Privacy Policy
This Privacy Policy explains how AI Estate Operator ("the Service", "we", "us", "our"), a product operated by T.M.E The Marketing Experts Ltd ("TME"), registered in Cyprus (reg. no. HE 457797), registered office at 15 Kallipoleos, Amaral 30, 4th Floor, Office 402, 1055 Nicosia, Cyprus, collects, uses, shares and protects personal data. It applies to our website, our customer dashboard, and the WhatsApp AI assistant we provide to real-estate agencies and developers.
AI Estate Operator provides an AI assistant that replies to prospective buyers and renters on WhatsApp on behalf of a real-estate agency or developer ("the Agency"), answers their questions, and helps book property viewings, syncing to the Agency's dashboard and calendar. Communication via WhatsApp Business Cloud API is central to how the Service works.
1. Who is responsible for your data (controller vs. processor)
Our role depends on whose data it is:
- People who message an Agency ("Leads"/end-users): the Agency is the data controller and decides why the data is used; AI Estate Operator acts as a processor handling the data on the Agency's instructions. If you contacted an Agency and want to exercise your rights, you may contact that Agency or contact us and we will route your request.
- Agency owners, agents and staff who use our dashboard ("Account Users"): TME is the controller for that account and login data.
Meta Platforms (which operates the WhatsApp Business Cloud API) acts as a processor for the messages it carries on our behalf.
2. What data we collect
From Leads (people messaging an Agency on WhatsApp)
- Your WhatsApp phone number and WhatsApp profile name;
- The content of your messages - text, voice notes (which we transcribe to text) and images you send;
- Property preferences you share - for example budget, areas, property type, number of bedrooms, and whether you want to buy or rent;
- Viewing appointments you request or confirm;
- Conversation history and technical metadata such as message timestamps.
From Account Users (Agency staff)
- Name, business email, phone number and role;
- Login credentials and two-factor authentication data;
- Settings and content you enter (agency profile, listings, templates, notes).
3. Why we use it and our legal basis (GDPR)
| Purpose | Legal basis |
|---|---|
| Reply to Leads, answer questions, qualify interest and book viewings | The Agency's legitimate interest in responding to inquiries, and taking steps at the Lead's request; consent obtained through WhatsApp opt-in where required |
| Provide the dashboard, CRM and calendar to the Agency | Performance of our contract with the Agency |
| Send reminders and follow-up messages | Legitimate interest / consent, with an opt-out (reply STOP) always available |
| Billing, security, fraud prevention and keeping records | Legitimate interest and legal obligation |
| Maintaining and improving the Service | Legitimate interest - we do not use tenant conversation data to train AI models |
4. Who we share data with (our sub-processors)
We use a small number of trusted providers to run the Service. Each is bound by a data-processing agreement and may only use the data to provide their service to us:
| Provider | What it does | Location |
|---|---|---|
| Meta Platforms | WhatsApp Business Cloud API - carries the messages | EU / global |
| Supabase | Database, authentication and file storage | EU (Frankfurt, Germany) |
| Netlify | Hosting for the dashboard and website | Global CDN |
| MailerSend | Transactional email (alerts, notifications) | EU / United States |
We do not sell your personal data, and we do not share it with third parties for their own advertising.
5. International transfers
Our primary storage is in the EU. Some of our service providers may process data outside the EEA. Where personal data leaves the EEA, we rely on the European Commission's Standard Contractual Clauses and equivalent safeguards in our agreements with those providers.
6. How long we keep it
Meta deletes message content from the WhatsApp Cloud API infrastructure within 30 days of processing. In our own systems, we keep Lead and conversation data for as long as the Agency's account is active and needs it for its business, and then delete or anonymise it. Account User data is kept for the life of the account and a reasonable period afterwards for legal and accounting purposes. You can ask for earlier deletion - see below.
7. Your rights
Subject to the roles described in Section 1, you have the right to access, correct, delete, restrict or object to the processing of your personal data, to data portability, and to withdraw consent at any time. Leads can opt out of messaging at any time by replying STOP.
To exercise any right, or to request deletion, see our Data Deletion page or email info@tme-affiliates.com. We respond within 30 days. You also have the right to lodge a complaint with the Cyprus supervisory authority, the Office of the Commissioner for Personal Data Protection (or your local authority in the EEA).
8. How we protect your data
- Data is stored in the EU and encrypted in transit (WhatsApp uses the Signal end-to-end encryption protocol; our systems use TLS);
- Each Agency's data is isolated from every other Agency's (tenant isolation / row-level security);
- Access is restricted, logged in an audit trail, and protected by two-factor authentication for staff;
- We do not train AI models on tenant data.
9. Cookies
The dashboard uses only essential cookies needed to keep you signed in securely. Our public website may use minimal analytics; you can control non-essential cookies through the site's cookie settings.
10. Children
The Service is intended for businesses and is not directed to children. We do not knowingly collect data from anyone under 18.
11. Changes to this policy
We may update this policy from time to time. We will change the "Last updated" date above and, for material changes, take reasonable steps to notify affected Agencies.
12. Contact us
T.M.E The Marketing Experts Ltd - AI Estate Operator
15 Kallipoleos, Amaral 30, 4th Floor, Office 402, 1055 Nicosia, Cyprus
Privacy requests and general enquiries: info@tme-affiliates.com