Center Frame Privacy Policy

1609951 B.C. Ltd., operating as Center Frame (“Center Frame,” “we,” “us,” or “our”) provides an AI-assisted, human-reviewed YouTube strategy and production service for real estate professionals. This Privacy Policy explains how we collect, use, disclose, retain and protect personal information when you visit, apply for, purchase or use our website, application, program and related services (collectively, the “Service”).

Center Frame’s designated Privacy Officer is responsible for our compliance with applicable privacy law and can be contacted at support@centerframe.app.

1. Who this Policy applies to

This Policy applies to applicants, customers, authorized account users, website visitors and people who communicate with us. It does not govern a third-party website or service that has its own privacy policy.

The Service is for business and professional users who are at least 18 years old.

2. Information we collect

Depending on how you interact with the Service, we may collect:

• Identity and contact information: name, email address, telephone number, location, brokerage or team, role and market.
• Application and business information: business goals, audience information, experience, areas of expertise, publishing plans, current challenges and application or onboarding responses.
• Account and service information: account identifiers, selected start date, subscription status, production status, approvals, preferences and interactions with the Service.
• Customer Content: voice notes, audio, transcripts, recordings, headshots, brand assets, stories, examples, source material, feedback and other material you provide.
• Public channel and source information: public YouTube channel information, videos, transcripts, websites, public profiles and links you provide or direct us to review.
• Transaction information: selected plan, payment status, billing history, tax information and limited payment metadata. Stripe processes payment-card details; Center Frame does not store full card numbers.
• Technical and usage information: IP address, browser and device information, log data, access times, diagnostics, security events, page views, clicks, navigation patterns and similar information collected through cookies, analytics and session-recording tools.
• Communications: emails, support requests, survey responses and notes from coaching or service sessions. If a call will be recorded, we will notify participants and obtain any consent required by law.

Please do not provide confidential client information, sensitive personal information or information that is unnecessary for the Service. If you provide personal information about another person, you confirm that you are authorized to do so.

3. How we collect information

We collect information:

• directly from you through applications, account setup, forms, uploads, recordings, checkout, coaching and support;
• from public sources, including public websites, profiles and YouTube channels;
• automatically through cookies, logs, analytics and session-recording technologies; and
• from service providers that help us operate the Service.

At launch, Center Frame does not connect to your private YouTube or Google account and does not collect private channel analytics or publish on your behalf.

4. How we use information

We use personal information to:

• assess applications, fit and available capacity;
• communicate application decisions and manage start dates;
• create and manage accounts, subscriptions, payments and customer records;
• research and recommend content direction;
• create, review, edit and deliver titles, scripts, recording packages, videos, thumbnails, descriptions and related work;
• provide coaching, office hours, customer support and service communications;
• personalize and improve the Service, workflows and customer experience;
• maintain security, prevent fraud and misuse, troubleshoot and enforce our agreements;
• comply with legal, tax, accounting and regulatory obligations; and
• send marketing communications where we have the consent or other lawful authority required to do so.

We use personal information for purposes that a reasonable person would consider appropriate in the circumstances and obtain additional consent where required for a new purpose.

Software and AI tools may help us organize, summarize or evaluate application information, but a person makes the final application decision.

5. AI processing and human review

We use artificial-intelligence service providers and human reviewers to analyze relevant inputs and help create directions, titles, scripts, recording packages, descriptions, thumbnails, edits and other deliverables. This may involve sending the information reasonably needed for a task to providers acting for us.

AI providers have their own data-use terms and settings. Depending on the provider and configuration, a provider may use submitted information to improve its services or models. We take reasonable steps to limit the information we send and to use privacy-protective business, API or no-training settings where available.

Center Frame does not itself use identifiable Customer Content to train a general-purpose model or publicly promote the Service without separate express permission.

We may use aggregated or de-identified information that cannot reasonably identify a person to analyze and improve the Service.

6. When we disclose information

We may disclose personal information:

• to Center Frame personnel and contractors who need it to provide the Service and are subject to confidentiality obligations;
• to service providers that support payments, hosting, databases, authentication, storage, email, transcription, media production, analytics, session recording, security, error monitoring or AI processing;
• during a proposed or completed financing, reorganization, merger, acquisition or sale, subject to appropriate confidentiality and legal safeguards;
• where required or permitted by law, including to protect rights, safety, security and the integrity of the Service; and
• with your consent or at your direction.

We do not sell personal information or disclose it for cross-context behavioural advertising. We do not use your name, likeness, content, results or testimonial in marketing or a public case study without separate permission.

You may contact our Privacy Officer for more information about the types of service providers we use and where they process information.

7. Processing outside Canada

We and our service providers may process or store information outside British Columbia or Canada, including in the United States. Information processed in another jurisdiction may be accessible to courts, law-enforcement agencies or regulators under that jurisdiction’s laws.

8. Cookies, analytics and session recording

We use cookies and similar technologies for authentication, security, checkout, preferences and core functionality. We also use analytics and session-recording tools to understand how people use the Service, diagnose problems and improve the experience. These tools may collect page views, clicks, cursor movements, navigation patterns, browser and device information, and similar interaction data.

One analytics provider is Google Analytics 4, operated by Google LLC. It uses first-party cookies, including _ga and _ga_*, to measure page views, sessions and interactions, and Google may process that information in the United States. You can limit it through your browser’s cookie controls or Google’s Analytics Opt-out Browser Add-on at tools.google.com/dlpage/gaoptout.

We do not use this information for third-party behavioural advertising. Where required, we will provide additional notice or choices for non-essential technologies.

You can control cookies through your browser, but disabling essential cookies may prevent the Service from working.

9. Marketing and service communications

Account, billing, security, delivery, application-status and support messages are service communications and are not optional while they are relevant to your relationship with us.

We send promotional emails or messages only where permitted by law. Where consent is required, we ask for it separately from acceptance of the Customer Agreement. You can unsubscribe through the link in a marketing message or by contacting support@centerframe.app. Unsubscribing from marketing does not stop necessary service communications.

10. Retention

We retain personal information only as long as reasonably necessary to provide the Service, fulfil the purposes described in this Policy, maintain appropriate business and legal records, resolve disputes and enforce our agreements. The period varies depending on the nature and sensitivity of the information, our relationship with you, and applicable legal, business and technical requirements.

If we use personal information to make a decision that directly affects you, including an application decision, we retain the information used for that decision for at least one year after the decision, as required by British Columbia law.

When personal information is no longer needed for an identified purpose or a legal or business reason, we delete it, de-identify it or securely destroy it. Some information may remain temporarily in backups until those backups are overwritten or securely deleted. You may ask us to delete your information, subject to information we are required or reasonably need to retain.

11. Security

We use administrative, technical and organizational safeguards appropriate to the sensitivity of the information, including access controls, secure transmission and service-provider controls. Access to Customer Content is limited to people and systems that reasonably need it to provide or support the Service.

No service can guarantee absolute security. If we become aware of a privacy or security incident, we will investigate, mitigate it and provide any notice required by law.

12. Your choices and rights

Subject to applicable law, you may ask us to:

• explain how we have used and disclosed your personal information;
• provide access to personal information we hold about you;
• correct inaccurate or incomplete information;
• provide a portable copy of information you supplied where reasonably available;
• withdraw consent where our processing depends on consent; or
• delete information that we are not required to retain.

Withdrawing consent may prevent us from providing part or all of the Service. We may need to verify your identity before responding. To make a request, contact support@centerframe.app.

If you have a privacy concern, please contact our Privacy Officer so we can try to resolve it. You may also contact the Office of the Information and Privacy Commissioner for British Columbia or another applicable privacy regulator.

13. Children

The Service is not directed to children, and we do not knowingly collect personal information from anyone under 18.

14. Changes to this Policy

We may update this Policy as the Service, our practices or the law changes. We will post the new version with an updated effective date and provide reasonable notice of a material change. Where required, we will obtain consent before applying a new use to information already collected.

15. Contact us