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 sent through the Platform and enquiry details
• 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 — when you save a search created from an AI chat — a snapshot of that conversation. The AI provider's replies are also logged for cost tracking and quality monitoring.
• 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.

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 improve the Platform, prevent fraud, and ensure security
• 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) or calendar sync (Google/Microsoft Calendar) — 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 and Slack.

We also share data with:

• Other users: Your public listing information is visible to all Platform users
• Legal requirements: When required by Irish or EU law, regulation, or legal process

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. Contact

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