Last updated: 23 October 2026. This policy explains how we process the data of visitors to the Laverna Real Estate website and mobile app, and of people who contact us about buying, selling, renting or managing property in Spain. The mobile app uses the same website and its online services, so the processing described below also applies to them.
Who is responsible for the data
The personal data controller is Alexandrov Dmitry, operating under the Laverna Real Estate brand. Postal address for enquiries: Av. Gabriel Miró, 9, 03710 Calpe, Alicante, España. Email: hello@lavernarealestate.com.
What data we use and why
When you contact us yourself through the website, email, WhatsApp, Telegram, Instagram Direct or Facebook Messenger, we may receive your name or profile name, contact details, message content, information about the property of interest and our communication history. We use these to respond, clarify your request, suggest suitable options and discuss a possible transaction or service. If an official channel is connected to the CRM, messages and identifiers from the relevant platform may be stored in a private CRM accessible to authorised staff. When you voluntarily request a viewing from a property listing, we store the contact details you provide, the property's REF, the purpose of your enquiry and your preferences in a private CRM so that we can respond and agree the next step. Following a messenger link does not automatically give us your conversations: we receive a message only when you send it.
The AI chat sends OpenAI your question, up to eight previous messages and, when discussing a property, available catalogue information. These data are used to prepare a reply and check the safety of the incoming context and response. The chat is identified as AI and does not replace a person, an independent lawyer or another professional. The checks do not guarantee that all errors will be absent. Recognisable email addresses and phone numbers are restricted or masked, but this is not a complete personal data check. Do not send passports, payment details, medical data or other sensitive information. The form for submitting title documents remains closed until secure file submission and checking are launched separately.
When you visit the website, Beget hosting and WordPress security tools may process technical data, including your IP address, request time, page address and browser information, needed to operate the website, prevent abuse and diagnose errors. Favourites, viewed properties and saved searches are stored in your browser and can be deleted through the website interface or browser settings.
Legal bases for processing
We respond to your enquiries and prepare proposals at your request; where this involves discussing a contract, the basis may be steps taken at your request before entering into it. Website protection, spam prevention and maintaining a history of business communications are based on our legitimate interest, taking your rights into account. Where separate consent is required, for example for optional analytics, advertising cookies or marketing messages, we request it separately. Refusing advertising consent does not prevent you from making a property enquiry.
Who can access the data
Access is limited to people who need the information to respond and handle the enquiry. Beget (hosting), OpenAI (AI chat responses), Meta (WhatsApp, Instagram, Facebook) and Telegram may be used to operate the website and communicate, depending on the channel you choose. These platforms have their own privacy policies. When preparing a specific transaction, data may be shared with an engaged professional only to the extent necessary and with the client informed. International data transfers may occur when using these services; information about the applicable mechanisms and specific recipients can be requested by emailing us.
Cookies and browser data
Necessary technical cookies help the website function and stay secure. Optional analytics and advertising tools must only be enabled after your choice in the cookie settings panel, if such tools are installed. You can also change or withdraw your choice there. Simply visiting the website does not disclose your name, phone number, email address or social media profile to us.
If you consent to analytics, Google Analytics 4 (Google) is used: a browser or device identifier, website interactions, viewed pages, technical device information and approximate location may be processed. Advertising personalisation is disabled in the current GA4 configuration. GA4 retention settings: event data — 2 months; user data — 14 months; the period for a user identifier may reset with new activity. This is not the retention period for all Google technical logs. Your website cookie choice is retained for up to 180 days unless you change or delete it earlier.
The website also has Jetpack Social (Automattic) installed for social features. WordPress components and connected services may receive technical request information. You can ask us for precise information about processors and data transfers; the existence of analytics settings does not mean that all technical requests are analytics-related.
Retention periods
We retain enquiries and their handling history for as long as necessary to respond, discuss a service and a possible contract; afterwards, only within the scope of applicable legal obligations or the period for defending lawful claims. The exact period depends on the nature of the enquiry and the obligations arising. Favourites and saved searches remain until you delete them or clear browser data. The content and retention periods of hosting technical logs and backups depend on the relevant service; you can request information by emailing us. Clearing the chat does not delete separate requests, messenger conversations or transaction documents.
AI chat storage and clearing
Up to 24 messages are stored on the device. A new history is assigned a fixed expiry after 30 days, without extension for each new message. For a history created before this update, the period is calculated from the saved last-updated date. Expired history is cleared the next time the page loads or a check runs in the open app. If the website or app is closed, its code cannot perform the clearing at that moment; you can delete browser or app data yourself.
An unfinished request may be temporarily saved in the tab's storage to recover from a connection failure; the app stops using it after 25 minutes and deletes it at the next check. On the website server, the technical task and response cache has a lifetime of up to 30 minutes. After receiving the response, the browser requests deletion of this cache; the clear button also sends such a request. Cache expiry is not a promise of immediate physical deletion from backups.
The general chat creates a separate OpenAI session for a new enquiry. Once processing is complete, the website requests deletion of that session through the API. If there is an error or execution is unfinished, a background task retries the request; execution depends on the scheduler operating and service availability. A minimal technical record with service identifiers is retained until clearing and cache deletion are confirmed; it does not contain the conversation text. Property-specific responses use Responses requests with the parameter store:false. This parameter does not mean that the provider performs no processing or keeps no security logs.
The ‘Clear’ button deletes the history on the current device and requests clearing of the available server cache for new enquiries. Without a network connection, the request may be carried out later; do not close the app before the connection is restored if you are waiting for the request to be sent. A technical deletion identifier, without chat text, may be temporarily stored on the device for a retry. Clearing one device does not clear other devices. Nor does it trigger bulk deletion of old OpenAI sessions created before this feature was implemented: you can contact us separately about those.
Deleting a session through the API does not guarantee immediate physical deletion of all copies held by OpenAI. The provider's rules apply to security logs, backups and specified exceptions. The Agents API is not a Zero Data Retention mode; its state may be processed in the USA. Learn more: OpenAI's data processing and retention rules. Do not enter sensitive data in the chat; to request access or deletion, use the contact below and provide the approximate date, device and nature of the enquiry, without resending sensitive text.
Mobile app data on the device
The mobile app additionally stores a local selection: property REFs, city, type, price and saved-search parameters. This copy is needed to view saved information without internet access and is not, by itself, sent to the CRM. Photos and current online data require a connection. The web section's data and the native offline selection may be stored separately. Clearing the AI chat does not delete the offline selection; to remove it completely, use the app data deletion settings or uninstall the app using the device's tools. To delete enquiries stored on the server, send us a separate request. System backups of the device are managed by its owner and platform provider.
Your rights
You may request access to your data, rectification or deletion, restriction of processing, object to processing and, where provided by law, receive data for portability. You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal. Email hello@lavernarealestate.com; specify the channel and approximate enquiry date so that we can find the record. Do not send an identity document by ordinary email without agreeing a secure verification method. You may also lodge a complaint with the Spanish Data Protection Agency (AEPD).