Data Controller
In compliance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), we inform you that the controller of your personal data is:
Name: AIPropHub
NIF/CIF (Tax ID): [pendiente de registro]
Address: Valencia, España
DPO contact / Data Protection Officer: privacy@aiprophub.com
Competent supervisory authority: Agencia Española de Protección de Datos (AEPD): www.aepd.es
1. Data We Collect
We collect the following categories of personal data when you register, browse, or transact on the AIPropHub platform:
| Category | Examples | Collected when |
|---|---|---|
| Identity | Full name | Registration |
| Contact | Email address, phone number | Registration, onboarding |
| Preferences | Budget range, investment type, preferred locations, property criteria | Onboarding, search |
| Transaction history | Bookings, offer history, wallet credits, unlock records | Platform usage |
| Technical | IP address, browser type, device identifiers, cookies | Automatically |
| Identity documents | Passport or DNI/NIE scan you upload | Only when you upload one to formalise a reservation, arras or deed |
We do not collect sensitive special-category data (health, ethnicity, religion) unless you explicitly provide it and consent.
Identity documents: why we ask, who sees them, how long we keep them. A passport or DNI/NIE copy is requested only to formalise a specific transaction: the reservation, the arras contract, or the deed. We share it with the estate agency handling that transaction and with the notary executing it, because those are the parties who need it to prepare the documents; nobody else, and we do not sell or transfer it for any other purpose. Lawful basis: performance of a contract you have asked us to help conclude (GDPR Art. 6(1)(b)). We delete the file automatically 12 months after upload, and you can delete it yourself at any time from your profile. If a confirmed anti-money-laundering duty applies to a specific transaction, the law may require us to keep the evidence longer; where that happens we will tell you.
2. How We Use Your Data
We process your personal data for the following purposes, each based on a lawful basis under GDPR Article 6:
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Property matching
We use your budget, investment preferences, and location criteria to compute match scores and recommend relevant listings. Lawful basis: contract performance.
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Communication
We send transactional emails (booking confirmations, offer updates, account notifications). We may also send marketing emails with your consent, which you can withdraw at any time. Lawful basis: contract performance / consent.
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Legal compliance
We retain transaction records to comply with Spanish tax law (Law 58/2003, General Tax Law). Lawful basis: legal obligation. We do not currently operate a dedicated anti-money-laundering compliance programme; we do not process your data on that basis.
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Platform security & fraud prevention
We analyse technical data to detect abuse, suspicious activity, and protect the integrity of the marketplace. Lawful basis: legitimate interest.
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Product improvement
We use usage data, which may be linked to your account while you are logged in, to improve our matching algorithms and user experience. This data is pseudonymous, not anonymised; see the processors below. Lawful basis: legitimate interest.
We do not sell your personal data to third parties. We share data with the processors listed in the next section under data processing agreements that require them to protect your data.
2a. Third-Party Processors
We use the following processors to operate the platform. Each receives only the data needed for the purpose stated:
| Processor | Purpose | Data shared |
|---|---|---|
| Sign-in (OAuth) | Name, email address, Google account identifier | |
| PostHog | Product analytics | Usage events and device/browser data, linked to your account id while logged in |
| Sentry | Error monitoring and crash reporting | Technical error data, which may include your account id and IP address |
| Groq | AI-generated text (ROI narratives, negotiation-assistant messages) | The property and deal data needed to generate the specific text |
| Replicate | AI image generation (Creativity Studio) | Photos you upload for that feature |
| Resend | Transactional email delivery | Your email address and message content |
| Cloudflare R2 | File storage (property photos, identity-verification documents, AI-generated renders) | Uploaded files |
| Expo | Mobile push notification delivery | Your device push token |
| Stripe | Payment processing (wallet top-ups) | Payment/checkout session data linked to your account id. AIPropHub does not store your card details: Stripe collects those directly; we only receive the resulting checkout session id, amount, and status |
| Vercel | Application hosting and infrastructure | All data submitted through the platform, including personal data, as it passes through our hosting layer |
| MongoDB Atlas | Primary database hosting (all platform data at rest) | All personal data the platform stores (accounts, properties, offers, deals, transactions, and identity-document metadata), held at rest in our database |
International transfers (GDPR Chapter V). Most of the processors above are US-based and may process your data outside the EU/EEA: Stripe, PostHog, Sentry, Groq, Replicate, Resend, Cloudflare, Expo, Google and MongoDB Atlas. Where a transfer occurs, it relies on the European Commission’s Standard Contractual Clauses, on the EU–US Data Privacy Framework where the recipient is certified under it, or on an adequacy decision. We are still confirming which of these applies to each processor individually, and the hosting region for some of them is not yet fixed on our side; we say so rather than state a basis we have not verified. You can ask us for the current position for any named processor at any time, and this section is updated as each is confirmed.
2b. Automated decision-making (GDPR Art. 22)
We use the following automated processes. None of them amounts to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, for the reasons explained below.
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Property match score
We automatically compute a compatibility score from your budget, preferences, and search criteria to recommend listings. It is purely informational: you decide which listings to view, contact, or dismiss.
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AI-drafted ROI explanations
Return-on-investment figures are always computed by deterministic rules in our code, never by an AI model. A language model (Groq) is used only to draft the explanatory text for those already-computed numbers; it does not decide or alter any figure.
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Automated negotiation ("Let AI negotiate")
If you turn this feature on, pricing decisions (offer, counter, withdraw) are computed by a deterministic rules engine within the maximum price you set yourself; an AI model only drafts the wording of each message; it never decides the price. These automated moves never close the deal by themselves: when the engine is ready to accept a price, the platform pauses and asks for your explicit confirmation before creating the deal and charging any commission. No deal is ever closed without that confirmation from you.
If you believe one of these automated tools produced an incorrect result, or you want a human explanation of how it was generated, contact us at privacy@aiprophub.com to request human intervention, express your view, or contest the result.
3. Your GDPR Rights
Under the GDPR, residents of the EU/EEA have the following rights with respect to their personal data:
Right of access (Art. 15)
Request a copy of all personal data we hold about you.
Right to rectification (Art. 16)
Ask us to correct inaccurate or incomplete data.
Right to erasure (Art. 17)
Ask us to delete your data where there is no overriding legal basis for keeping it.
Right to restriction (Art. 18)
Ask us to pause processing of your data while a dispute is resolved.
Right to portability (Art. 20)
Receive your data in a structured, machine-readable format (JSON) so you can transfer it to another provider.
Right to object (Art. 21)
Object to processing based on legitimate interests (for example, platform security or product improvement). You can also switch off personalised matching at any time in Settings; we then stop calculating your match score and stop matching your saved searches against new listings. We offer this control whether or not the right formally applies to matching.
Right to withdraw consent
Where processing relies on consent, withdraw it at any time without affecting prior processing.
Right to lodge a complaint
File a complaint with the AEPD (Agencia Española de Protección de Datos) at aepd.es.
To exercise any of these rights, contact us at privacy@aiprophub.com. We will respond within 30 days. Identity verification may be required.
4. Data Retention Periods
We retain personal data only as long as necessary for the purpose it was collected, or as required by law:
| Data type | Retention period | Reason |
|---|---|---|
| Account data | Until you delete your account | Service delivery |
| Transaction / wallet ledger records | Retained indefinitely at this time | Accounting record; a fixed retention period has not yet been set |
| Security audit log (privilege changes, account deletions, money-moving actions) | Deleted automatically after 3 years | Tamper-evident security record |
| Session / refresh tokens | Deleted automatically ~30 days after last use | Authentication housekeeping (database TTL) |
| Product-analytics events | Deleted automatically after 400 days | Product analytics (database TTL); our analytics processor, PostHog, applies its own separate retention to the copy it holds |
| Viewing bookings | Deleted automatically after 3 years | A past viewing has no ongoing purpose once the transaction is over, but can be evidence in a dispute about what was shown and when |
| Notifications | Deleted automatically after 1 year | A notification is a delivery mechanism, not a record: it carries nothing the underlying object does not |
| Offers | Deleted when you delete your account | Offer/negotiation history is part of your account data |
| Deals (in progress or closed) | Kept indefinitely; anonymised: your account link is removed rather than the record deleted | The counterpart agency retains its own business record of the deal |
| Signed reserve agreement | Kept for 5 years from signature, then deleted automatically | Establishment or defence of legal claims (GDPR art. 17.3(e)). Not anonymised: the parties' names sit inside the signed text that the signature covers. The 5-year figure is Spain's general limitation period for contractual actions (CC art. 1964.2) and is pending confirmation by our counsel |
| Expert reports & site-visit records | Retained indefinitely at this time | A fixed retention period has not yet been set |
Deleting your account deletes your account record and linked personal data (bookings, notifications, offers, saved searches, uploaded photos and identity documents) immediately; there is no recovery window. Any deal in progress with an agency is anonymised rather than deleted, so the agency retains its own record of the deal. The transaction ledger and security audit log rows described above are not deleted by account erasure; the audit log expires on its own 3-year schedule.
5. Contact for Data Requests
For any privacy-related request (access, deletion, portability, or complaint), please contact our Data Protection team:
Email: privacy@aiprophub.com
Response time: Within 30 calendar days of receiving your request (extendable by 2 months for complex cases, with notice).
Supervisory authority: Agencia Española de Protección de Datos (AEPD): www.aepd.es
6. Governing Law
This Privacy Policy is governed by Spanish law, including:
- Organic Law 3/2018 (LOPDGDD) on the Protection of Personal Data and Guarantee of Digital Rights
- EU Regulation 2016/679 (General Data Protection Regulation, GDPR)
- Law 34/2002 on Information Society Services and Electronic Commerce (LSSI)
Disputes arising from this policy fall under the jurisdiction of the AEPD and, where applicable, the competent courts of Spain.
We reserve the right to update this policy. Material changes will be communicated by email or prominent notice on the platform at least 15 days before taking effect.