LAST UPDATED: 2026-06-25
VERSION: v2.1
First Access Signals is operated by Keith Godding, a REALTOR® and member of the Toronto Regional Real Estate Board, working under THE AGENCY brokerage. This Privacy Policy describes how we collect, use, and protect your personal information when you use the First Access Signals mobile app and related services (the "Service").
We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada's Anti-Spam Legislation (CASL). For any privacy question or request, contact us at
befirst@firstaccesshomes.com. The Service is intended for Canadian residents and is not designed for use outside Canada.
When you sign up, you consent to the collection, use, and disclosure of your personal information as described in this policy. You can withdraw consent for marketing messages at any time (see "Your rights" below).
1. Information we collect
We deliberately collect a small amount of information. We do not collect financial data, government identification, or anything unrelated to helping you understand the value and timing of a real estate decision.
1.1 Information you give us
When you create an account with Apple, Google, or email and password, we receive your name, your email address, and (for the Apple and Google options) a unique provider identifier. When you complete the profile wizard, we also collect your phone number, your real estate intent (for example, "thinking of selling" or "actively buying"), and your acknowledgement of the bona-fide-consumer wording and the CASL consent we ask for at signup. We record the date of each acknowledgement.
1.2 Information collected as you use the Service
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Lookups and saved homes. When you search an address or neighbourhood, or save a listing, we record it on your account so we can show you the result and your saved items.
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Device and session data. We log basic technical data such as IP address, device type, app version, and session timestamps for security, fraud prevention, and debugging. We do not collect your precise GPS location.
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Crash reports. If the app crashes, we collect a redacted diagnostic report that does not include your personal information.
1.3 What we do not collect
For clarity, we do not collect:
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Government-issued identification or Social Insurance Number.
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Banking information, credit-card numbers, or credit scores.
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Income, employment, medical, or health information.
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Your precise GPS location.
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Tracking data about other apps or websites you use.
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Information from children. The Service is not directed at anyone under 18.
If a real estate transaction proceeds into a representation agreement, additional identity verification may be required by law. That collection is governed by a separate brokerage privacy notice, not this policy.
2. How we use your information
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To run the Service. Authenticating you, generating your Signal, and showing your saved homes.
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To connect you with Keith Godding. When you sign up, we send Keith your name, email, phone, and intent so he can follow up about your real estate goals. This is the lead-conversion purpose you consent to at signup.
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To send transactional messages. Such as a welcome email and notifications about saved-home Signal changes you opt into.
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To send commercial messages, with your consent. If you give express CASL consent, we may send follow-up messages from Keith. You can opt out at any time.
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To improve the Service and prevent abuse. Using aggregated, de-identified usage data, and detecting fraud, scraping, or attacks.
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To meet our legal and regulatory obligations. Including the records our MLS data agreement and CASL require us to keep.
We will not use your information for any other purpose without first asking you.
3. How we share your information
We share your information only as described below, and we do not sell it.
3.1 With Keith Godding (your REALTOR®)
The most important disclosure: when you sign up, we send Keith your name, email, phone, and real estate intent. Keith is the REALTOR® you are connecting with and uses this information to follow up about your real estate goals. This is the purpose you consent to at signup.
3.2 With service providers
We use trusted service providers to help us operate the Service. They process your information only on our instructions and only to provide their service to us. Some are located outside Canada, so your information may be subject to the laws of those jurisdictions.
To protect our signup and other forms from automated abuse, we use Cloudflare Turnstile. Turnstile runs a check in your browser and may process technical signals such as your IP address, browser and device characteristics, and interaction patterns to tell a real person from an automated bot. It does not ask you to solve a puzzle, and it is not used to track you across other websites. Cloudflare processes this data as our service provider under its Turnstile Privacy Addendum, available at
cloudflare.com/turnstile-privacy-policy.
3.3 With TRREB
TRREB may audit our compliance with the VOW Datafeed Agreement, including the records of your bona-fide-consumer acknowledgement. We may disclose those records to TRREB in response to such an audit.
3.4 Legal and business reasons
We may disclose your information when we believe in good faith it is necessary to comply with the law, enforce our Terms, or protect the rights, property, or safety of our users or others. If the Service is sold, merged, or transferred, your information may transfer to the new owner under a policy that gives you no less protection. For any other disclosure, we will ask you first.
4. Cookies and tracking
The mobile app does not use browser cookies. Our website uses essential cookies to keep you signed in and remember your preferences, and privacy-respecting analytics that count page visits and feature usage in aggregate. We do not use third-party advertising cookies, we do not collect a device advertising identifier, and we do not let ad networks track you through the Service. Push notification tokens are stored only if you opt in to push notifications.
5. Your rights
You have the following rights under PIPEDA and CASL.
5.1 Access and correction
You can ask what personal information we hold about you and ask us to correct it. Email
befirst@firstaccesshomes.com and we will respond within the timeframe the law requires.
5.2 Deletion
You can permanently delete your account at any time in the app: open the Account tab, tap "Delete account", and confirm. This removes your account, saved homes, and alert preferences and signs you out everywhere. If you no longer have the app, email
befirst@firstaccesshomes.com from your account address and we will action it. Some records must be retained for the periods our MLS data agreement and the law require; we will tell you what cannot be deleted and why.
5.3 Opt out of marketing
You can opt out of commercial follow-up messages at any time by tapping unsubscribe in any commercial email, adjusting your communication preferences in the app, or emailing
befirst@firstaccesshomes.com. You will still receive transactional messages (such as the welcome email and security notices), which are exempt from the opt-out requirement under CASL.
5.4 Withdraw consent and complain
You can withdraw consent for non-marketing uses, though some uses are essential to providing the Service and withdrawing them may mean we have to close your account. If you believe we have not complied with PIPEDA or CASL, please give us a chance to address it first at
befirst@firstaccesshomes.com. You may also complain to the Office of the Privacy Commissioner of Canada at
priv.gc.ca or the CRTC at
crtc.gc.ca/eng/casl-lcap.htm.
6. Security
We use industry-standard safeguards to protect your information, including encryption in transit and at rest, signed and short-lived access tokens, secure on-device storage of credentials, and limited, audited access to production systems. No system is perfectly secure. If we ever experience a breach affecting your information, we will notify you and the Office of the Privacy Commissioner of Canada as PIPEDA requires.
7. Retention and international transfers
We keep your personal information for as long as your account is active and for as long as we need it for the purposes described in this policy. Records that our MLS data agreement or CASL require us to retain (such as your acknowledgement and consent records) are kept for the period those rules require and may be audited during that window. After the applicable period, we delete or de-identify the information.
Your information is stored primarily in Canada and the United States, and some service providers are located in other jurisdictions. When your information is transferred outside Canada, it may be subject to the laws of the jurisdiction where the provider operates. By using the Service, you consent to these transfers for the purposes described here.
8. Children
The Service is not directed at anyone under 18. We do not knowingly collect information from children. If you believe a child has signed up, contact
befirst@firstaccesshomes.com and we will delete the account.
9. Changes and contact
We may update this policy from time to time. When we do, we update the "Last updated" date above, and for material changes we take reasonable steps to notify you. Your continued use of the Service after a change takes effect means you accept the updated policy.
End of policy.