Privacy Policy

1. Introduction & Scope

This Privacy Policy describes how Tenth Degree AI, a division of A Better Way Mortgage Group ("we," "us," or "our"), collects, uses, discloses, and protects your personal information when you use Brain MB at brainmb.ai and all related services.

Effective date: March 25, 2026. This policy applies to all users in Canada and is designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA).

2. Information We Collect

Account Information: Full name, email address, brokerage name, mortgage license number, and password (stored in hashed form only).

Usage Data: Search queries, conversation history, feedback submissions, and deal scenario logs. Deal scenario logs are pseudonymized and contain only structural fingerprints (LTV band, income type, product type, property type, amortization band, beacon band, province) with no personally identifiable information.

Payment Information: Subscription payments are processed securely by Stripe. We do not store or have access to your credit card numbers.

Technical Data: IP address, browser type, device information, and cookies necessary for authentication and service functionality.

Lender Portal Data: Lender staff names, email addresses, and phone numbers provided voluntarily by lender organizations through our portal.

ABW Broker Data: Franchise brand affiliation (DLC/MA) and ABW membership status for brokers affiliated with A Better Way Mortgage Group.

3. How We Use Your Information

• To provide, maintain, and improve the Brain MB service
• To process your subscription payments and manage your account
• To respond to your inquiries via the support assistant
• To generate anonymized analytics and usage statistics for service improvement
• To improve AI response accuracy through aggregated, anonymized feedback — never individual data
• To send service-related communications (we do not send marketing communications without your explicit consent)

4. AI-Generated Content Disclosure

Brain MB uses artificial intelligence (Claude by Anthropic) to analyze mortgage policies, rates, and guidelines. AI responses are generated based on our curated database of lender policies, rate data, and industry information.

AI-generated content may contain errors, omissions, or outdated information. We do not guarantee the accuracy, completeness, or timeliness of any AI-generated response. Users must independently verify all information before making lending decisions.

5. Data Sources

Rate and policy data displayed on Brain MB is compiled from:

• Lender submissions through our lender portal
• Publicly available lender rate sheets and guidelines
• Industry databases and publicly available information on the internet

Lender contact information is provided by lenders themselves through our portal or compiled from public sources. We make reasonable efforts to keep data current but do not guarantee real-time accuracy. Lenders may update their own information at any time through our lender portal.

6. Data Sharing & Third Parties

We use the following third-party service providers to operate Brain MB:

• Stripe — payment processing (Stripe's privacy policy applies to payment data)
• Supabase / Amazon Web Services — data hosting in the ca-central-1 region (Canadian data residency)
• Anthropic — AI processing (query content is sent to the Claude API for response generation; Anthropic's data handling policies apply)
• Resend — transactional email delivery only
• Vercel — website hosting and content delivery

We do NOT sell personal information to third parties. We do not share personal information for advertising or marketing purposes. We may share anonymized, aggregated data for analytical purposes.

7. Data Retention & Security

• Account data is retained while your account is active, plus a reasonable period after deletion to comply with legal obligations
• Conversation history is retained for service improvement; you may request deletion at any time
• Deal scenario logs are pseudonymized (structural fingerprints only — no PII) and retained for aggregate analytics
• Data is encrypted in transit (TLS 1.2+) and at rest (AES-256)
• Role-based access controls and authentication are required for all data access
• We conduct regular security reviews of our infrastructure and practices

8. Your Rights Under PIPEDA

Under the Personal Information Protection and Electronic Documents Act, you have the right to:

• Access the personal information we hold about you
• Challenge the accuracy of your personal information and have it corrected
• Withdraw consent for the collection, use, or disclosure of your personal information (note: withdrawal may limit our ability to provide the service)
• Request deletion of your account and associated data
• Know how your personal information is being used and disclosed
• File a complaint with the Office of the Privacy Commissioner of Canada

To exercise any of these rights, contact our Privacy Officer (see Contact section below). We will respond to access requests within 30 days.

9. Cookies & Tracking

• Essential cookies: required for authentication, session management, and core functionality
• Analytics cookies: used to understand usage patterns and improve the service
• We do NOT use third-party advertising or tracking cookies
• You may disable non-essential cookies through your browser settings; however, this may affect functionality

10. Children's Privacy

Brain MB is intended exclusively for licensed mortgage professionals. We do not knowingly collect personal information from persons under the age of 18. If we become aware that we have collected information from a minor, we will delete it promptly.

11. Cross-Border Data Transfers

Your data is primarily stored in Canada (AWS ca-central-1 region). Some service providers (Anthropic, Vercel, Stripe) may process data in the United States. Where data is transferred outside Canada, we ensure appropriate safeguards are in place consistent with PIPEDA requirements.

12. Data Breach Notification

In the event of a data breach involving personal information that poses a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by PIPEDA. We maintain an incident response plan and will act promptly to contain and remediate any breach.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or prominent notice on the site. Continued use of Brain MB after changes constitutes acceptance of the updated policy. Previous versions will be made available upon request.

14. Contact / Privacy Officer

Privacy Officer: Dean Lawton

Email: dean@abwmortgage.ca

Organization: A Better Way Mortgage Group (operating as Tenth Degree AI)

Mailing: A Better Way Mortgage Group, Langley, British Columbia, Canada

If you are not satisfied with our response to your privacy concern, you may contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.