Privacy policy — Rieltly

1. Who we are

The Rieltly service (the iPhone and Android app, the rieltly.com website and public listing pages on rieltly.com) is provided by sole proprietor (FOP) Arsen Memetov ("we"). Contact for personal data matters: support@rieltly.com.

Agent data (account, agency, subscription, support requests): we are the controller of this personal data.
Data of clients and property owners entered into the app by the agent: the controller is the agent (or their agency). We process it on the agent's behalf and only to run the service.
Data of mini-site visitors who submit an inquiry: we receive the inquiry and pass it to the agent who published the listing; from then on the agent processes this data as the controller, and we do so on their behalf.

2. What data we process

Agent account: email, name, phone, city, agency name, time zone, language, sign-in method (email and password, Apple or Google). If you sign in with Apple, we store the Apple token in order to revoke access when the account is deleted.
Agent work data: listings (type, address, parameters, price, description, photos, status), portal placements (portal, package, cost, dates, links), advertising costs, viewings, deals (stage, amount, commission), notes, notification settings.
Client data entered by the agent: name, phone, email, Telegram, Viber or WhatsApp handles, role (buyer, tenant, seller, landlord), source, request (property type, district, budget, rooms), status, notes, history of viewings and deals.
Property owner data entered by the agent: name, phone, notes. This data is stored separately from the public listing page and never appears on it.
Mini-site inquiries: name, phone, message, preferred viewing time (if given), page language, which listing and which route (link, QR code) the inquiry came from, an irreversible hash of the IP address to prevent abuse.
Public listing data on the mini-site: everything the agent has chosen to publish — photos, price, parameters, description, district or address (the agent chooses the precision), the agent's name, photo and contacts. By design this data is available to anyone with the link.
Subscription: subscription status and dates, purchase identifier in the App Store or Google Play. We never receive your card details.
Support requests: request text, category and attachments.
Technical data: device push token, app platform and version; server technical logs (request time, error codes); app crash reports: error type and text, a stack fragment, app version, OS version and platform, language, screen without parameters, a random installation identifier (not a device identifier). Names, phone numbers and addresses are automatically removed from these reports; reports are kept for 90 days.
Analytics: de-identified app usage events via Firebase Analytics: which screens were opened, key actions (sign-in, trial start, purchase, creating a listing without its data), device model, OS version, app installation identifier. Names, phone numbers, addresses and client data never reach analytics. To turn it off: Settings → Privacy → "Anonymous analytics".

We do not collect device location or the advertising identifier: the map on the mini-site is built from the address entered by the agent. Your phone book is not sent to us: when importing clients, the contact list is shown only on your device, and only the contact you pick is sent to the server. We do not track you in other apps or on websites, do not show ads and do not sell personal data.

3. Why we process data

to run the service: tracking listings, placements and costs, clients, viewings, deals;
to send the agent push notifications: about a placement ending, a viewing, a new inquiry, the end of the trial;
to show public listing pages and receive inquiries from them;
to verify the subscription and grant access to the app;
to answer support requests;
for security, protection against bots and abuse, and finding bugs;
to improve the app using de-identified analytics (unless it is turned off).

Legal bases: performance of the contract with the agent (terms of use), legitimate interest (security, analytics), consent (publishing the agent's photo and contacts on the mini-site, analytics). For client and owner data, the agent provides the legal basis themselves.

4. Where the data is stored

App data and files (listing photos, support attachments) are stored in Supabase, in an EU data centre (Frankfurt). Each agency sees only its own data: this restriction is enforced at the database level. Photos of listings published on a mini-site are served through Cloudflare and cached on its servers worldwide.

Some data is processed by the services listed in section 5. Some of them may process data outside the EU and Ukraine under their own data protection rules.

5. Who we share data with

Supabase — database, account sign-in, file storage, server functions.
Apple — Sign in with Apple, App Store subscription payments, push notification delivery to iPhone.
Google — Google sign-in, Google Play subscription payments, push notifications (Firebase Cloud Messaging), analytics (Firebase Analytics).
Cloudflare — hosting the rieltly.com website and rieltly.com mini-sites, photo caching, email forwarding to support@rieltly.com and protecting the inquiry form from bots (Cloudflare Turnstile: the service sees the page visitor's IP address and browser data).
SendPulse — sending service emails: email confirmation, password reset, data deletion warnings, support replies.
GitHub — storing daily encrypted database backups.

We verify purchases directly with Apple and Google servers, without intermediaries. Real estate portals (OLX, DIM.RIA, Rieltor.ua, LUN and others) receive no data from us: the app does not publish listings on portals, it only keeps a record of what the agent has placed themselves. There are no other recipients. We may disclose data to public authorities only where the law expressly requires it.

6. Mini-sites and the inquiry form

A listing page at rieltly.com is public: anyone with the link or who scanned the QR code can see it, and search engines may index it. The agent decides what is published: they can show only the district instead of the exact address, turn the page off or archive the listing — the page then becomes unavailable immediately. The owner's contacts, notes, placements and costs never appear on the page.

The inquiry form on the page is protected by Cloudflare Turnstile. The inquiry goes to the agent who published the listing, in the app and as a push notification. We do not call visitors or send them messages. If the agent has not accepted the inquiry within 30 days, the name, phone and message are de-identified, and after 90 days the record is deleted. If the agent has added you as a client, they process your data from then on — contact the agent first about it; their contacts are shown on the page.

To protect against bots and count views, we keep an irreversible hash of the visitor's IP address for no longer than 2 days. Mini-sites have no third-party cookies, ad trackers or counters.

7. Demo mode

If the sign-in screen has a "Look around without signing up" button, it creates a temporary anonymous account without email or password, filled with sample listings. The demo lasts 24 hours, after which the account and all changes in it are deleted automatically. The demo sends no push notifications, and mini-sites of demo listings are not publicly available. To limit abuse, we keep an irreversible hash of the IP address that started the demo for no longer than one hour.

8. Retention

While the account exists — all data of the agent, their clients and property owners.
After the subscription ends, the data is kept and the app is read-only. Listing mini-sites keep working for 14 more days, then the page shows "Listing unavailable". The data stays until you delete the account. Accounts that have had no access to the app for 12 months are deleted by us after warnings 30 and 7 days in advance by email to the account address, by push notification and in the app.
After the account is deleted, data and files are deleted immediately (see account deletion).
Mini-site inquiries: de-identified after 30 days, deleted after 90 days if the inquiry was not accepted (section 6). Visitor IP hashes — 2 days.
Support: request attachments are deleted 30 days after the request is closed, closed requests themselves after 180 days.
Subscriptions: App Store or Google Play purchase records (purchase identifier, status and dates) remain after account deletion without being linked to it. Records of ended or refunded subscriptions are deleted 180 days after the last change, the service log of store notifications after 90 days.
Crash reports — 90 days. Demo — up to 24 hours (section 7).
Database backups: daily, encrypted, kept for 30 days. Files (photos, attachments) are not included in backups. Deleted data disappears from backups within 30 days at the latest.

9. Your rights

You have the right to know what data of yours we process, to get a copy of it, to correct it, delete it, restrict processing, withdraw consent and to lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights. You can view and change most of the data in the app. For other requests, write to support@rieltly.com.

Clients and property owners should contact their agent first about their data, since the agent is the one who enters it. Mini-site visitors who submitted an inquiry — the agent whose contacts are shown on the page. You can also write to us, and we will pass the request to the agent or help ourselves.

10. Account deletion

You can delete your account in the app or by email: how to delete the account.

11. Children

The service is intended for agents aged 18 and over. If an agent enters data of a minor, the agent is responsible for obtaining the consent of the parents or legal guardians.

12. Changes to this policy

We may update this policy. The current version is always on this page, with the revision date at the top.