GILD-TECH builds Sarah, an assistant that answers buyers and sellers on WhatsApp on behalf of real estate agencies. This policy explains what personal data we process, why, on what legal basis, who we share it with, how long we keep it, and how you can exercise your rights or have your data deleted. It applies under the UK GDPR and the Data Protection Act 2018 in the United Kingdom, the GDPR in the European Union, and Thailand's Personal Data Protection Act (PDPA, B.E. 2562, 2019) for people and agencies in Thailand.
1. Who we are
Girlden LTD, trading as GILD-TECH
Company registered in England and Wales, number 14837617
Registered office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Email: ops@gild-tech.com
2. Three situations, two roles
- Real estate agencies, their staff and our prospects: Girlden LTD is the data controller.
- People who message GILD-TECH's demonstration number: Girlden LTD is the data controller.
- Buyers and sellers who message an agency that uses Sarah: the agency is the data controller and Girlden LTD is its data processor. We act only on the agency's documented instructions, under a data processing agreement signed at the start of the service.
3. Data we process
About agencies and our prospects: name, job title, company, email, phone, the content of our exchanges, meetings booked with us, billing data.
About people who message on WhatsApp, either an agency that uses Sarah or GILD-TECH's demonstration number:
- the phone number and the WhatsApp profile name;
- the content of messages, including voice notes (transcribed to text) and media sent;
- what the person says about their search or their property: type of property, area, budget, timeline, language;
- the call-back time they chose and the name of the agent who calls back;
- the history of the conversation and of the follow-ups.
4. Why we process it, and on what basis
| Purpose | Legal basis |
|---|---|
| Replying to the person on behalf of the agency, in their language, qualifying the request, passing their details to the agent, sending follow-ups | The basis chosen by the agency, as controller: usually steps taken at the person's request before a possible contract, or the agency's legitimate interest. We act as its processor. |
| Replying to people who message the demonstration number and showing them the service | GILD-TECH's legitimate interest |
| Providing the service to client agencies | Performance of the contract |
| Billing and keeping our accounts | Legal obligation |
| Talking with agencies interested in Sarah, booking a meeting | GILD-TECH's legitimate interest |
Follow-ups comply with WhatsApp's rules. We do not sell personal data. We do not use buyers' and sellers' data for our own marketing or for advertising.
5. How long we keep it
- An agency's buyers and sellers: for as long as the agency's contract with us lasts, then deleted or returned to the agency within 30 days of the end of the contract, unless the agency asks for earlier deletion.
- Conversations with the demonstration number: 90 days after the last message.
- Prospects: 3 years from the last contact.
- Clients: the length of the contract, then the period required by law.
6. Service providers
We use the following providers (sub-processors) to deliver the service:
| Provider | Purpose |
|---|---|
| Meta Platforms (WhatsApp Business Platform, Cloud API) | Receiving and sending WhatsApp messages |
| WaSender | Receiving and sending WhatsApp messages for GILD-TECH's demonstration number and for agencies that do not use Meta's API |
| Anthropic | Writing Sarah's replies (Claude AI model) |
| ElevenLabs | Transcribing voice notes and voice |
| Google (Google Workspace, Google Sheets) | Tracking sheet and email |
| n8n | Hosting the automations that connect the services |
| Stripe | Billing of agencies |
| Calendly | Booking a meeting with GILD-TECH from our website |
| GitHub Pages | Hosting our website |
| Google Fonts | Fonts on our website (your IP address is sent to Google when a page loads its fonts) |
Some providers may process data outside the United Kingdom, the European Union or Thailand. In that case, transfers rely on appropriate safeguards (adequacy decisions or standard contractual clauses).
7. How to delete your data
To delete the data linked to a WhatsApp conversation with an agency that uses Sarah, or with GILD-TECH's demonstration number, send an email to ops@gild-tech.com with the subject Delete my data, and include:
- your WhatsApp phone number;
- the name of the agency you contacted, or "GILD-TECH demonstration".
We delete the data and confirm it to you within 30 days.
8. Your rights
You can ask to access, correct, delete or receive a copy of your data, to restrict or object to its processing, and to withdraw your consent at any time. These rights apply in the United Kingdom, in the European Union and in Thailand (PDPA). Write to ops@gild-tech.com. If you contacted an agency, you can also ask the agency directly; we help the agency answer. We reply within one month.
9. Complaint
You can complain to the Information Commissioner's Office in the United Kingdom (ico.org.uk), to your local data protection authority in the European Union, for example the Data Protection Authority in Belgium (dataprotectionauthority.be) or the CNIL in France (cnil.fr), or, in Thailand, to the Personal Data Protection Committee (pdpc.or.th).
10. Security
Access to data is limited to the people who need it. Access keys are stored outside our code, and connections are encrypted.
11. Changes
We update this page when our practices change. The date of the last update is shown at the top.