

• Email: hello@genledge.ai
• Phone: +1 437 873 7345

We will respond to your request within the timeframes required by applicable law (typically 30 days for GDPR requests and 45 days for CCPA/CPRA requests). We may need to verify your identity before processing your request.

Please note that certain information may be exempt from deletion requests due to legal obligations, including Canadian Anti-Money Laundering (AML) regulations. We will inform you if we cannot fully comply with your request and explain the reasons why.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small text files stored on your device that help us understand how you use our site.

8.1 Types of Cookies We Use

• Essential Cookies: Required for the website to function properly
• Analytics Cookies (Google Analytics): Help us understand how visitors use our site by collecting anonymous information about pages visited, time spent, and user behavior
• Advertising Cookies (Google Ads/AdWords): Used to display relevant ads based on your browsing behavior and measure ad campaign effectiveness
• Remarketing Cookies: Allow us to show you relevant ads across the internet based on your previous visits to our site

8.2 Google AdWords Remarketing

We use Google AdWords remarketing to advertise GenLedge across the Internet. AdWords remarketing displays relevant ads tailored to you based on which parts of our website you have viewed. These cookies do NOT identify you personally or give us access to your computer. The cookies simply tell us "this anonymous person visited this page, so show them ads relating to that page."

We will never associate personally identifiable information with our AdWords and remarketing lists.

8.3 How to Manage Cookies

You can control and manage cookies in several ways:

• Browser Settings: Most web browsers allow you to refuse or delete cookies through your browser settings. Please refer to your browser's Help documentation for instructions
• Google Ads Opt-Out: Visit Google's Ads Preferences Manager
• Third-Party Opt-Out: Visit Network Advertising Initiative

Please note that disabling certain cookies may limit your ability to use some features of our website.

9. International Data Transfers

GenLedge is based in Canada, and your personal information is primarily processed and stored in Canada. If you are accessing our services from outside Canada, please be aware that your information may be transferred to, stored, and processed in Canada or other countries where we or our service providers operate.

We ensure that any international transfers of personal data are protected by appropriate safeguards, including:

• Standard contractual clauses approved by the European Commission (for GDPR compliance)
• Adequacy decisions by relevant data protection authorities
• Your explicit consent where required

10. Children's Privacy

GenLedge's services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16 years of age. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately at hello@genledge.ai.

If we learn that we have collected personal information from a child under 16 without verifiable parental consent, we will delete that information as quickly as possible. If you believe we might have information from or about a child under 16, please contact us.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will:

• Update the "Last Updated" date at the top of this Privacy Policy
• Notify you of material changes via email or through a prominent notice on our website
• Obtain your consent if required by applicable law

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of our services after changes are posted constitutes your acceptance of the updated Privacy Policy.

12. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We are committed to working with you to resolve any privacy concerns. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.

13. Third-Party Links and Services

Our website may contain links to third-party websites, services, or applications that are not owned or controlled by GenLedge. This Privacy Policy applies only to information collected by GenLedge.

We are not responsible for the privacy practices or content of third-party websites. When you click on a link to a third-party website, you will be subject to that website's privacy policy. We encourage you to read the privacy policies of any third-party websites you visit.

Third-party advertisers, sponsors, and partners may also set their own cookies, collect data, and solicit information through our website. GenLedge does not control these third parties and is not responsible for their privacy practices.

14. Your Acceptance of These Terms

By using our website or services, or by submitting personal information to us, you signify your agreement to this Privacy Policy and our Terms of Service. If you do not agree with this Privacy Policy, please do not use our services or provide us with your personal information.

This Privacy Policy does not create any contractual or other legal rights in or on behalf of any party beyond those provided by applicable law.

© 2026 GenLedge Inc. All rights reserved.