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Section 6

Privacy Policy

Last updated August 7, 2026

This policy explains how PropAI Software Development Services ("PropAI PH", "we") handles personal data, in accordance with the Data Privacy Act of 2012 (RA 10173), its Implementing Rules and Regulations, and issuances of the National Privacy Commission.

Two different roles, and why it matters

For data about brokers who subscribe — your name, contact details, billing records, account activity — we are the Personal Information Controller. We decide why and how it is processed.

For data about the buyers who message your Page, or ask about a listing in a comment on it — their name, Messenger ID, the content of their inquiry or comment, the budget and timeline they share — you are the Personal Information Controller and we act as your Personal Information Processor. We process that data only on your documented instructions, as set out in the Data Processing terms in our Terms of Service. This means you are responsible for having a lawful basis to process your buyers' data, and for telling them how it is used.

What we collect

  • Account data: name, email address, mobile number, business name, the Facebook Page you connect, and your plan.
  • Listing data: whatever you enter — unit details, prices, terms, photos, and text extracted from documents you upload.
  • Listing location: if you set a location for a listing, the address, area label, any landmark notes, and map coordinates you choose, plus the map images we generate from them. A precise house-and-lot address can identify the property owner, so you control how exactly it is shared with a buyer (general area only, exact location, or exact only after a confirmed viewing). It is stored as part of the listing and deleted with it. Address searches and coordinates are sent to our maps provider (see sub-processors).
  • Conversation data: messages exchanged between a buyer and your Page through the service, and the metadata Meta provides with them. We receive only messages sent to a Facebook Page you connect, under the pages_messaging permission. We have no access to your personal Messenger conversations, your friends list, or any personal profile data beyond what administering that Page requires.
  • Comment data: only if you switch on comment replies for your Page — public comments left on your Page's posts (the commenter's name, their Facebook ID for your Page, and the comment text), received under the pages_read_engagement and pages_read_user_content permissions, so the service can tell which comments are inquiries and reply to them. With comment replies off, comments are not stored.
  • Usage data: log records, timestamps, error reports, and reply counts used for billing and troubleshooting.
  • Billing data: plan and payment reference. During early access, invoicing is manual (GCash/bank transfer) — no card details pass through PropAI PH.

Why we process it, and on what basis

  • To provide the service — performance of our contract with you.
  • To generate replies — processing on your instructions as your Processor.
  • To bill you and keep records — contract, and our legal obligations under Philippine tax and accounting rules.
  • To keep the service secure and prevent abuse — our legitimate interests, balanced against the rights of the individuals concerned.
  • To send service notices — contract. Marketing messages are sent only with consent, and you can withdraw it at any time.

Automated processing

Replies are generated automatically and inquiries are scored for budget and timeline fit. This assists a human decision; it does not by itself determine whether anyone is offered a property or refused one. A person can request human review at any time.

Who we share it with

Only with sub-processors necessary to run the service — hosting, database, AI model inference, email delivery — each bound by contract to confidentiality and to process data only on our instructions. We do not sell personal data. We do not share it with other brokers. We disclose data to authorities only where legally compelled, and will tell you unless prohibited from doing so.

Sending data outside the Philippines

Some sub-processors store or process data outside the Philippines. Where that happens we remain accountable for it under the DPA and put contractual safeguards in place. The current locations are listed at /legal/sub-processors.

If something goes wrong

If we become aware of a data breach that affects your data, we will notify the National Privacy Commission and affected data subjects within 72 hours of discovery, as required by the Data Privacy Act.

Your rights

Under the Data Privacy Act you have the right to be informed, to access your data, to object to processing, to have inaccurate data corrected, to have data erased or blocked in the circumstances the law provides, to data portability, and to be indemnified for damage caused by unlawful processing. To exercise any of these, write to dpo@propaiph.com. We respond within 15 working days, and will tell you if we need longer and why.

You may also complain to the National Privacy Commission, 5th Floor, Delegation Building, PICC Complex, Pasay City — privacy.gov.ph.

Buyers messaging a broker's Page

If you messaged a broker, or commented on their Page's post, and your inquiry was answered through PropAI, the broker is the controller of your data. Contact them first. You may also write to us at dpo@propaiph.com and we will assist the broker in responding, or act directly where the law requires us to. See data deletion instructions.

Children

The service is for business use by adults. We do not knowingly process the data of anyone under 18. If we learn that we have, we will delete it.

Changes

We will post any change here and, for material changes, notify account holders by email at least 30 days before it takes effect.