This Policy sets out how Propvator Ltd processes personal data relating to visitors to its website and holders of a Propvator account. It is issued under the UK General Data Protection Regulation and the Data Protection Act 2018 and should be read with our Terms and Conditions.
1.1 Propvator Ltd, a company incorporated in England and Wales whose registered office is at Capital Office, 124 City Road, London, EC1V 2NX, is the controller in respect of the processing described below. This Policy covers our website at www.propvator.com, the signed-in dashboard, Propvator AI, the cashback programme and our correspondence with you.
1.2 Enquiries and requests under section 9 should be addressed to support@propvator.com.
2.1 Account data: your name, email address and authentication credentials, the latter stored in hashed form and not accessible to us in plain text. We may also process your country of residence and telephone number where required to verify your identity for lawful basis.
2.2 Dashboard content: the firms you save, their discount codes, and the purchase records you create, including firm, date, account size, sum paid and any reference. Processed to provide the dashboard.
2.3 Receipts, certificates and payment data: documents you upload in support of a purchase record, cashback claim or recorded payout, together with claim status, sums accrued and paid, and the bank, PayPal or cryptocurrency details you supply for settlement. A receipt will ordinarily show your name, email address, the firm, the order reference and the sum paid. Processed to verify, administer and settle claims. Lawful basis include performance of our contract with you, and compliance with a legal obligation as regards accounting and tax records.
2.4 Propvator AI data: the text of each question submitted, the response given, any rating you apply to a response and any written feedback you provide, together with the date and time and technical information about how the query was handled. No identifier is stored alongside those records, and we cannot attribute a query to an individual or link two queries to the same person. Processed to monitor and improve the facility and to identify errors in the interpretation of queries. Lawful basis include our legitimate interests in operating and developing a service provided free of charge.
2.5 Marketing data: your email address, where you have consented on registration, in order to send you offers, promotions and updates. Your consent gives right to lawful basis , which you may withdraw at any time through the unsubscribe link in any such message or by contacting us. Service messages concerning your account, your claims or our terms are sent on the basis of our contract with you and are not marketing.
2.6 Website usage data: where you have consented, information about your use of the website including pages viewed, controls activated, cursor movement, session duration, referring website, approximate location derived from your IP address and device characteristics, collected through cookies and comparable technologies.
2.7 Technical and hosting data: our hosting provider records server logs including IP address, resource requested, time and user-agent string, generated by the hosting platform rather than by our application and retained on the provider’s terms.
2.8 Correspondence: your communications with us, including support and claim correspondence. Lawful basis: our legitimate interests in dealing with communications addressed to us.
2.9 We also process the above where necessary to detect and prevent fraudulent or duplicated claims, to protect the Platform against misuse, to establish, exercise or defend legal claims, and to comply with obligations imposed on us by law, a court or a regulator.
2.10 Propvator AI accepts free text. We do not request personal data through it and it does not require any in order to operate. Any personal data appearing in a stored query is data a user has volunteered into a search field. Please do not enter personal details into it.
3.1 We may publish payout information recorded on the Platform, including your name and country, in leaderboards, tables and comparable features. Lawful basis: our legitimate interests in demonstrating outcomes achieved by users of the Platform.
3.2 You may object to that publication at any time, without giving a reason, by emailing support@propvator.com. On receipt we will remove your information from those features.
3.3 Where you generate an image or summary of your own performance for sharing, the decision to share it and the audience to which it is disclosed are yours.
4.1 Where you submit a receipt, purchase record or certificate in support of a claim, we may verify it with the firm to which it relates, disclosing your name, the order reference, the document and such further information as is necessary to establish that the transaction took place. The lawful basis is performance of our contract with you, the claim not being capable of verification otherwise, together with our legitimate interests in preventing fraudulent claims.
4.2 The firm processes the information disclosed to it as a controller in its own right and under its own privacy notice. We are not responsible for its processing.
5.1 Propvator AI uses a third-party artificial-intelligence language model to interpret the text of a question and to derive structured criteria from it. The query text is transmitted to the supplier with a fixed instruction; no identifier, IP address, country, session data or prior query is transmitted with it.
5.2 The supplier’s commercial terms provide that content submitted through its interface is not used to train its models and is deleted within a defined retention period.
5.3 No profiling is carried out and no decision producing legal effects concerning you, or similarly significantly affecting you, is taken by automated means.
6.1 Strictly necessary cookies are set without consent, the website being unable to function without them. All other cookies, including analytics and session-recording cookies, are set only where consent has been given through our cookie banner. Consent may be withdrawn at any time through the cookie settings control in the footer, without affecting the lawfulness of processing carried out beforehand.
6.2 Propvator AI sets no cookies and writes nothing to your device.
7.1 We do not sell, rent or trade personal data, and we do not disclose it to third parties for their own marketing purposes. We engage the following processors, who act on our instructions under written terms:
(a) Vercel Inc. (hosting of the Platform and dashboard; holds its own server logs. United States.)
(b) Vercel AI Gateway (transmission of query text to the model supplier.)
(c) Anthropic (supply of the language model referred to in section 5.)
(d) Supabase (database services for account data, dashboard content and query records.)
7.2 We may also disclose personal data to prop firms under section 4, to professional advisers, auditors and insurers where necessary, and where required by law, a court or a regulator or necessary to establish, exercise or defend legal claims.
7.3 Certain of the processors above process personal data in the United States. Where personal data is transferred outside the United Kingdom we rely on the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, with a transfer risk assessment where required. A copy of the safeguards relied upon may be requested at support@propvator.com.
8.1 Account data, dashboard content and certificates are retained for the duration of the account. On a deletion request the account is retained for 30 days, during which it may be reinstated, and is then permanently deleted.
8.2 Receipts, cashback claim records and payment records are retained for 6 years from the end of the financial year to which they relate, to satisfy accounting and tax obligations and to permit the defence of claims within the limitation period. Records in this category are retained notwithstanding deletion of an account.
8.3 Propvator AI records under section 2.4 are retained for as long as is necessary for the operation and development of the facility. Where they are retained beyond that period they are held in anonymised or aggregated form, from which no individual can be identified.
8.4 Marketing data is retained until you withdraw consent, after which your address is retained only on a suppression list so that we do not contact you again. Correspondence is retained for 24 months from the last communication unless it relates to a live or anticipated dispute. Analytics data is retained for the period configured with the provider, presently 12 months. Hosting server logs are retained as determined by the hosting provider.
8.5 We transmit all traffic over HTTPS, restrict database access to server-side credentials not exposed to the browser, store authentication credentials in hashed form, and limit access to personal data to those who require it. No system affords absolute security and we do not warrant that ours does. Where a personal data breach is likely to result in a risk to the rights and freedoms of data subjects we will notify the Information Commissioner’s Office within 72 hours of becoming aware of it, and notify affected individuals where the law requires.
9.1 You have the right to be informed of our processing of your personal data; to obtain a copy of it; to have inaccurate data rectified; to request erasure or the restriction of processing; to object to processing carried out on the basis of legitimate interests, including the publication described in section 3; to receive data you have provided in a portable format; and to withdraw consent where processing is founded on consent.
9.2 Propvator AI records under section 2.4 contain no identifier. We cannot determine which records relate to any individual and are not required to obtain further information for the sole purpose of identifying a data subject. If you believe you entered personal details into the query field, tell us approximately when and what was entered and we will search for matching text and delete any record identified.
9.3 Requests may be made at support@propvator.com. We may require proof of identity where a request concerns account or cashback records, and will respond within one month. Where a right cannot be given full effect because we are required to retain records under section 8.2, we will explain the extent to which the request can be met.
9.4 You may complain to the Information Commissioner’s Office at https://ico.org.uk. We ask that you raise the matter with us first.
10.1 The Platform is intended for persons aged 18 and over. We do not knowingly process personal data relating to children, and will delete any such data on being informed of it.
10.2 We may amend this Policy to reflect changes in our processing or in the law. The version number and effective date at the head of this document identify the version in force, and notice of any material amendment will be given on the Platform or by email.
