Privacy Policy
This Privacy Policy describes how Dataray SAS (“menosvueltas,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information when you use menosvueltas.com and related services (the “Service”). The Service is a software-as-a-service platform for real-estate professionals to organize property searches, collaborate with clients, contact listing publishers, and communicate via integrated messaging tools.
1. Introduction
For purposes of applicable data protection laws, Dataray SAS is the data controller responsible for personal information processed through the Service, except where we process data solely on behalf of a customer (for example, certain messaging data handled as described in Section 4).
Our registered address is Montevideo, Uruguay. If you have questions about this policy or our privacy practices, contact us at pavel@menosvueltas.com. Where required by law, you may also contact our data protection contact at Pavel Poddubnyi.
By using the Service, you acknowledge that you have read this Privacy Policy. If you do not agree, please do not use the Service.
2. Information we collect
We collect information in the following categories, depending on how you use the Service:
Account and authentication data. When you register, we collect your email address and credentials needed to authenticate you (such as a password hash and session tokens). We store your account email and related authentication data to operate your account.
Property and listing data. The Service helps agents capture and organize publicly available real-estate listings from third-party portals (for example, Mercado Libre or InfoCasas) using a browser extension. We store listing details you save, your notes, workflow status, search/pipeline organization, and related metadata you add in the Service.
Collaboration data. An account owner may invite a client or collaborator (viewer) to a search by email. We process invitee email addresses, optional display names set by collaborators, reactions (such as like/dislike), and comments they submit on shared searches.
Contacts and messaging data. The Service helps agents contact listing publishers or realtors. If you connect WhatsApp Business (see Section 4), we process phone numbers, contact names, message content, and conversation metadata needed to send and receive messages and sync threads on your behalf.
AI-processed activity. To power the AI assistant, we process activity such as new listings, listing changes, client reactions and comments, and your replies. This activity may be included in context sent to our AI inference provider to generate summaries, suggested next steps, and draft messages.
Usage and technical data. We may collect information about how you access and use the Service (for example, device/browser type, IP address, timestamps, and error logs) to operate, secure, and improve the Service.
Cookies and similar technologies. We use session cookies and similar technologies for authentication and to keep you signed in. See Section 13.
We do not intentionally collect special categories of personal data unless you choose to include such information in free-text fields (for example, in notes or messages).
3. How we use information
We use personal information to:
- Provide, maintain, and operate the Service, including account registration and login;
- Store and organize property searches, listings, notes, and workflow status;
- Enable collaboration features, including shared searches, invites, reactions, and comments;
- Facilitate outreach to listing contacts, including sending and receiving messages through the WhatsApp Business Platform when you connect your account;
- Power AI assistant features such as summaries, suggested next steps, and draft content based on relevant activity in your workspace;
- Protect the security and integrity of the Service, troubleshoot issues, and prevent abuse;
- Comply with applicable law, enforce our terms, and respond to lawful requests.
We process information where necessary to perform our contract with you, based on our legitimate interests in operating and improving a professional B2B service (balanced against your rights), and where required to comply with legal obligations. Where consent is required by law (for example, for certain optional integrations), we will seek it separately.
4. WhatsApp Business Platform / Meta data
menosvueltas integrates with the WhatsApp Business Platform (provided by Meta Platforms, Inc. and affiliates) so that agents can connect their own WhatsApp Business account and use messaging features within the Service.
What WhatsApp-related data we process. When you enable this integration, we may process:
- Phone numbers and contact names associated with your conversations;
- Message content (text and related metadata) that you send or receive through the connected account;
- Conversation identifiers and timestamps needed to display and sync threads in the Service;
- Technical credentials (such as access tokens) required to maintain the connection, stored using encryption as described in Section 10.
Our role. For WhatsApp messaging, we act as a tool and processor on your behalf: messages are sent and received using your connected WhatsApp Business account. You are responsible for your outreach, the accuracy of contact information you use, and obtaining any consents or providing any notices required under applicable law before messaging your contacts.
Meta terms and permitted use. Your use of WhatsApp features is also subject to Meta’s Platform Terms, Developer Policies, and applicable WhatsApp Business terms. We use WhatsApp-related data only to provide messaging functionality in the Service—for example, to display threads, send messages you initiate, and sync conversation history. We do not sell WhatsApp-related personal data, and we do not use it for advertising or unrelated profiling.
You may disconnect WhatsApp at any time through the Service settings (where available) or by contacting us. Disconnecting stops new processing via the integration, subject to retention described in Sections 7 and 8.
5. AI processing & third-party AI provider
The Service includes an AI assistant that processes workspace activity—such as new listings, listing changes, client reactions and comments, and your replies—to produce summaries, suggested next steps, and draft content.
AI inference is performed using a third-party AI provider (for example, via OpenRouter, which may route requests to a large-language-model provider). Relevant context from your workspace is transmitted to that provider only to generate responses for you within the Service. The provider acts as a subprocessor under our instructions.
We do not use your content to train our own public models for unrelated purposes. Third-party providers may process data according to their own terms and technical configurations; we do not authorize providers to use your data to train their models beyond what their applicable terms and settings allow. Specific provider names and subprocessors may be listed at available on request.
You should avoid submitting sensitive personal data in prompts or notes unless necessary for your business purpose.
7. Data retention
We retain personal information for as long as needed to provide the Service, fulfill the purposes described in this policy, and comply with legal obligations. Retention periods may vary by data type and your use of features (for example, active searches, messaging history, or AI-generated outputs).
Unless a different period is required by law or specified in your agreement with us, we apply the following general approach: 1 year. When data is no longer needed, we delete or anonymize it in accordance with our internal procedures, subject to backup and legal hold requirements.
8. Data deletion
You may request deletion of your personal information as follows:
- Account deletion: If available in the Service, use in-product account settings to delete your account. Otherwise, email pavel@menosvueltas.com from the address associated with your account with the subject line “Account deletion request” and sufficient information for us to verify your identity.
- Other deletion requests: Email pavel@menosvueltas.com describing the data you want deleted (for example, a specific search, collaborator invite, or messaging connection). We may ask you to verify your identity before processing the request.
When you delete your account, we will delete or anonymize associated personal data in our active systems, including account profile data, searches and listing content you created, collaboration data tied to your account, messaging integration data, and AI-related workspace content, subject to:
- Data we must retain to comply with law, resolve disputes, enforce agreements, or maintain security logs;
- Information stored in encrypted backups for a limited period before automatic purging;
- Data processed on behalf of another user (for example, comments on a search owned by another agent) that remains necessary for that user’s legitimate use of the Service.
We will respond to verified requests within a reasonable timeframe and in accordance with applicable law. If you connected WhatsApp, disconnecting the integration and deleting your account stops our further use of WhatsApp credentials and associated thread data in the Service, as described above.
9. Your rights
Depending on your location, you may have rights regarding your personal information, such as:
- Access — request a copy of personal information we hold about you;
- Correction — request correction of inaccurate information;
- Deletion — request deletion as described in Section 8;
- Restriction or objection — object to or ask us to limit certain processing;
- Portability — receive certain data in a structured, commonly used format where applicable;
- Withdraw consent — where processing is based on consent, withdraw it without affecting prior lawful processing.
To exercise these rights, contact pavel@menosvueltas.com. We may need to verify your identity. You may also lodge a complaint with a supervisory authority in your country of residence.
This policy is governed by the laws of Uruguay, without regard to conflict-of-law principles, except where mandatory local consumer or data protection rules provide otherwise.
10. Security
We implement administrative, technical, and organizational measures designed to protect personal information, including access controls and database row-level security appropriate to a multi-tenant SaaS environment. Sensitive third-party tokens (such as WhatsApp Business access tokens) are stored using encryption.
No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we work to maintain safeguards consistent with the nature of the data and risk.
11. International data transfers
We and our subprocessors may process and store information in countries other than where you are located, including countries that may not provide the same level of data protection as your jurisdiction. Where required, we use appropriate safeguards such as standard contractual clauses or equivalent mechanisms. Details are available on request at pavel@menosvueltas.com.
12. Children’s privacy
The Service is intended for real-estate professionals and business users. It is not directed to children under 16 (or the age defined by applicable law in your region), and we do not knowingly collect personal information from children. If you believe we have collected information from a child, contact us and we will take appropriate steps to delete it.
14. Changes to this policy
We may update this Privacy Policy from time to time. We will post the revised policy on this page and update the “Last updated” date. If changes are material, we may provide additional notice (for example, by email or in-product notice) where required by law. Continued use of the Service after the effective date of an update constitutes acceptance of the revised policy, to the extent permitted by law.
15. Contact us
If you have questions, requests, or complaints about this Privacy Policy or our data practices, contact:
Dataray SAS
Montevideo, Uruguay
Email: pavel@menosvueltas.com
Data protection contact (if applicable): Pavel Poddubnyi