1. Who We Are
Company: Genie AI Labs Ltd (trading as RealGenie)
Data Protection Contact: privacy@realgenie.ai
ICO Registration: Pending
2. What Data We Collect
| Data Type | Examples | Why We Collect It |
|---|---|---|
| Account data | Email, name, phone, password | To provide our service |
| Property data | Postcodes, valuations, comparables | To deliver AI analysis |
| Customer data (your clients) | Names, phones, emails of buyers/sellers | To enable communication features |
| Communication data | Email/SMS/WhatsApp messages | To deliver omnichannel messaging |
| Calendar data | Events, attendees (via Google/Microsoft OAuth) | To enable calendar integration |
| Usage data | Pages visited, features used | To improve our platform |
| Document data | Uploaded surveys, EPCs, legal docs | To enable document analysis |
3. Legal Basis for Processing
| Processing Activity | Lawful Basis (GDPR Art 6) |
|---|---|
| Account management | Contract performance (Art 6(1)(b)) |
| AI valuations | Legitimate interest (Art 6(1)(f)) |
| Marketing emails | Consent (Art 6(1)(a)) |
| AML record keeping | Legal obligation (Art 6(1)(c)) |
| Calendar integration | Consent (OAuth) |
4. How Long We Keep Data
| Data Type | Retention Period | Reason |
|---|---|---|
| Account data | Duration of subscription + 1 year | Grace period for reactivation |
| Customer contacts | 2 years after last interaction | Business relationship management |
| Property context | 1 year after transaction completes | Dispute resolution |
| Conversation messages | 1 year after last message | Service delivery |
| Chat history | 30 days | Session context only |
| Documents | 6 years after transaction | RICS/HMRC audit requirements |
| AML records | 5 years (legal minimum) | Money Laundering Regulations 2017 |
| Audit trails | 7 years | RICS professional standards |
5. Who We Share Data With
| Service | Purpose | Location | DPA |
|---|---|---|---|
| Amazon Web Services (AWS) | Infrastructure, database, storage | UK (eu-west-2, London) | Yes |
| Anthropic (Claude AI) | AI processing, valuations, content | USA (SCCs in place) | Yes |
| Google (Gemini, Calendar, Gmail) | AI processing, calendar, email | USA/EU (SCCs) | Yes |
| Twilio | SMS and WhatsApp messaging | USA (SCCs) | Yes |
| Brevo (SendinBlue) | Email delivery | EU | Yes |
| Microsoft | Calendar, Outlook integration | USA/EU (SCCs) | Yes |
| Zoho | CRM integration (API only) | USA/EU/IN | Yes |
| Stripe | Payment processing | USA/EU (SCCs) | Yes |
6. Your Rights
- Right to access your data (request within 30 days)
- Right to correct inaccurate data
- Right to delete your data (with exceptions for legal obligations)
- Right to restrict processing
- Right to data portability (receive your data in machine-readable format)
- Right to object to processing
- Right to contest automated decisions (including AI valuations)
- Right to withdraw consent at any time
You can also complain to the ICO at ico.org.uk
7. Automated Decision-Making
RealGenie uses AI to generate property valuations, market analysis, and content. These are automated processes that may significantly affect property pricing decisions.
Under the Data (Use and Access) Act 2025, you have the right to:
- Be informed when automated decisions are made
- Receive meaningful information about the logic involved
- Contest automated decisions
- Request human intervention
8. International Transfers
Your data is stored in the UK (AWS eu-west-2, London). Some processing is carried out by US-based services (Anthropic, Google, Twilio). These transfers are protected by Standard Contractual Clauses (SCCs) as approved by the ICO.
9. Security
- Encryption in transit (TLS/SSL)
- Encryption at rest (AES-256 for sensitive data)
- Access controls and authentication
- Regular security reviews
- Data stored exclusively in UK data centres (eu-west-2)
10. Cookies
See our Cookie Policy for details on cookies and tracking technologies we use.
11. Changes to This Policy
We may update this policy from time to time. We will notify you of significant changes via email or in-app notification.
12. Contact Us
Email: privacy@realgenie.ai
Complaints: You can complain to the ICO at ico.org.uk/make-a-complaint