Privacy Policy
Last updated: 21 October 2026
1. Who we are
Properly Tech LLC (ТОВ «Проперлі Теч»; EDRPOU code 45821219; 38 Mytropolyta Vasylia Lypkivskoho St., Building A, Apt. 100, Kyiv 03035, Ukraine) — “Properly”, “we” or “us”. We build Properly, a CRM and ERP system for residential real estate developers, provide it to our customers and operate the website properly.digital.
For any question about personal data, write to support@properly.digital.
2. Our two roles
Controller. We decide why and how to process the data of website visitors, of people who contact us, and the contact details of our customers’ representatives.
Processor. Developers who use Properly keep the data of their leads and buyers in their own Properly system: contacts, conversations, apartment selections, contracts and payments. This also covers the customer’s user accounts and their activity log in the system. The developer is the controller of that data. We process it only on the developer’s instructions and under our contract with them.
If you sent an enquiry to a developer or are buying a home from one, please contact that developer first about your data. If you send your request to us, we will pass it to the developer and help fulfil it.
Exception: data received through Meta platforms. Under Meta’s rules and our contract with the customer, we delete such data at the request of the person it concerns — see the Data Deletion page.
3. What data we process
Website visitors. Technical request data: IP address, browser and device type, page and time. The logs of the web server that hosts the website record this data to deliver pages and protect against attacks. The website uses no analytics services.
People who contact us via Telegram, phone or email: name, company, position, phone number, email, Telegram username and the content of the conversation. Website enquiries are handled by a business development manager of our sales partner M4U.
Our customers’ representatives: name, position, work email and phone number, and correspondence with us about the contract and support.
Data in our customers’ systems (we act as processor): contact details of leads and buyers, communication history, apartment search requests, price calculations, contracts, payment schedules, user accounts and their activity log. The customer decides what data is kept.
4. Data from Meta platforms: Facebook, Instagram, Messenger and WhatsApp
A customer can connect their own Facebook Pages, Instagram professional accounts and WhatsApp Business phone numbers to their Properly system. Properly then receives data through Meta’s official APIs — only from the Pages, accounts and numbers the customer has connected.
| Source | Data | Purpose |
|---|---|---|
| Connection via Facebook Login for Business | ID and name of the Facebook user who connects; the Pages, business portfolios and Instagram accounts they grant access to; access tokens | connect the selected Pages and accounts to the customer’s system |
| Lead Ads (lead forms in Facebook and Instagram ads) | name, phone number, email and answers to other form questions; form, ad, campaign and Page IDs; submission time | create a lead in the customer’s CRM and assign it to a sales manager |
| Messenger and Instagram Direct | page- or account-scoped user ID, name and profile picture (where available), messages, attachments, timestamps | the customer’s sales managers reply from Properly, and the conversation is kept in the buyer’s record |
| WhatsApp Business Platform | phone number, WhatsApp profile name, messages, attachments, delivery statuses, message templates | the same: the conversation with the buyer in one record |
We use this data only to provide our service to the customer who connected it. We do not sell it, do not use it for advertising or profiling, do not share it with other customers, data brokers or any other third parties except our processors listed in section 7, and do not use it to train artificial intelligence models. Data received from Meta is not shared with AI model providers (section 7).
Meta access tokens are stored encrypted. When the customer disconnects the integration, the tokens are deleted and no new data is received. Data already received stays in the customer’s CRM until the customer deletes it, the customer’s copy of the system is deleted, or the person it concerns asks us to delete it. We process this data in line with the Meta Platform Terms and Developer Policies.
5. Why we process data and on what legal basis
| Purpose | Data | Legal basis |
|---|---|---|
| Answer enquiries, show a demo, prepare a contract | contact details, correspondence | steps taken at your request before entering into a contract; legitimate interest for company representatives |
| Conclude and perform contracts with customers, provide support | contact details of customer representatives | our contract with the customer; legitimate interest for its representatives |
| Provide the Properly service | data in the customer’s system | the customer’s instructions under our contract |
| Protect the website and system, prevent abuse | technical data, logs | legitimate interest |
| Comply with the law: accounting, requests from authorities | company details, documents, correspondence | legal obligation |
These legal bases come from the Law of Ukraine “On Personal Data Protection” and, for individuals in the EU, from the EU General Data Protection Regulation (GDPR) where it applies.
6. Where data is stored
Each customer gets a separate copy of the Properly system. Depending on our agreement with the customer, it runs:
- on Hetzner servers in data centres in Germany and Finland (EU);
- on DigitalOcean servers in a data centre in Frankfurt (Germany);
- on the customer’s own server — in that case the customer decides where the data is kept and who can access it.
The properly.digital website is hosted on a Hetzner server in Finland (EU).
7. Who we share data with
We do not sell personal data.
Our processors. They receive data only to the extent their function requires.
| Company | What it does | Where |
|---|---|---|
| Hetzner Online GmbH | servers for customer systems and the website | Germany and Finland, EU |
| DigitalOcean, LLC | servers for some customer systems | USA; data centre in Frankfurt (Germany) |
| OpenAI, L.L.C. | models for artificial intelligence features | USA |
| Anthropic, PBC | models for artificial intelligence features | USA |
AI model providers receive only the data needed for a specific user request. Data received from Meta is not shared with them. Under their commercial API terms, this data is not used to train their models.
Sales partner. Website enquiries are handled by a business development manager of M4U. M4U receives your contact details and correspondence only to answer your enquiry on behalf of Properly.
Services the customer connects. Data is shared at the customer’s choice, within the customer’s own accounts with these services:
- Meta Platforms Ireland Ltd. and Meta Platforms, Inc. — Facebook, Instagram, Messenger, WhatsApp Business Platform;
- Zapier, Inc. — automations the customer sets up;
- Telegram — messages through the customer’s bots;
- Rakuten Viber — Viber for Business;
- IP telephony — Ringostat, Binotel;
- SMS — TurboSMS;
- email — Google Workspace, Microsoft 365 or the customer’s own mail server.
Public authorities receive data only when legally required.
8. Transfers outside Ukraine and the EU
Some of our processors are based in the USA. We transfer data to them under contracts that require protection at least equal to what the law requires. For recipients covered by the GDPR, these contracts include the EU Standard Contractual Clauses, or the recipient is certified under the EU-U.S. Data Privacy Framework.
9. How long we keep data
- Data in a customer’s system is kept while the customer’s system is active. When the customer’s copy of the system is deleted, we delete the data; it is deleted from backups within 30 days.
- Data received from Meta can be deleted earlier: the customer can delete it in their system, and the person it concerns can ask us to delete it — see the Data Deletion page.
- Enquiries to us are kept for up to 3 years after the last contact if no contract is concluded.
- Security logs are kept for up to 90 days.
- Accounting records are kept for the periods required by law.
10. How we protect data
- Encryption in transit (TLS).
- Access tokens for external services are stored encrypted.
- A separate copy of the system for each customer.
- Role-based access and user activity logs.
- Regular backups.
- Our staff access customer systems only for support and security, at the customer’s request or with their consent.
11. Your rights
Under Article 8 of the Law of Ukraine “On Personal Data Protection” and, where it applies, the GDPR, you have the right to:
- know what data about you we process, why, and who receives it;
- get a copy of your data;
- correct inaccurate data;
- have your data deleted;
- restrict or object to processing;
- receive your data in a machine-readable format;
- withdraw consent where processing is based on consent;
- complain to the Ukrainian Parliament Commissioner for Human Rights or to the supervisory authority of the EU country where you live.
To exercise these rights, write to support@properly.digital. We reply within 30 days. If your data is held in a developer’s system, we will pass your request to the developer and help fulfil it. We delete data received through Meta platforms ourselves — see the Data Deletion page.
12. Cookies
The website sets no cookies and uses no analytics or advertising services.
13. Children
Properly is a business service. We do not knowingly collect data of people under 18 for our own purposes. Customers decide what data is kept in their systems.
14. Changes to this policy
We publish each new version on this page with its date. We notify customers in advance about significant changes.
15. Contact
Properly Tech LLC 38 Mytropolyta Vasylia Lypkivskoho St., Building A, Apt. 100, Kyiv 03035, Ukraine support@properly.digital