Privacy Policy

Who we are

Above Grade AI, Inc. is an Ontario corporation, headquartered at 5-201 2600 Skymark Avenue, Mississauga, Ontario, L4W 5B2, Canada. Above Grade AI publishes the Above Grade real estate intelligence brief. In this policy, "Above Grade," "we," "us," and "our" refer to Above Grade AI, Inc. We are the data controller for all personal information collected through `abovegrade.ai`, the weekly Tuesday Brief email, and any account you hold on our portal.

This policy is written to comply with Canada's Personal Information Protection and Electronic Documents Act* (PIPEDA) and Canada's Anti-Spam Legislation (CASL). It covers information we collect from Canadian residents and, by extension, anyone in any jurisdiction who subscribes to the Brief or creates a portal account.

What we collect, and why

We collect the minimum information needed to send you the Brief, give you access to the portal, and improve what we publish.

When you subscribe to the Tuesday Brief:

• Your email address (required to send you the Brief)
• Your name, if you provide it
• The professional role you select at signup (realtor, mortgage broker, or other)
• The date and source of your signup (which page or referral)

When you create a portal account:

• The same email address you subscribed with (your portal sign-in)
• A session token stored as a secure HTTP-only cookie so you stay signed in (default 60 days, or 90 days if you check "Keep me signed in")

When you read the Brief or use the portal:

• Basic engagement data: which issues you open, which articles you click. This is collected through standard email-tracking pixels and our analytics provider. We use it in aggregate to understand what content is working — never to build a profile of you personally.
• Standard server logs: IP address, browser type, pages requested, timestamps. These are kept for security and operational debugging.

We do not collect:

• Payment information (Above Grade is free)
• Sensitive personal information (health, racial, religious, or political data)
• Information about people who have not interacted with us

Why we collect each thing

• What: Email + role at signup · Why: To send the Brief and tailor content to your role · Legal basis: Express consent (CASL); implied consent for transactional emails
• What: Portal session cookie · Why: To keep you signed in without re-entering a magic link every visit · Legal basis: Necessary for the service you requested
• What: Engagement data (opens, clicks) · Why: To learn what content works and to improve future issues · Legal basis: Legitimate interest, with the right to opt out
• What: Server logs · Why: Security, debugging, abuse prevention · Legal basis: Legitimate interest
• What: Correspondence (replies to the Brief, support requests) · Why: To respond to you · Legal basis: Necessary to deliver the response you asked for

Who we share information with

We don't sell your information. We don't share it for marketing purposes. We don't trade subscriber lists with sponsors, advertisers, partners, or anyone else.

We do use a small number of trusted service providers to operate Above Grade. Each one only receives the information needed to do its job, and each is contractually obligated to handle that information confidentially:

• GoHighLevel (GHL) — our email list management and delivery platform. Holds your email, name, role, signup source, and engagement events. Servers in the United States.
• Amazon Web Services (AWS) — Simple Email Service (SES) — sends transactional email from us to you (magic-link sign-in emails, certain confirmation emails). Holds your email address for the duration of the send.
• Vercel — hosts the Above Grade website and serves it to you. Processes the network requests you make to us (IP, browser type, URL requested). Servers in the United States and Canada.
• Sanity — our content management system. Stores the articles, issues, and editorial assets we publish. Does not store subscriber data.
• Anthropic (Claude) — the AI provider that runs our content drafting pipeline. Processes the public source material the pipeline ingests; does not process subscriber data. Your information is not shared with Anthropic.
• OpenLibrary / Unsplash — open content providers for book covers and editorial imagery. We send only the keyword or title we are searching for; we do not share subscriber data.

We may disclose information if we are legally required to (court order, subpoena, lawful regulatory request) or if we reasonably believe disclosure is necessary to prevent harm. We will notify the affected person where the law permits.

Where your information lives

Above Grade's primary data storage is in Canada and the United States, depending on the service. Email and engagement data sit primarily in U.S. data centres (GHL, AWS SES). The website is served from Vercel's North American edge network. Editorial content sits in Sanity's hosted environment (United States).

By subscribing or creating an account, you understand that some of your information will be processed and stored outside Canada, subject to the laws of the jurisdictions where these providers operate. Our providers' privacy and security practices are required by contract to meet or exceed the standards of PIPEDA.

How long we keep your information

We keep your subscription information for as long as you are subscribed, plus a short period after you unsubscribe so we can honour your unsubscribe request and prevent accidental re-addition. Engagement data is retained in aggregate for as long as it's useful for editorial planning, typically up to three years.

Server logs are retained for up to 90 days for security and debugging, then deleted or anonymized.

If you delete your portal account, we delete your account data within 30 days. Some information may persist in backups for a further period before being overwritten in the normal course of backup rotation.

Your rights

Under PIPEDA, you have the right to:

• Know what personal information we hold about you, and how we use and share it.
• Access that information and receive a copy in a readable format.
• Correct information that is inaccurate, incomplete, or out of date.
• Withdraw consent to our processing at any time (subject to legal or contractual restrictions).
• Unsubscribe from any of our emails by clicking the unsubscribe link in any email, or by replying to the Brief.
• Complain to the Office of the Privacy Commissioner of Canada if you believe we have handled your information improperly.

To exercise any of these rights, email newsletter@abovegrade.ai with the subject line `Privacy request — [your name]`. We will respond within 30 days, and in most cases sooner.

Cookies and tracking

The Above Grade website uses a small number of cookies, all functional:

• A session cookie that keeps you signed in to your portal account
• A short-lived sign-in cookie used during the magic-link authentication flow
• A basic analytics cookie (if enabled) used to understand aggregate website traffic — not to identify you individually

We do not use advertising cookies. We do not allow third-party advertising trackers on the site.

Our Tuesday Brief contains a standard email-tracking pixel. You can disable image loading in your email client to prevent the pixel from registering.

Children

Above Grade is a professional publication for realtors and mortgage brokers. We do not knowingly collect information from anyone under the age of 18. If you believe we have collected information from a minor, please contact us so we can delete it.

Changes to this policy

We may update this policy from time to time. If we make material changes — what we collect, who we share it with, or how long we keep it — we will tell you in advance by email (if we have your email) and post the updated policy with a new "Last reviewed" date at the bottom of this page. Continued use of Above Grade after a policy update means you accept the updated terms.

How to contact us about privacy

Privacy questions, access requests, corrections, and complaints:

Above Grade AI, Inc. Attention: Privacy 5-201 2600 Skymark Avenue Mississauga, Ontario, L4W 5B2 Canada

Email: newsletter@abovegrade.ai Subject line: `Privacy request — [your name]`

If you are not satisfied with our response, you can also contact the Office of the Privacy Commissioner of Canada at priv.gc.ca.

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Above Grade AI, Inc. · Above Grade · Powered by Treadstone Law Last reviewed: [DATE — set by counsel]