Privacy policy
1. Who is responsible for your information?
NonAgent is operated by an independent self-employed professional based in Spain, who is responsible for personal data handled through the website and services. For privacy matters, contact contact@nonagent.es.
2. What information may we receive?
Depending on how you interact with us, this may include your name, email address, enquiry answers, property listing links, intended property use, purchase stage, deadlines, relevant preferences or circumstances, and messages you send. During an engagement we may also receive interview information, property materials (including documents such as a nota simple), relevant correspondence or screenshots, and information necessary to deliver the agreed analysis.
We may receive information that we did not request. Please do not send identity documents, banking information, special-category personal data or other sensitive material through the enquiry form. If unnecessary material is received, we will limit its use and delete it where appropriate.
Our systems may also process routine technical information needed to operate and protect the website, including hosting and form-submission records. Payment providers process payment-related information when a payment is arranged.
3. Why we use information, and on what basis
- Responding to enquiries and assessing possible engagements: to review what you ask, communicate with you and decide whether we can offer a service. Basis: steps requested before entering a contract, or legitimate interests where appropriate.
- Providing agreed services: to conduct analysis, prepare and deliver video and PDF materials, manage clarifications and maintain engagement records. Basis: performance of a contract.
- Administration and legal obligations: invoicing, accounting, tax records, legal requests and relevant compliance. Basis: legal obligations and, where appropriate, legitimate interests.
- Protecting the business and resolving issues: preserving a defensible record of what was agreed and delivered, investigating factual corrections or complaints and handling potential claims. Basis: legitimate interests, subject to applicable rights and retention limits.
- Optional marketing emails: only when you subscribe separately. Signup uses a confirmation email (double opt-in), and our email platform processes your email address and subscription status to send these messages. Basis: consent. You can unsubscribe at any time.
- Optional interview or call recordings: recording takes place only after explicit permission, for accuracy and preparation of the analysis. We offer a non-recorded alternative.
- Testimonials and client-specific public case studies: only with separate permission for the proposed publication. General lessons and appropriately de-identified property research may be used internally without turning client information into public material.
4. AI-assisted analysis
NonAgent may use AI-assisted tools to organise, interpret, summarise or draft parts of its analytical work. A person remains responsible for the conclusions and deliverables. We aim to minimise client identifiers before using these tools and do not intentionally submit unnecessary sensitive information.
5. Service providers and sharing
We use third-party services for website hosting, email, file storage, payments and, where relevant, online meetings and analytical work. These providers may process information as service providers or independent controllers, depending on their role. We may also share information with professional advisers or authorities where necessary and lawful. We do not sell personal information.
Some services may involve processing outside the European Economic Area, subject to applicable data protection requirements.
6. Recordings, transcripts and property research
Context & Fit may include an interview. Recording is recommended to support accuracy but is optional and requires explicit permission. Where practical, recordings or transcripts are stripped of identifying details before analytical reuse. Removing names alone does not necessarily make information anonymous.
We maintain a distinction between identifiable client records and a property research database. Research observations and analytical findings may be retained for comparison, learning and service improvement, while avoiding unnecessary client details. Publishing client-specific deliverables or case studies is handled separately and requires appropriate permission.
7. How long information is kept
Unsuccessful enquiries are provisionally kept for up to six months, unless a longer period is justified by a continuing exchange, legal requirement or dispute. Client engagement records, final deliverables, relevant supporting evidence and material correspondence are retained for an appropriate, documented period to support professional accountability and potential claims. Financial records are kept for applicable statutory periods. Temporary files and unnecessary copies are deleted sooner.
8. Delivery files
When Google Drive is used to deliver completed work, access is restricted to specified recipients and is normally available for 30 days after delivery. This does not mean that NonAgent deletes its internal engagement archive after 30 days. Clients should download their copies during the access window.
9. Your rights
Subject to applicable law, you may request access to your personal data, correction, deletion, restriction, objection or portability, and withdraw consent where processing depends on it. Use the contact details in section 1. Withdrawing consent does not invalidate earlier lawful processing.
You may also lodge a complaint with the Spanish Data Protection Agency (AEPD).
10. Security and changes
We use proportionate access controls, restricted sharing and data minimisation, and review how client information is handled. No online transmission or storage system is risk-free. We may update this policy when our actual tools, services or legal requirements change, and will show the effective date above.