Privacy Policy
Version 2 · 10 October 2026
1. Who we are
[[COMPANY_LEGAL_NAME]] operates the ASL platform and is responsible for the personal data processed through it. This policy explains what data we collect, why, who we share it with, and what your rights are.
2. The data we collect
Data you give us: • Account details: full name, email address, phone number and password (stored hashed; we cannot read it). • Identity verification data: photos of the front and back of your ID card, a selfie, and the outcome of the review. • Listing data: the description, photos, documents, price, location and address of the property. • Broker applications and managed-marketing requests, and the details they contain. Data collected automatically: • IP address, device name and browser or app type when you sign in. • A security log of actions on the account, such as sign-in, sign-out and password changes. • Your approximate or precise location, only if you grant the app location permission. • The versions of the Terms and of this Privacy Policy you accepted, and when. Payment data: • When you buy a paid service we keep a record of the transaction (amount, status, reference number). Card details are entered with the payment provider; we do not keep full card numbers.
3. How we use your data
• To create your account, confirm it by email, sign you in and protect the account. • To verify your identity and Broker status in order to reduce fraud. • To review and publish your Listings and show them to people looking for property. • To show properties on a map and convert addresses into locations. • To deliver paid services and process and reconcile their payments. • To send verification codes and notifications about your account, Listings and requests. • To respond to your questions and complaints. • To detect and prevent misuse, keep audit records and meet our legal obligations. Your phone number is a contact detail only; account verification is done by email.
4. The basis for processing
We process your data on the basis of the consent you give when creating the account, to perform these terms and deliver the service you asked for, to comply with legal obligations, and for our legitimate interest in protecting the Platform and its Users from fraud. You can withdraw consent at any time by deleting your account; this does not affect processing carried out before the withdrawal.
5. What other people can see
A published Listing, with its description, photos, price and location, is visible to all Users and visitors of the Platform, together with the Advertiser's name, role and verification status. Your ID photos and selfie are never shown to other Users; only staff authorised to review verification can see them.
6. Who we share your data with
We do not sell your personal data. We share it only with: • service providers acting on our behalf: hosting and databases, storage of photos and documents, maps and location services, email delivery and payment processing. Each receives only what it needs to provide its service; • public and judicial authorities where the law requires it, or to protect our rights or those of Users; • a legal successor in the event of a merger, acquisition or transfer of the business, subject to this policy. Some of these providers may have servers outside your country; in that case data is transferred under the safeguards required by law.
7. Retention and account deletion
We keep your data for as long as your account exists. When you request deletion, the account is disabled and can be restored for 30 days. After that your identifying details (name, email address, phone number, profile photo, address) are removed and the account becomes anonymous. After that we may keep limited records that do not directly identify you, such as payment records, audit logs and verification evidence, for as long as the law requires or as needed to resolve disputes and prevent fraud. If the account is under a legal hold, deletion is postponed until the hold is lifted.
8. Security
We apply technical and organisational measures to protect your data, including encrypted connections, hashed passwords, restricting access to identity documents to authorised staff, logging sensitive actions, and temporarily locking an account after repeated failed sign-in attempts. No security measure is perfect, so we cannot guarantee absolute security. If a breach affects your data we will notify you and the competent authorities as the law requires.
9. Your rights
Under applicable law you have the right to: • access your personal data and obtain a copy of it; • have inaccurate data corrected; you can edit your name inside the app; • ask for your account and data to be deleted; • object to, or ask us to restrict, certain processing; • withdraw your consent; • complain to the competent data-protection authority. To exercise any of these rights, write to us at [[CONTACT_EMAIL]]. We may ask for proof of identity before acting on a request.
10. Device permissions
• Location: to place a property on the map and to show your position on it. It is optional and can be turned off in the device settings. • Camera, photos and files: to upload property photos and documents and identity verification photos. We only access what you choose.
11. Children
The Platform is not intended for anyone under 18 and we do not knowingly collect their data. If we learn that an account belongs to a minor we will delete it.
12. Changes to this policy
We may update this policy. Each update carries a new version number and publication date and is shown in the app, and we may ask for your agreement to material changes.
13. Contact us
For any question about this policy or your data: [[COMPANY_LEGAL_NAME]] Address: [[COMPANY_ADDRESS]] Email: [[CONTACT_EMAIL]]