DRAFT — Requires Formal Legal Review
This privacy policy specifies EstateTrack's data handling architecture and regulatory compliance commitments under Master Blueprint §19. Formal counsel reviews are registered with national data protection authorities prior to regional commercial rollouts.Dual Controller/Processor Framework & Data Isolation Standards
We collect minimal data necessary to power automated property operations and vacancy discovery. EstateTrack operates in a dual capacity: we control platform accounts and billing data, while landlords control their operational tenancy records. We never sell personal data or track you across the web. You have the right to access, export, or delete your information at any time, subject to statutory 3-year financial ledger retention rules.
To provide transparent data protection compliance (including GDPR and the Kenya Data Protection Act, 2019), EstateTrack operates under a distinct dual responsibility model:
We act as the authoritative Data Controller for account authentication profiles, credential security, landlord subscription billing records, edge security telemetry, and user legal consent logs.
The landlord or executive management firm is the Data Controller for all operational tenancy records (tenant contact records, lease agreements, unit assignments, rent invoices, maintenance logs, and in-app communications). EstateTrack processes this data solely on the landlord's instruction within strict organizational boundaries.
EstateTrack collects prospective tenant inquiries upon one-time email confirmation as initial Controller, and securely delivers confirmed leads to the listing landlord and assigned staff for vacancy fulfillment.
Name, verified email, telephone number, display title, organization trade name, country, pricing tier, and subscription payment history.
Name, verified email, phone number, role assignment, and associated property assignment identifiers.
Name, verified email, phone number, assigned unit, lease terms, payment claim references, and maintenance submissions.
Email address (one-time confirmed), inquiry message, search text criteria, and session security tokens. Zero account credentials created.
Data visibility within an organization is strictly partitioned by role (Master Blueprint §1.7):
We partner exclusively with SOC-2 and ISO 27001 certified infrastructure providers. We do not sell, rent, or trade telemetry to advertising data brokers:
For a complete sub-processor registry, review our Service Providers Directory.
We retain personal records only as long as necessary to provide platform services and satisfy statutory obligations (Master Blueprint §19.10):
| Data Category | Retention Duration | Post-Retention Action |
|---|---|---|
| Active Tenancy & Portfolios | Life of active account | Retained while active |
| Closed Landlord Organization | 30-day reversible window | Permanent purge on Day 30 |
| Media Uploads (Purged Account) | Purged immediately on Day 30 | Permanent storage erasure |
| Financial Ledger Entries | 3 Years in compliance archive | Permanent erasure after 3 yrs |
| Tenant Move-Out Profile | Login ends immediately | Email freed platform-wide |
| Seeker Vacancy Inquiries | 12 Months | Automated record purge |
| Legal Consent Audit Records | Life of account + 6 years | Statutory evidentiary archive |
Every user retains fundamental data autonomy rights under applicable privacy legislation:
To exercise any privacy right, contact our Data Protection desk. We respond to all formal requests within thirty (30) calendar days.
For questions regarding data processing, cross-border transfers, or to file an inquiry, reach out to our dedicated privacy office:
privacy@myestatetrack.com • Data Protection Desk, XILFANX LLC
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