Privacy Policy

1. Introduction

Truehome ("we", "us", "our") is committed to protecting your privacy and personal data in accordance with the General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018. This Privacy Policy explains how we collect, use, store, and protect your information when you use our platform.

2. Data Controller

Truehome is the data controller for personal data collected through the Platform. For data protection enquiries, contact us at privacy@truehome.ie.

3. Data We Collect

We collect the following categories of personal data:

• Account information: Name, email address, profile photo, and account preferences
• Listing data: Property details, images, and descriptions you provide when creating listings
• Search activity: Saved searches, favourites, and search criteria
• Usage data: Pages visited, features used, IP address, browser type, and device information
• Communication data: Messages you send through the Platform and enquiry details, together with the read status of those messages. When both you and the person you are messaging have read receipts switched on, we record and show the time a message was read; you can switch read receipts off in your profile at any time. If you send an enquiry without an account (where that option is enabled), we also collect the name, email address and any phone number you enter, and we create a single-use link that lets you claim the conversation when you register.
• Location data: Saved places and location preferences you provide voluntarily
• Approval in Principle (AIP) data: If you use the Buyer Approved feature, we temporarily receive your AIP document to extract lender name and expiry date. The document is deleted immediately after extraction. We retain only the extracted fields (lender name, expiry date, and verification timestamp).
• AI search interactions: The free-text messages you send to AI search and the assistant's replies. We store these by default to debug problems, monitor quality and improve the reliability of the AI search. We do not use them to train AI models. You can turn this off at any time in your profile, which also deletes what we have stored; in any case these logs are kept for at most 90 days. Separately, when you save a search created from an AI chat, we keep a snapshot of that conversation.
• Neighbourhood feedback: When you accept an AI-suggested neighbourhood, we record the suggested area pair to improve our suggestions.
• Bug reports: If you submit a bug report, its description and any screenshot you choose to attach.
• Calendar connection data: If you connect a Google or Microsoft calendar, the OAuth access tokens and the external calendar events imported to detect viewing conflicts.
• Activity (audit) logs: Records of significant account, bidding, viewing and verification actions, each with a timestamp and originating IP address — see section 7a.
• Referral source: How you arrived at Truehome: the marketing campaign parameters (UTM tags) in the link you followed, the referring website, and, if you choose to tell us, your answer to "how did you hear about us". We record this once, when you create an account, to understand which of our content and channels bring people to Truehome. It is first-party only, and we set no third-party advertising cookies for it.
• AI connector data (estate agents): If you connect an AI assistant such as Anthropic's Claude or OpenAI's ChatGPT to your Truehome agent account, we record the authorisation you grant (an OAuth token, never your password) and keep an audit record of the actions the assistant takes on your behalf. The assistant works with your existing Truehome data, which can include your listings, enquiries, viewings, offers, private notes and the messages buyers have sent you. See section 16.

4. Legal Basis for Processing

We process your data on the following legal bases under GDPR Article 6:

• Contract performance: To provide our property listing and search services
• Legitimate interest: To operate, secure, debug and improve the Platform, including storing your AI search messages to fix problems and improve the reliability of the AI search (you can opt out in your profile), and to prevent fraud
• Consent: For analytics cookies and marketing communications (where applicable)
• Legal obligation: To comply with Irish and EU regulations

When you use a Platform feature that relies on a third-party processor — for example AI search (Google Gemini), commute times (Google Distance Matrix), calendar sync (Google/Microsoft Calendar), or connecting an AI assistant to your agent account (Anthropic or OpenAI) — that data sharing is carried out under contract performance, to deliver the feature you have chosen to use. Sharing data with our hosting, email and infrastructure providers (see section 6) rests on contract performance and our legitimate interest in operating the Platform securely and reliably.

5. How We Use Your Data

We use your personal data to:

• Provide and maintain the Platform
• Match you with relevant property listings based on your saved searches
• Send transactional emails (listing confirmations, saved search notifications)
• Improve our services and user experience
• Prevent fraud and maintain Platform security
• Verify Approval in Principle documents submitted by buyers to display a Buyer Approved badge to estate agents (automated extraction only; documents are not read by Truehome staff unless you request manual review)

6. Data Sharing

We do not sell your personal data. To operate the Platform we share specific data with the third-party processors listed below. Each receives only the data it needs for its stated purpose, under a data-processing agreement.

Each processor handles data under its own privacy policy: Google (Cloud, Gemini, Distance Matrix, Calendar), Microsoft, HERE, Mapbox, Twilio/SendGrid, Stripe, Slack, Anthropic and OpenAI.

We also share data with:

• Other users: Your public listing information is visible to all Platform users
• Agents you contact: When you message an agent about a listing, your messages and enquiry details are shared with that listing's agent. If the listing is later transferred to a different agent (for example when an agent leaves an agency), your conversation and its message history become visible to the new agent, and the previous agent keeps read-only access to it for continuity.
• Legal requirements: When required by Irish or EU law, regulation, or legal process

6a. Google API Services User Data Policy

Truehome's Calendar Sync feature connects to the Google Calendar API. Truehome's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Specifically:

• We use Google Calendar data only to provide the calendar sync feature you have connected: detecting scheduling conflicts and keeping your Truehome viewing appointments in sync with your external calendar.
• We do not use Google Calendar data to serve advertising of any kind.
• We do not allow humans to read Google Calendar data, except where you have given affirmative agreement for a specific case, where it is necessary for security purposes such as investigating abuse, to comply with applicable law, or on an aggregated and anonymised basis for internal operations permitted under the policy.
• We do not transfer Google Calendar data to any third party except Google itself and Truehome's infrastructure providers, who process it solely on Truehome's behalf under the same restrictions described above.

7. Data Retention

We retain personal data only for as long as we need it. As a baseline, your personal data is kept while your account is active and removed within 30 days of account deletion. We may keep anonymised, aggregated data (such as listing view statistics) indefinitely. The categories below have their own schedules:

7a. Audit Logging

For security, fraud prevention and dispute resolution, Truehome keeps audit logs of significant actions on the Platform — account and profile changes, bids placed, viewing bookings, and buyer-verification events. Each entry records what changed, a timestamp and the originating IP address. These logs are used only for those purposes — never for marketing or analytics — and are retained for as long as needed to investigate security incidents or resolve disputes.

8. Your Rights Under GDPR

Under the GDPR, you have the following rights:

• Right of access: Request a copy of your personal data — use the "Export My Data" button in your profile settings
• Right to rectification: Update inaccurate data via your profile settings
• Right to erasure: Delete your account and data — use the "Delete My Account" button in your profile settings
• Right to restrict processing: Request that we limit how we use your data
• Right to data portability: Receive your data in a machine-readable format (JSON)
• Right to object: Object to processing based on legitimate interest
• Right to withdraw consent: Withdraw consent for analytics at any time via cookie settings

To exercise any of these rights, contact us at privacy@truehome.ie or use the self-service tools in your profile settings.

9. Cookies

We use cookies to provide essential functionality and, with your consent, for analytics. For full details, see our Cookie Policy.

9a. Analytics & Error Reporting

Truehome uses a lightweight, first-party analytics module to understand how the site is used and to detect technical errors. This module captures:

• Page-load performance — timing metrics (e.g. time-to-first-byte, DOM ready) to help us optimise load speed.
• Click events — which links and buttons are used, without recording the text you type or any form content.
• JavaScript errors — error messages and stack traces when something breaks, so we can fix it.

Each event is tied to a session correlation ID. No personally identifiable information (name, email, address, payment details) is sent via this module. Sensitive surfaces — including the feedback form, account-settings forms, and the payment flow — are excluded from click tracking via a data-private marker. Raw event data is retained for 30 days and then deleted. You can opt out by disabling JavaScript for this site, though doing so will also prevent core interactive features from working.

10. International Data Transfers

Your data is stored and processed within the European Economic Area (EEA) on Google Cloud Platform servers located in Europe. Where third-party services process data outside the EEA, appropriate safeguards (Standard Contractual Clauses) are in place.

11. Data Security

We implement appropriate technical and organisational measures to protect your data, including encryption in transit (TLS), secure cloud infrastructure, access controls, and regular security reviews.

12. Children's Privacy

The Platform is not intended for children under 18. We do not knowingly collect personal data from children.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify registered users of material changes via email. The "Last updated" date at the top indicates the most recent revision.

14. Complaints

If you have concerns about how we handle your data, you may lodge a complaint with the Data Protection Commission (DPC), Ireland's supervisory authority.

15. Buyer Approved Feature

The Buyer Approved badge indicates that you have submitted a document that our automated system identified as an Approval in Principle (AIP) from a recognised Irish lender, with a valid future expiry date. Truehome is not a financial services provider. We do not verify approvals directly with lenders, and the badge does not constitute financial advice or a guarantee of mortgage approval. Estate agents using the Platform should verify mortgage status directly with buyers and their lenders before making decisions. The legal basis for processing AIP documents is our legitimate interest in providing a meaningful buyer verification signal on the Platform, balanced against your privacy interests through immediate document deletion and minimal data retention.

16. AI Assistant Connector (for estate agents)

Estate agents can connect an AI assistant, such as Anthropic's Claude or OpenAI's ChatGPT, to their Truehome agent account, and then manage their desk by talking to that assistant. This section explains the data implications. Buyers and other Platform users are not affected unless their listing agent chooses to use the connector with data relating to them.

The connection uses OAuth, so your Truehome password is never shared with the assistant. You grant access with a token that you can revoke at any time by disconnecting the assistant from its own settings or from your Truehome account. You also choose what the assistant may do, ranging from read only, to preparing drafts, to taking actions on your behalf. Every action that sends a message or changes data is shown to you in full and waits for your confirmation before it happens.

When you use the connector, the assistant reads and acts on your existing Truehome data at your instruction. Depending on what you ask it to do, this can include your listings, enquiries, viewings, offers, private notes and the messages buyers have sent you. That data is processed by the AI provider you have connected (Anthropic or OpenAI), each acting under its own privacy policy and under its data-processing terms with Truehome, and it is not used to train their models under those terms.

Your responsibility as an agent. Some of the data the assistant can reach is personal data about buyers who contacted you, including their names, contact details and message content. By connecting an assistant and asking it to work with that information, you are choosing to share it with the AI provider you selected. You remain responsible for handling buyer personal data in line with your own obligations under the GDPR, and for using the connector only for legitimate estate-agency purposes. If in doubt, do not grant the assistant the ability to read buyer conversations.

The legal basis for the sharing the connector performs is contract performance, to deliver the feature you have chosen to use. We keep a record of your authorisation and an audit trail of the actions the assistant takes on your behalf, as described in sections 3, 6 and 7.

17. Contact

For privacy-related enquiries, contact us at privacy@truehome.ie.