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Draft — not yet reviewed by a solicitor. This document was generated based on what Deal Analyser actually does technically, but data protection law application depends on specifics of your business (registered entity, other data flows, ICO registration status) that only a solicitor reviewing your full operation can confirm. Do not publish this as final without that review — every bracketed [placeholder] below needs a real value, and the whole document needs sign-off.
Privacy Policy
Last updated: [date of publication]
This policy explains what personal data Deal Analyser collects, why, and what rights you have over it. It applies to the Deal Analyser website and mobile app.
Who we are
Global Tech Develop Ltd, registered in England and Wales under company number 16250551, registered office 124 City Road, London, England, EC1V 2NX, is the data controller for the personal data described in this policy. We are registered with the Information Commissioner's Office (ICO) — our ICO registration number is [ICO registration number — confirmed registered, but you'll need to give me the actual number to put here, e.g. from your ICO registration certificate or ico.org.uk's public register lookup].
What we collect
- Account data: name, email address, and password (stored as a one-way cryptographic hash — we never store or can see your actual password).
- Deal data: the property figures you enter into the calculator (purchase prices, rents, costs) and any deals you choose to save to your account.
- Communication data: if you sign in, a one-time 6-digit code is emailed to you as part of two-factor authentication. If you subscribe to our newsletter, your email address and subscription status.
- Technical data: IP address and basic request logs, collected automatically by standard web server operation, used for security and abuse prevention.
- Sign-in data (if you use Google or Freedom Property Academy sign-in): your name and email address as provided by that service, used to create or match your Deal Analyser account. We do not receive your Google or Freedom Property Academy password.
We don't collect payment card details, and we don't use tracking or advertising cookies. We do use a single first-party cookie to remember your cookie preference itself — this is exempt from needing consent, since its only purpose is remembering the choice. Three genuine third-party services (Google Fonts, Google reCAPTCHA, and Google Sign-In) only load after you accept them in the cookie banner shown on your first visit; rejecting them still lets you use the calculator and everything else normally, with system fonts and email/password sign-in only. You can change your choice any time via "Cookie Preferences" in the footer.
Why we process it, and our legal basis
- Providing the calculator and your account — necessary to perform our contract with you (UK GDPR Art. 6(1)(b)).
- Two-factor authentication codes — necessary for account security, a legitimate interest (Art. 6(1)(f)) that doesn't override your rights, since it exists to protect your own account.
- Newsletter emails — only with your explicit, opt-in consent (Art. 6(1)(a)), confirmed by a confirmation-link click before you're added to any send list. You can withdraw this consent at any time via the unsubscribe link in every email, with no need to sign in.
- Fraud and bot prevention (reCAPTCHA) — legitimate interest in keeping the service usable and secure.
Who we share data with
We use the following processors, each bound by their own data processing terms:
- Amazon Web Services (AWS) — hosting and email delivery (Amazon SES). Data is hosted in the eu-west-2 (London) region, as recommended elsewhere in this build — update this line if you deploy to a different AWS region.
- Google — reCAPTCHA (bot protection on sign-up) and, if you choose to use it, Google Sign-In. Google's own privacy policy governs data it processes for these purposes.
- HM Land Registry — we retrieve (not send) publicly available sold-price data to power the market price-check feature. No personal data of yours is sent to HM Land Registry.
- Freedom Property Academy — if you access Deal Analyser via single sign-on from Freedom Property Academy, your name and email are shared between the two systems to match your account.
We do not sell personal data to anyone, for any purpose.
How long we keep it
[Retention period — a business decision, not a technical one. Common approach: account data kept for the life of the account plus a defined period after closure (e.g. 6 years, aligned with standard UK limitation periods for contract claims); confirm the actual figure with your solicitor and insert it here.]
Your rights
Under UK GDPR, you have the right to:
- Access the personal data we hold about you
- Have inaccurate data corrected
- Request erasure of your data ("right to be forgotten")
- Request a portable copy of your data
- Object to processing based on legitimate interest
- Withdraw consent at any time (e.g. unsubscribing from the newsletter)
How to complain
If you're unhappy with how we've handled your personal data, you can raise it directly with us — by any means, including email, and we don't require a specific form. Contact [data protection contact email]. We will acknowledge your complaint within 30 days and respond without undue delay.
If you're not satisfied with our response, you also have the right to complain directly to the Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint — raising it with us first is not a requirement for going to the ICO, though we'd appreciate the chance to put things right directly.
Children
Deal Analyser is intended for adults (18+) making property investment decisions. We do not knowingly collect data from children.
Changes to this policy
We'll update this page if how we handle data changes, and update the date at the top when we do.
Contact
Global Tech Develop Ltd, 124 City Road, London, England, EC1V 2NX, [contact email].