SafeBuy Georgia ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal data in compliance with GDPR, UK GDPR, and Georgian data protection laws.
1. Data We Collect
We collect the following types of data:
- Account Information: Email, name, phone number (when you register)
- Property Interactions: Properties you view, favorite, compare, or request viewings for
- Search Data: Search queries, filters applied, and browsing patterns
- Location Data: District-level location (not precise GPS) to show nearby properties
- Device Information: Device type, OS version, app version for technical support
- Usage Analytics: How you use app features, time spent on screens
- Preferences: Quiz answers, lifestyle preferences, budget range
- Chat Metadata: Duration, message count (NOT message content)
- Voice & Audio: Microphone access for voice chat features (only when you initiate)
- Performance Data: Crashes, errors, load times
2. How We Use Your Data
We use your data for the following purposes:
- Essential Services: Account management, property viewing requests, customer support
- Product Improvement: Understand which features are most valuable
- Personalization: Recommend properties matching your preferences (with your consent)
- Market Intelligence: Generate anonymized insights about property demand trends
- Safety & Security: Prevent fraud, ensure platform safety
- Legal Compliance: Meet regulatory requirements
3. Legal Basis for Processing
We process your data based on:
- Contract Performance: Essential services you requested
- Consent: Analytics, marketing, personalization (you can withdraw anytime)
- Legitimate Interest: Product improvement, fraud prevention
- Legal Obligation: Compliance with laws
4. Data Sharing & AI Processing
We share your data only when necessary:
- Service Providers: Firebase (Google) for app infrastructure and authentication
- AI Providers: When you use our AI features (SafeBuy AI chat, document analysis, financial checkup), your inputs — including chat messages, uploaded document images, and financial details — are sent to Google (Gemini) and OpenAI for processing. These providers process data under their data processing agreements and do not use your data to train their models.
- Property Owners/Agents: When you request a viewing
- Aggregated Insights: We may sell anonymized, aggregated market intelligence (never individual user data) to real estate developers, researchers, or market analysts
- Legal Requirements: When required by law
We NEVER sell your personal identifiable information.
5. Public Registry Data (NAPR)
Our app displays property ownership information obtained from Georgia's National Agency of Public Registry (NAPR), a publicly accessible government database. This includes property owner names, ownership percentages, and masked personal identification numbers.
Legal basis: Legitimate interest (Article 6(1)(f) GDPR). Displaying public registry data serves the legitimate interest of property transaction transparency and buyer due diligence, which is the intended purpose of the public registry. Personal IDs are partially masked to minimize data exposure. If you are a property owner and wish to exercise your rights regarding this data, please contact us.
6. Data Retention
- Account Data: Retained while your account is active, deleted upon request
- Analytics Events: Raw data kept for 90 days, then aggregated and anonymized
- Aggregated Insights: Kept indefinitely (no personal identifiers)
- Chat History: Stored securely, deleted upon request
7. Your Rights (GDPR)
You have the right to:
- Access: Request a copy of your data
- Rectification: Correct inaccurate data
- Erasure: Request deletion of your data ("right to be forgotten")
- Restriction: Limit how we process your data
- Portability: Receive your data in a machine-readable format
- Object: Object to certain processing activities
- Withdraw Consent: Disable analytics anytime in app settings
To exercise these rights, go to Profile > Privacy & Data or contact us.
8. Cookies & Tracking
We use the following tracking technologies:
- Firebase Analytics: App usage tracking (requires consent)
- Local Storage: Saved preferences, session management
- Crash Reporting: Automatic error detection for bug fixes
You can control tracking in app settings.
9. Children's Privacy
SafeBuy Georgia is not intended for users under 18. We do not knowingly collect data from children.
10. International Transfers
Your data may be processed in:
- Georgia (country): Primary operations
- EU/UK: GDPR-compliant processing
- USA: Firebase (Google), OpenAI, Google (Gemini) servers
For transfers to the USA, we rely on the EU-U.S. Data Privacy Framework where applicable, and Standard Contractual Clauses (SCCs) approved by the European Commission as appropriate safeguards under Article 46 GDPR.
11. Security
We protect your data with:
- Encryption in transit (HTTPS/TLS)
- Firebase security rules
- Regular security audits
- Access controls and authentication
However, no system is 100% secure. Use strong passwords and protect your account.
12. Changes to This Policy
We may update this policy occasionally. You will be notified of significant changes. Continued use after changes constitutes acceptance.
13. Contact Us
For privacy questions or to exercise your rights:
- Email: contact@elix.digital
- In-App: Profile > Support > Privacy Request
Data Protection Officer: contact@elix.digital
SafeBuy Georgia is responsible for data protection compliance. For DPO inquiries, contact contact@elix.digital.
14. Supervisory Authority
If you are unhappy with how we handle your data, you can complain to:
- EU: Your local Data Protection Authority
- UK: Information Commissioner's Office (ICO)
- Georgia: Personal Data Protection Service