Legal
Privacy Notice.
Last updated 19th Aug 2026.
Progressa is a live product. An estate agent opens a case when a sale goes agreed, and from then on we hold information about the sale and about the people in it — the vendor, the buyer, and the solicitors on both sides. This notice covers that, and it also covers the waitlist and the research conversations that came before it.
If you are a buyer, a seller or a solicitor: the estate agent is the controller of the case record. We hold it for them and act on their instructions. This notice tells you what we do with it, and everything here applies to you.
Who holds it
True Home Properties Limited, 77 Camden Street Lower, Saint Kevin's, Dublin, D02 XE80, company number 811518. Write to hello@progressa.ie and you will reach a person, not a queue.
Two different roles, and the difference matters. For the waitlist and the research conversations we are the controller — our own decision, our own purpose. For everything inside a case we are a processor: the estate agency decides what to record and why, and we act on their instructions. If you want a case record changed or deleted, the agency is the right first stop, and the Data Processing Agreement is the contract that governs it.
What a case holds
- the property address and any Eircode
- the names and email addresses of the vendor, the buyer, and the solicitors on each side — and, on an apartment, the managing agent
- every milestone and its dates: what has happened, when it was recorded, and by whom
- every email we sent on the agent’s behalf, who it went to, and whether it was delivered
- replies: a solicitor’s tap on a status button, and the text of any written reply that comes back to us
- when a link we sent was opened — the count and the time, per person. The agent sees this as “has viewed”. There is no tracking pixel and no open-tracking in the email itself; this records only the loading of a page you clicked through to.
We do not hold the contract, the title documents, the deposit, or anything about anyone ’s finances beyond the fact that a milestone such as “loan offer issued” has or has not happened. There is no payment processing on a case: the agency pays us, and no party to a sale is ever charged.
Where we got your details
From the estate agency, not from you. When the agency opens a case it enters the property, the vendor, the buyer and the solicitors on each side from its own sale file. We do not buy contact details, we do not look them up, and nobody has to register with us for us to hold their name — which is why the first email you get from us may be the first you have heard of us.
A vendor or a buyer can correct their own details, and their solicitor’s, from the link in their welcome email. Anyone else can reply to any message from us and we will pass the correction to the agency, who decides what the record says.
How the AI reading works, and what it sees
When a solicitor replies to one of our emails in their own words, we send those words to Anthropic to be read, and a suggested status comes back — “this reads as still waiting”. Up to about 6,000 characters of the reply go with it. The reply may include whatever the solicitor chose to write, so it may include information about the sale that nobody planned to send us.
Three things are true of that, and we would rather state all three than the flattering one:
- The suggestion never changes anything on its own. It is marked unconfirmed and it waits for the agent to accept or reject it. Nothing is recorded, and no email goes out, on the strength of a machine reading.
- Anthropic does not train on it. They process it to answer the request and for their own limited abuse-monitoring retention, under their commercial terms.
- It is a transfer to the United States, covered by the standard contractual clauses in their data processing addendum.
A solicitor who would rather not have their words read this way can answer by tapping one of the buttons instead — those never go to Anthropic — or can tell the agent, who can turn the automatic reading off for their account.
If you joined the waitlist
We record:
- the email address and the agency or branch name you entered
- when you signed up, and when you confirmed
- the exact sentence shown beside the button you pressed, word for word
- your IP address and browser user agent
- the page that referred you here, if any
We use it to tell you when Progressa opens, and for nothing else. No other list, no partners, no advertising. The lawful basis is your consent, given by confirming the link we emailed you. That is also why we store that sentence verbatim: if you ever ask what you agreed to, we can show you the words themselves rather than a description of them.
The IP address and user agent are kept so we can show a signup was genuine and limit abuse of the form. Every email we send carries an unsubscribe link, and unsubscribing is enough, and you do not need to explain yourself.
If you asked for a demo
The form on the homepage takes your work email, your agency or branch name, and a phone number if you choose to give one. What you enter arrives as a single email in our own mailbox, together with a log entry recording that it was sent, and we use it to arrange the demo and for nothing else. You are not added to any list.
The lawful basis is that you asked us to contact you. Your IP address and browser user agent are checked at submission time to limit abuse of the form. If you change your mind, say so in any reply and the thread ends there.
If you spoke to us as part of our research
We are talking to estate agents about how sale-agreed work actually gets done. If you took part, we may hold notes covering your name, your agency and role, how you work today, and what you told us would or would not be useful. The basis is your consent, and you can withdraw it afterwards. Tell us and we will delete the notes.
If we ever want to record or transcribe a call, we will ask first, at the time, and name the tool we would use. We will not record without you saying yes.
Nothing you tell us is published in a way that identifies you or your agency without asking you first, separately, for that specific thing.
One request in the other direction: please do not show us real client or transaction data during a conversation. We do not need it to understand the problem, and we would rather not hold it. If it comes up on a shared screen we will not record it or write it down.
Who else touches it
Six sub-processors, each acting only on our instructions. The Data Processing Agreement carries the same list as its annex, and we will tell an agency before we add to it.
| Who | What they do | Where | Transfer cover |
|---|---|---|---|
| Neon | Hosts the database — every case record. | London, United Kingdom | UK adequacy decision, renewed 19 Dec 2025 |
| Vercel | Hosts the site and the product. Our code runs in Dublin. | United States (company); Dublin (execution) | Standard contractual clauses |
| Resend | Sends and receives the email, and holds it in its logs. | United States | Standard contractual clauses |
| Anthropic | Reads written replies and suggests a status. See above. | United States | Standard contractual clauses |
| Stripe | Takes the agency’s card payment. No party to a sale is ever charged, so no buyer’s or seller’s data reaches Stripe. | United States | Standard contractual clauses |
| Sentry | Receives error reports. Email addresses and link tokens are removed before they leave us; a case id and a count survive. | Germany (EU region) | Within the EEA |
A correction to an earlier version of this page. It said Resend was “in Ireland”. Resend’s routing region is EU; its account and log data is stored in the United States. The earlier wording was wrong and it is the kind of wrong that matters in a privacy notice, so it is named here rather than quietly edited.
What we do not do
- We do not sell or rent your data, to anyone, ever.
- We do not add you to any list other than the one you asked for.
- We do not build a profile of you or track you across other sites.
- We set no cookies on the marketing site, and only strictly necessary ones for a signed-in agent. See the Cookie Notice.
- We do not put open-tracking pixels in email, and we never say “read” when we mean “delivered”.
- We run no third-party scripts or general visitor analytics. Opening a page here contacts nobody but us.
How long we keep it
A closed case is kept for six years. That is the point of it. The record is a dated account of what was asked and what was answered, and an estate agent may need it years later — for a client, for the PSRA, or in a dispute about who said what and when. Six years matches the ordinary Irish limitation period for a contract claim and the agent’s own record-keeping duties.
Waitlist details: until you unsubscribe. Research notes: up to twelve months after the research finishes, or until you ask us to delete them.
What we cannot delete, and why
Most things you can have deleted on request. The exception is the case ledger — the dated list of what happened — which is append-only by design. The database itself refuses to change or remove a line; a correction is recorded as a new line saying so, and both stay visible.
That is deliberate, and it is the whole value of the record: an account of events that can be quietly edited afterwards is not evidence of anything. Under Article 17(3)(e) GDPR the right to erasure does not apply where the processing is necessary for the establishment, exercise or defence of legal claims, and that is the ground we rely on for the ledger.
In practice this means we can remove your contact details from a case and stop writing to you at any time, and the dated line saying an update was requested on a particular day stays. If you think that balance is wrong in your case, say so and we will look at it.
Why we are allowed to write to you at all
If you are the vendor or the buyer: the agency instructed us to keep you updated on your own sale. That is their legitimate interest and yours, and every message carries a one-click way to stop.
If you are the vendor’s solicitor: your own client asked the agency to coordinate the sale, and you are on the file. Every message says what it is and carries a way to stop.
If you are the buyer’s solicitor, you are not the agency’s client and there is no consent from anyone that covers you. We rely on legitimate interests — coordinating a transaction you are already a party to. In practice the product prefers to prompt the buyer to ask you, rather than write to you directly, for exactly this reason.
The balancing test for that, in short. Our interest is coordinating a transaction you are already acting on, for a client of ours who is a party to it. Your interest is not being drawn into unbilled work or into correspondence you did not ask for. We weigh those by keeping the ask small and the exit immediate: one message per recipient rather than one per sale, a cooldown of days rather than hours, no automatic escalation, nothing that asks you to commit to a date, and an opt-out that stops every sale you have with that agency at once. We think that is proportionate. If you disagree, the opt-out is the answer and you do not need to give us a reason. The longer written test is available on request.
Stopping is always enough on its own. You never have to give a reason, and an opt-out applies to every sale you have with that agency, not just the one that annoyed you.
Your rights
You can ask for a copy of what we hold, ask us to correct or delete it, object to what we are doing with it, or withdraw consent. Where we hold it for an agency, we will pass the request to them and help them answer it. Email hello@progressa.ie. We will act within one month and normally much sooner, because the volumes involved are small.
If you are unhappy with how we have handled it, you can complain to the Data Protection Commission, whose contact details are at dataprotection.ie. You can do that without coming to us first, though we would rather have the chance to put it right.