LAST UPDATED: 2026-04-27
VERSION: v1
First Access Signals is operated by Keith Godding, a real estate broker registered with the Toronto Regional Real Estate Board under THE AGENCY brokerage. This Privacy Policy describes how First Access Signals collects, uses, and protects your personal information when you use the mobile application and any related services (the "Service").
First Access Signals complies with the Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada's Anti-Spam Legislation (CASL). If you have questions, contact the privacy officer at
befirst@firstaccesshomes.com.
This is a Canadian product. The Service is intended for Canadian residents and is not designed for use in the United States, the European Economic Area, the United Kingdom, or any other jurisdiction outside Canada.
1. Introduction and scope
1.1 What this policy covers
This policy applies to:
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The First Access Signals mobile app (iOS and Android), bundle ID ca.firstaccesshomes.signals.
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Our web property at signals.firstaccesshomes.com.
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Email communications we send you (lead-conversion outreach, transactional emails, push notifications).
This policy does not apply to third-party websites or services that we link to. When you click an external link, the third party's own privacy policy applies.
1.2 Who is the privacy officer
Keith Godding serves as Chief Privacy Officer for V1. Contact:
befirst@firstaccesshomes.com. If you wish to escalate beyond First Access Signals, you may also file a complaint with the Office of the Privacy Commissioner of Canada at
priv.gc.ca.
1.3 Your consent
When you sign up for the Service, you consent to the collection, use, and disclosure of your personal information as described in this policy. You may withdraw consent for marketing messages at any time (see §6.3 below).
2. Information collected
First Access Signals deliberately collects a small amount of information. The Service does not collect financial data, government identification, social insurance numbers, or any data unrelated to helping you understand the value and timing of a real estate decision.
2.1 Information you give at signup
When you create an account by signing in with Apple or Google, First Access Signals receives:
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Your name (first name and last name).
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Your email address. If you use Apple's Hide My Email feature, we receive a @privaterelay.appleid.com address that forwards to your real email.
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A unique provider identifier from Apple or Google.
When you complete the profile wizard, we additionally collect:
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Your phone number, used by Keith to follow up about your real estate goals.
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Your real estate intent (for example, "thinking of selling," "actively buying").
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Optional secondary motivations (for example, "downsizing," "first-time buyer").
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Your acknowledgement of the bona-fide-consumer wording required by the TRREB Virtual Office Website (VOW) Datafeed Agreement.
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Your express consent to be contacted by Keith Godding under Canada's Anti-Spam Legislation (CASL).
We record the timestamp of each acknowledgement and the version of the wording you acknowledged.
2.2 Information collected as you use the Service
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Lookup queries. When you search for a home address or a neighbourhood, the Service records the query so it can show you the result and improve the model over time. Lookups are not stored in a way that identifies you publicly; they are linked to your account internally for support and audit.
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Saved homes. If you save a listing, the Service stores the listing identifier and the timestamp on your account.
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Device and session metadata. The Service logs your IP address, device type, app version, and the timestamps of your sessions for security, fraud prevention, and debugging. It does not log your precise GPS location.
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Crash reports. If the app crashes, First Access Signals collects a redacted stack trace. It does not include your personal information in crash reports.
2.3 Information NOT collected
For clarity, First Access Signals does not collect:
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Government-issued identification (driver's licence, passport, etc.).
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Social Insurance Number.
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Banking information, credit-card numbers, or credit scores.
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Income, employment, or employer details.
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Medical or health information.
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Tracking data across other apps or websites you visit.
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Children's data. The Service is not directed at anyone under 18.
If your real estate transaction with Keith proceeds beyond a lookup and into a representation agreement, additional identity verification will be required by the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). That collection is governed by a separate brokerage privacy notice, not this policy.
3. How information is used
First Access Signals uses your information for the following purposes:
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To run the Service. Authenticating you, generating your Market Signal, displaying your saved homes, and responding when you tap something in the app.
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To connect you with Keith Godding. When you sign up, the Service sends Keith one email with your name, email, phone, intent, and the timestamps of your VOW and CASL acknowledgements. Keith uses that information to follow up about your real estate goals.
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To send you transactional messages. A welcome email after signup with your dashboard link and the privacy, terms, and methodology references. Push notifications about saved-home Market Signal changes (when this feature ships).
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To send you commercial messages, with your consent. If you have given express CASL consent, First Access Signals may send you commercial follow-ups (lead-conversion emails from Keith). You may opt out at any time by tapping the unsubscribe link in any commercial message.
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To improve the Service. First Access Signals uses aggregated, de-identified usage data to find bugs, improve the model's accuracy, and design better features.
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To meet legal and regulatory obligations. Including the TRREB VOW audit-evidence retention requirement, CASL consent-record retention, and PIPEDA access-request fulfillment.
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To prevent fraud and abuse. Detecting suspicious account creation, scraping attempts, or attacks on the infrastructure.
First Access Signals will not use your information for any other purpose without first obtaining your consent.
4. How information is shared
First Access Signals shares your information only as described in this section. It does not sell your information.
4.1 With Keith Godding (the broker)
The single most important disclosure: when you sign up, the Service sends Keith one email containing your name, email, phone, real estate intent, and the timestamps of your VOW and CASL acknowledgements. Keith is the broker of record and will use your information to follow up about your real estate goals. This is the lead-conversion purpose you consented to at signup.
4.2 With service providers we use to run the Service
Email delivery (lead notification + transactional)
Maps, address autocomplete, tile rendering
Apple (App Store + Apple Sign In)
App distribution and identity provider
Google (Play Store + Google Sign-In)
App distribution and identity provider
Internal engineering tooling (does not see your data)
These providers process your information only on First Access Signals' instructions and only for the purposes described above. Where a provider is located outside Canada, your information may be subject to the laws of that jurisdiction.
4.3 With TRREB and other real estate boards
TRREB has the right under the VOW Datafeed Agreement to audit First Access Signals' compliance with the agreement, including reviewing the records of bona-fide-consumer acknowledgements. The timestamps and wording version of your acknowledgement may be disclosed to TRREB in response to such an audit.
4.4 Legal disclosure
First Access Signals may disclose your information when it believes in good faith that disclosure is necessary to:
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Comply with a court order, subpoena, or other lawful request from a government authority.
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Enforce our Terms of Service or this policy.
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Protect the rights, property, or safety of First Access Signals, our users, or others.
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Investigate or prevent fraud, security incidents, or violations of law.
4.5 Business transactions
If THE AGENCY brokerage or the Service is sold, merged, or transferred, your information may be transferred to the new owner. Any new owner will be bound by this policy (or a successor that gives you no less protection) unless you consent to a change.
4.6 With your consent
For any other disclosure, First Access Signals will ask you first.
5. Cookies and tracking technologies
The mobile app does not use traditional browser cookies. The web property at signals.firstaccesshomes.com uses:
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Essential cookies and local storage to keep you signed in and to remember your preferences. These cannot be turned off.
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Analytics cookies that count page visits and feature usage in aggregate. First Access Signals does not use third-party advertising cookies.
First Access Signals does not respond to Do Not Track signals. It does not allow third-party advertising networks to set cookies or pixels on the Service.
The mobile app uses standard iOS and Android device identifiers (advertising ID is NOT collected). Push notification tokens are stored when you opt in to push notifications.
6. Your rights
You have the following rights under PIPEDA and CASL.
6.1 Access and correction
You have the right to ask what personal information we hold about you and to ask us to correct it if it is inaccurate. To make a request, email
befirst@firstaccesshomes.com. We will respond within 30 days.
6.2 Deletion
You have the right to ask us to delete your account and your personal information. To make a request, tap "Delete account" in the app or email
befirst@firstaccesshomes.com. We will action the request within 30 days. Some information must be retained for the periods set out in §8 below; we will tell you which information cannot be deleted and why.
6.3 Opt out of marketing messages
You may opt out of commercial follow-up messages from Keith at any time by:
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Tapping the unsubscribe link at the bottom of any commercial email you receive.
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Adjusting your communication preferences in the app settings while signed in.
Opt-out takes effect within 10 business days as required by CASL §11(3).
You will continue to receive transactional messages (for example, the welcome email after signup, password-reset emails if email-and-password sign-in is enabled in a future version, security alerts) because those are exempt from the opt-out requirement under CASL §6(6).
6.4 Withdraw consent for non-marketing uses
You may withdraw your consent for the non-marketing uses described in this policy. Note that some uses are essential to the Service: if you withdraw consent for the basic processing required to authenticate you and generate your Market Signal, we will not be able to provide the Service to you and your account will be closed.
6.5 Complain to a regulator
If you believe we have not complied with PIPEDA or CASL, you may file a complaint with:
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Office of the Privacy Commissioner of Canada for PIPEDA matters:
priv.gc.ca or 1-800-282-1376.
7. Security
First Access Signals uses industry-standard safeguards to protect your information:
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Transport Layer Security (TLS) for all data in transit.
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Encryption at rest for the Postgres database hosting your account.
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Refresh tokens are stored on the server only as SHA-256 hashes; the plaintext token never leaves your device.
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Access tokens (JSON Web Tokens) are signed and expire every 15 minutes.
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On-device, refresh tokens are stored in expo-secure-store (the iOS Keychain or Android Keystore), gated by Face ID, Touch ID, or your device passcode.
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Access to production systems is limited to Keith Godding and is audited.
No system is perfectly secure. If First Access Signals ever experiences a breach affecting your information, it will notify you and the Office of the Privacy Commissioner of Canada as required by PIPEDA section 10.1.
8. Retention
First Access Signals retains your personal information for as long as your account is active and for three years after you delete your account, with these exceptions:
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Bona-fide-consumer ack records and CASL consent records are retained for the lifetime of your account plus three years. TRREB and the CRTC may audit these records during the retention window.
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Refresh tokens are deleted 30 days after issue or immediately when you sign out.
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Lookup query history is retained for 24 months and then deleted.
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Crash reports and debug logs are retained for 90 days.
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Mailjet send logs are retained per Mailjet's standard 30-day window.
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Aggregated, de-identified analytics may be retained indefinitely because they do not identify you.
After the applicable retention period, First Access Signals deletes or de-identifies the information.
9. International data transfers
Your information is stored primarily in Canada and the United States. Some of our service providers are located in other jurisdictions (for example, Mailjet is headquartered in France). When your information is transferred outside Canada, it may be subject to the laws of the jurisdiction where the provider operates, which may provide a different level of protection than Canadian law.
By using the Service, you consent to your information being transferred to and processed in these jurisdictions for the purposes described in this policy.
10. Children
The Service is not directed at children under the age of majority in their province (18 in Ontario). We do not knowingly collect information from children. If you believe a child has signed up, please contact
befirst@firstaccesshomes.com and we will delete the account.
11. Changes to this policy
First Access Signals may update this policy from time to time. When it does, it will:
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Update the "Last updated" date at the top.
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Increment the document version.
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Notify you by email (a transactional notice, not a commercial one) at least 14 days before the change takes effect, if the change is material.
Your continued use of the Service after the effective date of a change constitutes your acceptance of the updated policy.
12. Contact us
For any privacy question, request, or complaint:
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Mail: Keith Godding, c/o THE AGENCY, 2484 Bloor Street West, Unit 19, Toronto, Ontario M6S 1R5
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Phone: +1 (647) 368-6167
We respond within five business days for general questions and within 30 days for formal access, correction, or deletion requests.
End of policy.