1. Introduction

Golden Team Realty Inc., Brokerage ("Golden Team Realty," "we," "our," or "us") is committed to protecting the privacy and personal information of our registered real estate agents, clients, and other individuals whose information we collect, use, or disclose in the course of our business.

This Privacy Policy explains how we handle personal information collected through our internal agent portal located at https://agent.goldenteamrealty.com/ (the "Portal"). The Portal is an access-restricted website intended exclusively for use by registered real estate agents and authorized administrative staff of Golden Team Realty Inc., Brokerage.

This Privacy Policy is governed by the Personal Information Protection and Electronic Documents Act (PIPEDA), the Trust in Real Estate Services Act, 2002 (TRESA), and applicable rules of the Real Estate Council of Ontario (RECO).

2. Scope

This Privacy Policy applies to:

• All registered agents of Golden Team Realty Inc., Brokerage who access the Portal;

• All administrative staff and authorized personnel who use the Portal;

• All personal information of third parties (including, without limitation, prospective tenants, buyers, and sellers) that agents submit, upload, or process through the Portal in connection with brokerage services.

3. Information We Collect

We collect personal information that is reasonably necessary to operate the Portal, support our agents, and deliver brokerage services. The categories of information we collect include:

3.1 Agent and Staff Information

• Full legal name and trade name

• Business contact information (email, phone number, mailing address)

• RECO registration number and license expiry date

• Photograph and professional profile information

• Native language and language proficiency

• Account login credentials (email and password managed through Wix Members)

• Internal documents stored or linked through the Portal (e.g., training records, sales reports)

3.2 Tenant and Client Information (Submitted by Agents)

When agents use Portal services such as the Tenant Credit Check Service, we collect the following on behalf of prospective tenants or clients:

• Full legal name and current address

• Signed Form 410 (Rental Application) and supporting documents

• Social Insurance Number (SIN), where voluntarily provided

• Other information reasonably required to complete the requested service

Such information is collected and processed only with the prior written consent of the individual (as evidenced by their signed Form 410 or equivalent authorization).

3.3 Transaction and Order Information

• Records of purchases made through the Portal's internal Online Shop

• Service requests (e.g., design requests, cleaning services, lockbox orders)

• Payment information (processed by Wix Payments; we do not store full credit card numbers)

3.4 Technical Information

• IP address, browser type, device type, and operating system

• Pages visited, features used, and timestamps of access

• Cookies and similar tracking technologies (see Section 9)

4. How We Collect Information

We collect personal information through:

• Direct submission by agents during account setup and ongoing use of the Portal;

• Forms completed within the Portal (including third-party form services such as Cognito Forms);

• File uploads and Google Drive links shared by agents;

• Automated logging of Portal activity by our web infrastructure provider (Wix);

• Communications you send to us by email, phone, or other channels.

5. How We Use Personal Information

We use personal information for the following purposes:

• To authenticate agents and administrators accessing the Portal;

• To provide brokerage-related services, training, resources, and internal communications;

• To process service orders placed through the Portal (e.g., printing, design, cleaning, lockbox, tenant credit checks);

• To monitor RECO license expiry and notify agents of upcoming renewal deadlines;

• To comply with our legal, regulatory, and contractual obligations under PIPEDA, TRESA, and RECO rules;

• To maintain records for tax, audit, and regulatory purposes;

• To detect, prevent, and respond to fraud, unauthorized access, or misuse of the Portal.

We do not use personal information for purposes unrelated to those listed above without obtaining additional consent.

6. Disclosure to Third Parties

We do not sell personal information. We disclose personal information only to the following categories of third parties, and only as reasonably necessary:

6.1 Service Providers

• Wix (Wix.com Ltd.) — website hosting, CMS, member authentication, and payment processing

• Cognito Forms — secure form submission and data collection

• Google Drive (Google LLC) — file storage and document sharing

• Equifax Canada Co. — credit reporting for the Tenant Credit Check Service

• Email and communication providers used to send notifications and reports

These service providers are contractually or legally required to safeguard personal information and use it only for the purposes for which it was disclosed.

6.2 Regulatory and Legal Disclosures

We may disclose personal information when required or permitted by law, including:

• To the Real Estate Council of Ontario (RECO) in connection with regulatory compliance;

• To law enforcement, courts, or regulatory authorities pursuant to a valid legal request;

• To protect our legal rights, property, or the safety of others.

6.3 Cross-Border Transfers

Some of our service providers (including Wix and Google) may store or process data outside of Canada, including in the United States. By using the Portal, you acknowledge that personal information may be subject to the laws of the jurisdictions in which our service providers operate.

7. Data Storage and Security

We take reasonable physical, organizational, and technological measures to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification. These measures include:

• Access restrictions limiting Portal access to authenticated agents and authorized staff;

• Encryption of data in transit using industry-standard protocols (HTTPS/TLS);

• Role-based access controls within our CMS;

• Periodic review of administrative access permissions.

No method of electronic transmission or storage is 100% secure. While we strive to protect personal information, we cannot guarantee absolute security.

8. Data Retention

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, or as required by law.

• Agent records: Retained for seven (7) years following termination of the agent's relationship with Golden Team Realty Inc., Brokerage, in accordance with RECO record-keeping requirements and Canadian tax law.

• Tenant and client records (including credit check requests): Retained for seven (7) years from the date of service, unless a longer retention period is required by law.

• Portal activity logs: Retained for operational and security purposes for a reasonable period consistent with industry practice.

When personal information is no longer required, we securely destroy, erase, or anonymize it.

9. Cookies and Tracking Technologies

The Portal uses cookies and similar technologies to:

• Maintain authenticated user sessions;

• Remember user preferences;

• Analyze Portal usage and performance.

Most web browsers allow you to control cookies through browser settings. Disabling cookies may affect the functionality of the Portal, including the ability to remain logged in.

10. Your Rights

Subject to applicable law, you have the right to:

• Access the personal information we hold about you;

• Correct inaccurate or incomplete personal information;

• Withdraw consent for the collection, use, or disclosure of your personal information, subject to legal or contractual restrictions;

• Request deletion of your personal information, where applicable;

• File a complaint with our Privacy Officer or with the Office of the Privacy Commissioner of Canada.

To exercise any of these rights, please contact our Privacy Officer using the contact information in Section 13.

We will respond to verified requests within thirty (30) days, as required by PIPEDA.

11. Children's Privacy

The Portal is intended exclusively for use by registered real estate agents and authorized staff who are at least 18 years of age. We do not knowingly collect personal information from individuals under the age of 18. If you believe we have inadvertently collected such information, please contact our Privacy Officer immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or services. The "Last Updated" date at the top of this policy indicates when it was most recently revised. Material changes will be communicated to Portal users by email or by prominent notice on the Portal.

Continued use of the Portal after changes take effect constitutes your acceptance of the revised Privacy Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of personal information, please contact our Privacy Officer:

Privacy Officer: Yi Gao (Broker of Record) Golden Team Realty Inc., Brokerage 650 Highway 7 East, Unit 306 Richmond Hill, ON L4B 2N7 Canada

Email: johngao668@gmail.com Phone: 647-824-3166

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada:

Office of the Privacy Commissioner of Canada 30 Victoria Street Gatineau, Quebec K1A 1H3 Phone: 1-800-282-1376 Website: https://www.priv.gc.ca

Golden Team Realty Inc., Brokerage RECO Registration Number: 6000947 Broker of Record: Yi Gao