Privacy Policy

2.1 Account Data (GDPR Art. 6(1)(b) - Contract Performance)

• Email address
• Name (first and last)
• Authentication method (bcrypt password hash, or your Google account ID if you use Sign in with Google)
• Account creation date

2.2 Profile Data (GDPR Art. 6(1)(b))

• City and country (for regional context)
• Investment preferences (property types, budget ranges)
• Property search criteria
• Phone number (optional, only if provided)

2.3 Usage Data (GDPR Art. 6(1)(f) - Legitimate Interest)

• IP address (anonymized after 7 days)
• Browser type and version
• Device information
• Pages visited and time spent
• Search queries and report generation history
• Login timestamps and session data

2.4 Payment Data (GDPR Art. 6(1)(b))

• Transaction IDs and payment status (via Stripe)
• Billing address (if provided)
• Note: We do NOT store credit card numbers - Stripe handles all card data

2.5 Communication Data (GDPR Art. 6(1)(a) - Consent)

• Email communications (if opted in)
• Newsletter preferences
• Support ticket content

2.6 Buyer Profile Data (GDPR Art. 6(1)(a) - Consent)

When generating property reports, you may optionally provide:

• Purchase purpose (primary residence, investment, holiday home)
• Buying timeline
• Nationality
• Risk tolerance
• Intended property use
• Annual income range

All buyer profile fields are optional with "Prefer not to say" options. This data is used for analytics and may be shared in anonymized, aggregated form with partner agencies (see B2B Services below).

Partner Network

We connect users with verified Italian property professionals including:

• Licensed real estate agents (agenti immobiliari)
• Property lawyers (avvocati)
• Mortgage brokers and finance partners
• Surveyors and architects (geometri, architetti)

Consent-Based Referrals

If you opt-in to partner referrals, we may share:

• Your name and contact information
• Property search preferences and budget range
• Regions of interest
• Buying timeline

You can withdraw consent at any time via your Account Settings. Partners are contractually bound to use your data solely for the referral purpose and comply with GDPR.

Anonymized Analytics

We provide partners with anonymized, aggregated market insights (e.g., search trends by region, price bracket preferences). This data cannot identify individual users.

What AI is Used For

We use AI systems (OpenAI GPT-4o, Anthropic Claude, Google Gemini and Perplexity AI) to perform automated analysis of property and market data. This includes generating investment scores, rental yield projections, and neighbourhood analysis. This AI processing concerns the property being analysed and market conditions — not individual user profiles or personal characteristics.

No Fully-Automated Legally-Binding Decisions About You

Trovara does not subject users to fully-automated decisions that produce legal or similarly significant effects about them as individuals within the meaning of GDPR Article 22(1). Our AI outputs are:

• Informational property analysis — not decisions about your eligibility for services
• Presented as estimates to assist your human decision-making
• Not used to approve or deny access to financial services, employment, or essential services

Your Right to Request Human Review

If you believe an AI-generated analysis or score in a Trovara report is significantly inaccurate or has caused you harm, you may contact our Data Protection Contact at dpo@trovara.io to request human review of the output. We will respond within one month. For more information, see our AI Transparency Statement.

What data, and where it comes from

When a report is generated, or when the buyer confirms the property's cadastral reference, we retrieve the cadastral record of that property — and only that property — from the Catasto kept by the Agenzia delle Entrate, through the licensed provider Openapi S.p.A. (OpenAPI.it). The Catasto is a publicly accessible register. From the record we keep only the registered owner's name (person or company), the type of right (for example full ownership or usufruct) and the ownership share. We do not keep the owner's tax code (codice fiscale), date or place of birth or address, and we do not search the register by person.

Purpose and legal basis

The purpose is to let a prospective buyer compare the registered owners with the seller before signing, and to show whether several owners or split rights (such as usufruct) must be involved in the sale. The legal basis is our legitimate interest and that of the buyer (Art. 6(1)(f) GDPR) in avoiding a purchase from someone who cannot sell the property. We consider that the owners' interests do not override it: the data comes from a publicly accessible register, is limited to name, right and share, concerns only the property the buyer is considering, and is used for no other purpose — in particular not for marketing and not to contact the owners. No automated decision-making within the meaning of Article 22 GDPR concerns the owners.

Recipients and storage

The buyer who ordered the report, and anyone the buyer shares the report or its PDF with. Our hosting provider processes the data on our behalf in the EU (Google Cloud, Netherlands; section 4). Owner names are not passed to the AI models we use (section 4B).

Retention

The owner data is part of the report and is kept for as long as the report is kept (section 5). It is deleted together with the report or with the buyer's account.

Why we do not notify owners individually

Article 14 GDPR would normally require us to inform each owner directly. We rely on the exception in Article 14(5)(b) GDPR: the cadastral record contains no contact details, so informing owners would require us to collect further data about them (such as their home address) solely for that purpose — a disproportionate effort that would itself intrude further into their privacy. As the appropriate measure that provision requires, we make this information publicly available here.

Rights of property owners

If you are a registered owner and your data appears in a Trovara report, you have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17) and restriction of processing (Art. 18), and the right to object at any time, on grounds relating to your particular situation, to this processing based on legitimate interest (Art. 21). Write to privacy@trovara.io, naming the property (comune and, if known, the cadastral reference). We respond within one month (Art. 12(3)). Corrections to the register itself must be requested from the Agenzia delle Entrate. You may also lodge a complaint with a supervisory authority (section 6).

7.1 Google Services Integrated

Trovara integrates the following Google Maps Platform services to provide location intelligence in our property reports:

• Google Maps JavaScript API (interactive property maps)
• Google Places API (nearby amenities, points of interest)
• Google Street View Static API (street-level neighborhood imagery)
• Google Distance Matrix API (travel time and distance calculations)
• Google Solar API (building solar potential analysis)
• Google Air Quality API (local air quality data)
• Google Address Validation API (property address verification)
• Google Geocoding API (address-to-coordinate resolution)

7.2 Data Google May Collect

When you interact with Google Maps features in Trovara, Google may collect certain information including your IP address, device information, and usage data. This data collection is governed by the Google Privacy Policy.

7.3 Your Rights Regarding Google Data

For information about how Google processes your data and your rights with respect to that data, please refer to the Google Privacy Policy and Google Maps/Google Earth Additional Terms of Service.