Privacy Policy

This policy explains how First Reply Agent collects and uses personal data, in line with the EU General Data Protection Regulation (GDPR) and Spanish Organic Law 3/2018 (LOPDGDD).

1. Who is responsible for your data

2. What data we collect

• When you contact us by WhatsApp, email or phone: your name, phone number, email address, agency name, and the content of your messages.
• When your agency runs a pilot or becomes a client: business contact details, billing information and the details needed to set up the service.
• When you visit this website: technical data such as your IP address, browser type and the pages requested, which our hosting provider records in standard server logs. This website has no contact forms and does not use analytics or advertising tracking.

3. Why we use it, and on what legal basis

Answering your enquiry and arranging a pilot	Steps taken at your request before entering into a contract (Art. 6.1.b GDPR)
Providing the service to client agencies	Performance of a contract (Art. 6.1.b GDPR)
Invoicing, accounting and tax	Legal obligation (Art. 6.1.c GDPR)
Following up on a business conversation you started, and keeping the website secure	Our legitimate interest (Art. 6.1.f GDPR)

We do not sell your data, and we do not make decisions about website visitors based solely on automated processing.

4. How long we keep it

We keep enquiry data for as long as needed to deal with your request and any follow-up, and for no longer than 2 years after our last contact if no business relationship results. Client and billing data are kept for the duration of the relationship and then for the periods required by law (for example, 6 years for accounting records under Spanish law). Server logs are kept for a short period by our hosting provider.

5. Who we share it with

We only share data with service providers that help us run the business, under contracts that require them to protect it:

• our website hosting provider;
• Google (Google Fonts), which receives your IP address when this website loads its fonts;
• Meta Platforms (WhatsApp), if you contact us on WhatsApp;
• our email provider, if you contact us by email;
• our accountant or tax advisor, for invoicing and tax purposes.

Some of these providers may process data outside the European Economic Area, for example in the United States. Where that happens, the transfer is protected by an adequacy decision (such as the EU–US Data Privacy Framework) or by the European Commission’s Standard Contractual Clauses.

6. Data we process for client agencies

When an agency uses our service, Valentina handles enquiries from that agency’s buyers and sellers. For that data, the agency is the data controller and First Reply Agent acts as a data processor on its behalf, under a data processing agreement and the agency’s own privacy policy. Valentina always identifies herself as an AI assistant at the start of a conversation.

7. Your rights

You can ask to access, correct or delete your personal data, to restrict or object to its processing, and to receive it in a portable format. Where processing is based on consent, you can withdraw consent at any time. To exercise these rights, email cris@firstreplyagent.com — we will reply within one month.

If you believe your data has not been handled correctly, you can complain to the Spanish Data Protection Agency (AEPD) at www.aepd.es.

8. Security

We use reasonable technical and organisational measures to protect personal data against loss, misuse and unauthorised access.

9. Changes to this policy

We may update this policy from time to time. The latest version will always be on this page, with the date it was last updated.