Privacy policy
What Flat Spain collects, who it goes to, how long it stays, and what you can make us do about it. Written to be read rather than to be survived. The two sections most people want are what we learn from your search and the model that reads your brief.
Who is responsible
Flat Spain is the data controller for everything described here. Reach us at support@lifetti.com.
What we collect
Your brief. What you type when you ask for a search: the city, budget, dates, who is moving, and anything else you tell us. Whatever you put in it, we process — so leave out what you would not want a model provider to see.
Contact and payment. Your email address, and from Stripe a payment reference and status. We never see your card number.
Your report and account. The shortlist produced for you, any re-runs, and messages exchanged with support.
What we learn from your search. The brief, the shortlist it produced and which listings you opened, kept so the service can be made better at reading briefs and screening listings. Stripped of direct identifiers on the way in. There is a section on this below, including how to switch it off without losing anything.
Behavioural measurement. Which pages were visited and whether a visit became an order. Deliberately built not to identify you: a visitor is a hash of IP address and browser string, salted with a key that changes daily, so the same person is a different value tomorrow. The raw IP address is never written to the database, no cookie is set, and nothing here can be joined to your order.
Why we are allowed to
- To perform our contract. Running the search you paid for, delivering the report, taking payment, and supporting you afterwards.
- Legitimate interests. Three things: keeping the service secure and working; the pseudonymous measurement above, which sets no identifier on your device and cannot single you out; and improving how the service reads briefs, screens listings and ranks matches. The section below says exactly what that last one means, and how to stop it.
- Consent. Advertising cookies, and nothing else. Refusing costs you no functionality.
- Legal obligation. Keeping invoices for as long as tax law requires.
How the service gets better, and how to stop it
A search is not a lookup. Reading a brief written in plain English, telling a real advertisement from a bait one, and knowing what a two-bedroom in Ruzafa should cost this month are all things the service has to be good at, and it gets good at them by observing its own work.
What that means concretely. We keep the brief you wrote, the shortlist we produced from it, and what you did with the shortlist — which listings you opened, which you ignored, whether you asked us to widen the search. Those three together are what tell us that a phrasing was misread, that a screening rule fires on listings that turn out to be fine, or that our ranking put the wrong flat first. Text is stripped of direct identifiers before it is stored: email addresses, phone numbers, bank details and ID numbers are replaced with placeholders on the way in, because none of them are what the service needs to learn from.
What you get for it. A second search that reads your wording better than the first did, a scam screen tuned on listings that really did turn out to be ghosts, and price benchmarks drawn from what is actually being advertised in your barrio rather than a national average. This is also why we can tell you a flat has been listed 34 days when the typical one nearby goes in 9 — that sentence only exists because we watched.
What it is not. It is not a profile of you, it is not shared with advertisers, and it is not sold. We do not build an advertising audience out of it. Your brief is not published, and it is not used to train anyone else's public model.
And you can switch it off, without losing anything. This runs on our legitimate interest, so you have an absolute right to object. Turn it off in your account settings or email us, and we stop using your orders this way and delete what we already hold from them. The search, the screening, the benchmarks and the report are exactly the same afterwards — the only difference is that your orders stop contributing to the next improvement. We think that is the right way round: a control worth having is one that costs you nothing to use.
Statistics about the market, not about you
Separately from all of the above, we publish aggregate figures about the Spanish property market: asking prices per m² by barrio, how long listings survive, how often a portal carries an advertisement our screen flags. These are computed from the listings themselves and from counts across many orders. They contain nothing that identifies any person, they cannot be traced back to an individual search, and once aggregated they are no longer personal data at all.
Objecting to the improvement processing above does not remove your orders from these counts, because by the time a figure is a barrio median there is nothing personal left in it to remove. If that distinction matters to you, ask us and we will explain exactly what a given figure is built from.
If you are an agent or a landlord we contacted
Most people reading this are customers. This section is for the other group: the estate agents, agencies and private landlords whose contact details appear on the listings we screen. You did not give us your data and you may never have heard of us, so the law requires us to tell you the following directly.
- What we hold. What the public listing showed: the advertised property, the name, phone number, email or agency shown on it, and where it was published. Where we messaged you, the messages exchanged. Where we can measure it, whether enquiries about your listings were answered and how quickly.
- Where it came from. The property portals and agency feeds where the listing was publicly advertised.
- Why. Our legitimate interest, and our customers', in knowing whether an advertised property is genuine, still available, and answered by someone. A renter losing a deposit to a listing nobody was ever going to answer is the harm this exists to prevent.
- What we publish. Aggregate response rates, never a judgement about you and never an individual accusation. Any figure we publish carries the sample it was measured over and the period it covers.
- Your rights. The same as everyone else's: see what we hold, correct it, have it erased, or object to it entirely. Email us and we will act within one month. If you tell us a listing is no longer yours or no longer live, that is also the fastest way to have it removed from what customers see.
Landlord outreach — read this one
Where the feature is switched on, after your report is delivered we message the shortlisted listings' owners or agents on WhatsApp, in Spanish, to confirm the flat is still available and on what terms. Their answers update your report.
Those messages come from our number, not yours, and we do not pass on your name, email or phone number. What we send is the enquiry itself — the kind of tenancy, the move-in timing and the questions the listing left open.
Who else sees it
We do not sell personal data and we do not share it for anyone else's marketing. These processors act on our instructions:
| Who | For | What they get |
|---|---|---|
| Stripe | Payments | Card details go directly to Stripe and never reach our servers. We store the payment reference and status. |
| Moonshot AI (Kimi) | The AI agents | Your brief and the listings being screened are sent to the model that parses and ranks them. |
| Kapso / WhatsApp (Meta) | Landlord outreach | Where enabled, the messages we send shortlisted landlords on your behalf, and their replies. |
| Apify | Listing collection | Public listing pages are collected through it. Carries no data about you. |
| Supabase | Database & image storage | Where orders, reports and listing images are stored. |
| Vercel | Hosting | Serves the site and processes the request logs that come with that. |
| Resend | Sends the notification telling you a report is ready. | |
| Plausible | Analytics | Aggregate traffic measurement, where configured. Sets no cookie and does not identify you. |
| Google, Meta | Advertising | Only if you accept advertising cookies. Reject and nothing is sent. |
Some of these operate outside the European Economic Area. Where they do, the transfer runs on the European Commission's standard contractual clauses together with an assessment of the destination country's law and, where needed, additional safeguards. The transfer that matters most here is the one to our model provider, and it has its own section below.
The model that reads your brief
Your brief has to be read by a language model to become a search. Today that model is operated by Moonshot AI, whose infrastructure is outside the EEA. This is the single transfer of your data that we would most want you to know about, so it gets its own heading rather than a row in a table.
- What is sent. The text of your brief, and the listing data being screened. Not your email address, not your payment details, not your account history.
- What it is used for. Producing your result, and nothing else. Under our agreement with the provider your content is not used to train their models.
- How the transfer is covered. Standard contractual clauses, plus a transfer impact assessment we keep on file and will show you the conclusions of on request.
- What you can do about it. Write your brief the way you would write it to a letting agent. Everything the search needs is in the property and the budget — a brief never needs your employer, your medical circumstances, your immigration status or anyone's date of birth, and we would rather you left them out than trusted us with them.
Where we improve our own models on the material described above, that is done on our own infrastructure, on text already stripped of direct identifiers, and it is covered by the objection right in the same section.
How long we keep it
- Orders, reports and invoices. For as long as you have an account with us, and thereafter for the period tax law requires.
- Behavioural rows. Deleted automatically after 400 days.
- Quality and improvement records. Deleted automatically after 180 days, and immediately for your orders if you object.
- Feedback records. Deleted automatically after 365 days.
These are enforced by a scheduled job, not by anyone remembering to run one.
Your rights
Under the GDPR you can ask us for any of the following, free, and we will answer within one month.
- Access. A copy of what we hold about you.
- Rectification. Correction of anything wrong.
- Erasure. Deletion, except where we must keep an invoice for tax law.
- Portability. Your data in a machine-readable form.
- Objection. To anything we base on legitimate interests — the behavioural measurement, and the service improvement described above. Switch it off in your account settings, or email us. We stop, and we delete what we already hold.
- Withdraw consent. For advertising cookies, at any time, as easily as it was given.
- Complain. To the Spanish supervisory authority (AEPD, aepd.es), or the authority where you live. We would rather you came to us first, but the right does not depend on that.
Email support@lifetti.com. If you think we have got it wrong, you can complain to the Spanish data protection authority (Agencia Española de Protección de Datos, aepd.es) or to the authority where you live.
Cookies
Set out separately, with a per-category table and a way to change your mind, on the cookie policy.