Privacy notice
How Relay handles personal data
Effective August 22, 2026 · Relay is a product of Crestatech Solutions · Terms of service
Relay is a client operating system for real-estate brokerages in the Philippines. It processes personal data of the people who use it (agents, managers, owners) and of the buyers those teams talk to. This notice explains what we collect, why, who sees it, how long we keep it, and how to exercise your rights under the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).
Consent records inside Relay reference this notice by version. The current version is 2026-08-21.
1.Who we are and how to reach us
Relay is developed and operated by Crestatech Solutions (“Crestatech”, “we”, “us”). For any question about this notice, to exercise a data-subject right, or to reach our data protection contact, email info@creatatech.io. We answer privacy requests within fifteen (15) business days and tell you sooner if we need more time.
2.The two roles we play
Which role we play decides who you should contact first and who is responsible for what.
When a brokerage uses Relay with its buyers
The brokerage (the organization that created the workspace) decides why and how buyer data is processed. It is the personal information controller. Crestatech processes that data on the brokerage’s instructions as a personal information processor, under the Terms of service and the data-processing terms they contain. If you are a buyer and want to access, correct or delete what a brokerage holds about you, contact that brokerage first; we help them respond, and you can always also write to us.
When you use Relay as a team member or visit this website
For your account, workspace membership, support requests and our own service operations (security logs, billing, product analytics limited to what is described below) Crestatech is the controller.
3.What we collect
Account and workspace data
- Name, email address, password hash (held by our authentication provider), and optional profile details such as a PRC licence number and practitioner type that a brokerage records to model its team structure.
- Organization name, team membership, role, invitations and assignment rules.
- Sign-in events, session cookies and the organization you last worked in.
Buyer data processed on behalf of brokerages
- Messages sent to the brokerage’s Facebook Page, Instagram professional account or WhatsApp Business number, together with the sender id Meta assigns, the display name Meta provides, timestamps and attachments. Agents’ replies and assistant drafts are stored in the same thread.
- Contact details an agent records or a buyer shares: name, phone, email, preferred channel.
- Qualification details needed to help someone buy a home: property or project of interest, location, budget band, purchase timeline, cash/bank financing preference, site-viewing readiness and the agreed next action.
- Consent records: purpose, status, channel, source, the version of this notice, who recorded it and when — including withdrawals.
- Documents uploaded for a reservation or home-loan checklist — government-issued IDs, proof of billing, payslips, certificates of employment, income-tax returns, bank statements, reservation and financing forms — plus the text extracted from them and the document type we classify them as.
- Activity: appointments, site viewings, tasks, notes, stage changes, bank-referral status and every assistant action, each timestamped and attributed to a user, a system or a source.
Technical data
- Structured server logs that contain request, job and record identifiers, sizes and timings — never message bodies, documents or secrets.
- Webhook events received from Meta, stored immutably so a delivery can be replayed and audited.
We do not collect special categories of data on purpose. If a buyer volunteers sensitive information in a message (for example health or family circumstances), it stays in that thread and is never extracted into a profile field or used in any signal.
4.Where the data comes from
- Meta’s official business APIs. Relay receives messages through the Messenger Platform, Instagram Messaging API and WhatsApp Cloud API only after a Page or WhatsApp administrator connects that asset and grants the permissions Meta requires. We never read personal Messenger inboxes, never scrape Facebook profiles, groups or friend lists, and never collect data Meta has not sent to the connected business asset.
- The brokerage team — what agents type into a contact, a note, a task or a checklist.
- Buyers themselves — through the conversation, and through documents or forms they provide for a reservation or loan.
5.Why we process it and on what basis
| Purpose | Lawful basis (RA 10173 §12–13) |
|---|---|
| Receiving and answering a buyer’s inquiry on the channel they chose | Necessary for steps at the buyer’s request before entering a contract; the brokerage’s legitimate interest in answering people who contacted it |
| Qualification, property matching, site viewings and transaction processing | Contract with the buyer (reservation, sale) and pre-contractual steps; consent recorded as transaction processing |
| Collecting and checking reservation or loan documents | Consent recorded as document collection; contract; legal obligations of the developer or bank that the brokerage serves |
| Referring a buyer to a preferred bank | Explicit consent recorded as bank referral — the referral does not start without it |
| Follow-ups and marketing messages outside an active transaction | Consent recorded as marketing messages, withdrawable at any time; Meta’s and WhatsApp’s messaging policies apply on top |
| Running accounts, workspaces, security, audit trails and support | Contract with the brokerage; our legitimate interest in operating a secure service; legal obligations |
Consent is never a single checkbox. Each purpose has its own record with the channel it was given on, the source (for example a Messenger opt-in or an agent recording it), the version of this notice, and a full history of withdrawals — append-only, so it can be audited.
6.AI features
Relay can draft a follow-up before Meta’s 24-hour customer-service window closes, summarise a thread, and suggest a next action. To do that it sends the minimum necessary context — the recent conversation, the recorded qualification details and the brokerage’s instructions — to an AI model provider listed under Who we share data with. We do not send documents, identifiers such as phone numbers or sender ids, or secrets to model providers, and we do not allow providers to train on this data.
Drafts are gated by deterministic rules (no prices, discounts, availability or financing claims the system cannot source) and are shown to a team member, or sent by the assistant only where the brokerage has explicitly enabled that and the assistant identifies itself as automated. Every assistant action is written to the timeline. Nothing is decided about a person by AI alone.
7.Buyer readiness signals — no automated decisions
To help a team prioritise its day, Relay shows three separate, explainable indicators: whether contact details are verified, how ready to buy someone has said they are (declared budget, timeline, financing, viewings booked, documents received), and how engaged the conversation is. Each indicator lists the reasons behind it.
- There is no composite score, and nothing is inferred from race, ethnicity, religion, political views, health, family status, appearance, social connections, neighbourhood or any “wealth from profile” technique.
- Signals are visible to the brokerage team only, can be overridden by a human, and are never used to automatically refuse service or deprioritise a person.
- Buyers may object to this processing (see Your rights); the brokerage must honour the objection.
9.How we protect it
- Encryption in transit (TLS) and at rest; channel access tokens are additionally encrypted at the application layer with AES-256-GCM.
- Every database table is protected by row-level security scoped to the brokerage, on top of application-level authorization and role checks (owner, admin, manager, agent). Agents see documents only for the buyers they work with.
- Documents live in a private bucket with no public access; files move only through short-lived signed links minted after an authorization check, and are parsed in an isolated sandbox that never holds database credentials. Files with active content are rejected before extraction.
- Webhook payloads are verified with a signature before anything is stored. Secrets never reach the browser, logs or AI prompts.
- Audit trails — activity timeline, job events, webhook events and consent records — are append-only for application users.
No system is perfectly secure. Report a vulnerability or a suspected incident to info@creatatech.io; we treat reports as confidential.
10.How long we keep it
- Buyer data, conversations and documents are kept while the brokerage’s workspace is active and for as long as that brokerage instructs, subject to its own legal retention duties (for example for consummated sales). Deleted records are first soft-deleted so a mistake can be reversed, then purged.
- Account data is kept while the account exists and deleted or anonymised within thirty (30) days of closure, except where we must keep a minimal record to meet a legal obligation or resolve a dispute.
- Server logs and webhook events are kept for a limited operational period for security and troubleshooting.
11.Your rights and how to exercise them
Under the Data Privacy Act you have the right to:
- be informed that your personal data is being processed, and about this notice;
- access the personal data held about you and learn where it came from and who it was shared with;
- object to processing, including for direct marketing and to the readiness signals described above, and to withdraw consent for any purpose at any time;
- have inaccurate data rectified;
- have data erased or blocked where it is incomplete, outdated, unlawfully obtained or no longer necessary;
- obtain a copy of your data in a portable format (data portability);
- be indemnified for damages caused by inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorised use of personal data; and
- lodge a complaint with the National Privacy Commission (privacy.gov.ph).
If you are a buyer, write to the brokerage you spoke with — they control your data — or email info@creatatech.io and we will route the request and help them answer. If you are a team member, email us directly. We will verify your identity before acting on a request, and we will not charge for a reasonable request.
12.Deleting your data
You can ask for the personal data Relay holds about you to be deleted, including anything that reached us through Facebook, Instagram or WhatsApp. This section also serves as the data-deletion instructions required by Meta’s platform terms.
- Email info@creatatech.io with the subject “Data deletion request”. Tell us the name of the brokerage you messaged (the Page, Instagram account or WhatsApp number), and the name, phone number or email you used, so we can find the right record.
- We confirm receipt within three (3) business days and verify that you are the person the data is about.
- We delete or anonymise the contact record, conversations, consent history and documents attributed to you within thirty (30) days, and confirm by email. Where the brokerage is legally required to keep part of a record (for example a completed sale), we tell you what is kept and why.
A brokerage can also delete a buyer’s record from inside Relay. Disconnecting a Page or WhatsApp number stops all further data from flowing; it does not by itself delete what was already received — ask for that explicitly.
14.Children
Relay is a business tool for real-estate professionals and is not directed at anyone under eighteen (18). If you believe a minor’s data has reached us, tell us at info@creatatech.io and we will remove it.
15.If something goes wrong
If a personal-data breach is likely to cause serious harm, we notify the National Privacy Commission and the affected brokerage within seventy-two (72) hours of knowing about it, as NPC rules require, and help the brokerage notify affected individuals. We keep an internal record of every security incident, including those that did not require notification.
16.Changes to this notice
When we change this notice materially we update the effective date and the version stamped on new consent records, tell brokerages in the product, and — where a change affects how buyer data is used — ask brokerages to refresh the consent they have collected. Earlier versions are available on request.
17.Contact
Crestatech Solutions · info@creatatech.io · Data-subject requests, privacy questions, security reports and requests from the National Privacy Commission all reach the same address.