Privacy Policy

Introduction

Robospien Limited (trading as “MarketCode”, “we”, “us”, or “our”) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and share your information when you use our AI-powered real estate platform, website, and related services (collectively, the “Service”).

We are a company registered in England and Wales. As a data controller, we process your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Information We Collect

Information You Provide

• Account information: name, email address, password, and profile details when you register for an account.
• Payment information: billing address, payment card details, and transaction history (payment processing is handled by our third-party payment processor).
• Communication data: messages, queries, and feedback you send to us or submit through the Service, including conversations with our AI agents.
• User content: data, documents, property information, and other materials you upload or create using the Service.

Information Collected Automatically

• Usage data: information about how you interact with our Service, including pages visited, features used, search queries, and actions taken.
• Device information: browser type, operating system, device identifiers, and screen resolution.
• Log data: IP address, access times, referring URLs, and error logs.
• Cookies and similar technologies: we use cookies and similar tracking technologies to collect information about your browsing activity. See the Cookies section for more details.

Information from Third Parties

• Authentication providers: if you sign in using a third-party service (such as Google), we receive basic profile information from that provider, such as your name, email address, and profile picture.
• Public data sources: we may collect publicly available property and market data to enhance our Service.

Information from Connected Services

If you choose to connect third-party services to your account (such as Google Workspace, including Google Drive, Gmail, or Google Calendar), we may access and process data from those services on your behalf. The specific data accessed depends on the permissions you grant and may include:

• Files and documents you select or make available through the connected service.
• Email metadata and content relevant to your use of the Service.
• Calendar information used to support scheduling and workflow features.

We only request the minimum permissions necessary to provide the features you use. You can revoke access to connected services at any time through your account settings or the third-party service's own permissions page.

How We Use Your Information

We use your information for the following purposes:

• Providing the Service: to operate, maintain, and improve our AI-powered real estate platform, including property analysis, sourcing, and due diligence features.
• AI processing: to power our AI agents and models that provide property insights, market analysis, and personalised recommendations. Your inputs may be processed by artificial intelligence systems to generate outputs.
• Account management: to create and manage your account, authenticate your identity, and provide customer support.
• Communication: to send you service-related notifications, updates, and marketing communications (where you have opted in).
• Analytics and improvement: to understand usage patterns, diagnose technical issues, and improve the quality, performance, and safety of our Service.
• Legal compliance: to comply with applicable laws, regulations, and legal processes.
• Security: to detect, prevent, and respond to fraud, abuse, and security incidents.

AI Data Processing

Our Service uses artificial intelligence and machine learning technologies to provide property analysis, market insights, and other features. In connection with this:

• Your inputs (such as queries, uploaded documents, and property data) are processed by AI models to generate relevant outputs and recommendations.
• We may use aggregated, anonymised data to improve our AI models and the overall quality of the Service. Individual personal data is not used for model training without your explicit consent.
• AI-generated outputs are provided for informational purposes and should not be relied upon as the sole basis for property investment or financial decisions.

Third-Party AI Providers

We use third-party AI service providers to process data and generate outputs. Each provider is bound by data processing agreements and is not permitted to use your data for their own purposes. Specifically:

• Anthropic (Claude): prompts and outputs are not used to train Anthropic's models under our commercial agreement. Data is processed in accordance with Anthropic's commercial terms and is not retained beyond what is necessary to provide the response.
• OpenAI / Azure OpenAI: when using Azure OpenAI, your prompts, completions, embeddings, and training data are not available to other customers and are not used to improve OpenAI or Microsoft models.
• Google Cloud AI: Google Cloud does not use customer data to train its foundation models. Data processed through Google Cloud AI services is governed by Google Cloud's data processing terms.

Legal Basis for Processing

Under UK GDPR, we rely on the following legal bases to process your personal data:

• Contract performance: processing necessary to provide the Service you have requested (Article 6(1)(b)).
• Legitimate interests: processing necessary for our legitimate business interests, such as improving our Service, ensuring security, and preventing fraud (Article 6(1)(f)).
• Consent: where you have given explicit consent, such as for marketing communications or optional data processing (Article 6(1)(a)).
• Legal obligation: processing necessary to comply with legal requirements (Article 6(1)(c)).

How We Share Your Information

We do not sell your personal data. We may share your information with:

• Service providers: trusted third parties who assist us in operating the Service, including cloud hosting, payment processing, AI model providers, analytics, and customer support tools. These providers are contractually obligated to protect your data.
• Professional advisers: lawyers, accountants, and auditors where necessary for our business operations.
• Legal requirements: when required by law, court order, or governmental authority, or to protect our rights, safety, or property.
• Business transfers: in connection with a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction.

Third-Party Integration Data

When you connect third-party services to your MarketCode account, the data accessed from those services is used solely to provide and improve the user-facing features you have requested. We do not use data obtained from third-party integrations for purposes unrelated to the Service.

Google API Services

MarketCode's use and transfer of information received from Google APIs adheres to theGoogle API Services User Data Policy, including the Limited Use requirements. Specifically:

• We only access the Google user data necessary to provide the features you have enabled (e.g., document import from Google Drive, calendar integration).
• Google user data is used solely to provide or improve user-facing features that are prominent in the Service.
• We do not transfer Google user data to third parties except as necessary to provide the Service, with your explicit consent, for security purposes, or to comply with applicable laws.
• We do not use Google user data for serving advertisements, including retargeting, personalised, or interest-based advertising.
• We do not allow humans to read Google user data unless we have your affirmative consent, it is necessary for security purposes or to comply with applicable law, or the data has been aggregated and anonymised for internal operations.

You may revoke MarketCode's access to your Google account at any time via yourGoogle Account permissions page.

Cookies and Tracking Technologies

We use the following types of cookies:

• Essential cookies: required for the Service to function properly (e.g., authentication and security).
• Analytics cookies: help us understand how visitors interact with the Service (e.g., Google Analytics).
• Functional cookies: remember your preferences and settings.

You can manage your cookie preferences through your browser settings or our cookie consent tool. Disabling certain cookies may affect the functionality of the Service.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this policy, unless a longer retention period is required by law. Specifically:

• Account data: retained for the duration of your account and for a reasonable period thereafter to comply with legal obligations.
• AI interaction data: conversation logs and AI-generated outputs are retained for a limited period to provide the Service and improve quality, unless you request earlier deletion.
• Payment data: retained as required by tax and accounting regulations.
• Third-party integration data: data accessed from connected services (such as Google Workspace) is retained only for as long as necessary to provide the features you have enabled. When you disconnect a service or delete your account, associated integration data is deleted.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest.
• Access controls and authentication mechanisms.
• Regular security assessments and monitoring.
• Employee training on data protection practices.

While we take reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security.

International Data Transfers

Your data may be processed in countries outside the United Kingdom. Where we transfer data internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO), or transfers to countries with adequate data protection standards.

Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

• Right of access: request a copy of the personal data we hold about you.
• Right to rectification: request correction of inaccurate or incomplete data.
• Right to erasure: request deletion of your personal data in certain circumstances.
• Right to restriction: request that we restrict processing of your data in certain circumstances.
• Right to data portability: request a machine-readable copy of data you have provided to us.
• Right to object: object to processing based on legitimate interests or for direct marketing purposes.
• Rights related to automated decision-making: where we make decisions based solely on automated processing (including AI), you have the right to request human review.
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, please contact us using the details in the Contact section. We will respond to your request within one month.

Children's Privacy

Our Service is not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us and we will promptly delete it.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the “Last updated” date. Your continued use of the Service after any changes constitutes acceptance of the updated policy.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, pleasecontact us.