How we look after your data.

1. Who we are

Agent Delegator (agentdelegator.co.uk) provides coaching and a performance app for UK estate and letting agencies. It is owned by Ruban Thavanesan. You can contact us about privacy at hello@agentdelegator.co.uk.

2. Your agency and us

If you work for an agency that uses Agent Delegator, your agency decides what data is used and why. In data protection terms your agency is the controller and we are its processor: we only use the data on your agency’s instructions and under a written agreement with them.

The one exception is the shared coaching bank (section 6), where we create anonymous tips for all agencies that opt in. For that work we are a controller, and we only do it when your agency’s owner has opted in.

3. What we use

• Your login details: name, work email, role and office. Passwords are handled by our login provider and never stored in plain text.
• Work activity from your agency’s systems, such as its CRM (for example Reapit), phone system (for example Wildix), lead provider and email: counts of calls, leads, viewings, valuations, offers and response times.
• Call transcripts, emails and CRM notes, where your agency has connected them, for coaching and training.
• Questions you ask the AI coach, any screenshot you add, and the answers.
• Messages, feedback and coaching notes you write in the app.
• A record of sign-ins and sign-outs (time and type of device, such as “iPhone · Safari”), the pages of the app you open, and admin actions. This is for security and to support you, and only our super admin can see it.
• If you visit our public website, an anonymous count of visits: the page, the site that sent you, a rough location (town and country) and your type of device. We don’t set cookies for this, don’t store your IP address and can’t tell who you are. We skip it if you turn on “Do not track” or Global Privacy Control, or decline cookies.

Clients’ details (tenants, landlords, buyers, sellers and applicants) are only used as far as a statistic needs them. We never sell data or use it for advertising.

4. Monitoring for training

Agencies using Agent Delegator monitor calls, emails and CRM notes for staff training, coaching and performance monitoring. The aim is to help people improve, not to catch them out. Your agency should tell you this directly, and callers are told by the agency’s phone system or website that calls may be recorded and monitored for training.

Our lawful basis on your agency’s behalf is legitimate interests: helping its team serve clients well and develop their skills. We never use monitoring to make decisions about pay, discipline or employment on our own; any decision is made by a person at your agency.

5. The AI coach

The AI coach answers questions using only the figures you’re allowed to see in the app. It can’t see other agencies’ data, it never sees health or sickness information, and it shows which numbers each answer used. The coach is powered by Anthropic’s Claude. Anthropic processes questions to produce answers and does not use them to train its models.

6. The shared coaching bank

The coaching bank collects short, anonymous tips on approaches that led to a good result, such as a viewing booked or an instruction won, so that agents at every agency in the bank can learn from what works.

• Opt in by the agency owner. Each agency’s owner or director chooses to opt in or out in the app. Until they opt in, nothing from that agency goes into the bank and its AI coach doesn’t use it. They can opt out at any time.
• Anonymous tips only. A tip describes the situation and what worked, for example “offer two set viewing times rather than asking when suits them”. Tips never contain names, addresses, phone numbers, email addresses, prices, dates or times.
• Checked by a person. Some tips are first drafted by AI from the short summary of a high-scoring call. Our team reads every tip before it goes into the bank. We keep the tip only, not the call, email or note it came from.
• No one is told where a tip came from. Agencies, coaches and staff never see which agency a tip came from.

Our lawful basis is legitimate interests: improving coaching for all participating agencies, with safeguards so that no one can be identified from a tip. If you have concerns about a tip, contact us and we will review or remove it.

7. Checking rules on GOV.UK

When the AI coach answers a question about law or regulation, such as deposits, right to rent or safety certificates, it checks GOV.UK only and links the page it used. It doesn’t send your agency’s data to GOV.UK, only a general search. GOV.UK guidance isn’t legal advice for your situation.

8. Cookies and website analytics

The app uses only the cookies it needs to keep you signed in, which don’t need your consent. On our public pages (the home page, the sign-in page and this notice) we ask before using Google Analytics. If you accept, Google Analytics sets cookies (named _ga) for up to 2 years so we can count visits, see which pages are read, the kind of device used and the town or city the visit came from. We don’t use it for advertising, Google signals are switched off, and we never see who you are. If you reject, nothing is set or sent to Google.

We keep your answer in a cookie called ad_consent for a year so we don’t ask again. You can change your mind at any time with “Cookie settings” at the bottom of those pages. Google Analytics keeps its reports for 14 months. Our lawful basis is your consent.

Separately, our own server keeps an anonymous count of visits to those pages without any cookies (see section 3). It stops as soon as you reject cookies.

9. Who else handles data

We use trusted suppliers under contracts that protect your data:

• Supabase: database and logins, hosted in London.
• Vercel: website hosting, running in London.
• Anthropic: the AI coach. Questions may be processed in the United States under UK-approved safeguards.
• Google: reading reports your agency already keeps in Google Sheets, read-only.
• Google Analytics: counting visits to our public pages, only if you accept cookies. Google may process this data in the United States under UK-approved safeguards.
• Your agency’s own systems (for example its CRM and phone system), which we only read from.

10. How long we keep it

Activity figures are kept while your agency uses Agent Delegator. Messages are kept for the period your agency chooses, then deleted automatically. Any call transcripts Agent Delegator stores are kept for no more than 90 days. Anonymous coaching bank tips are kept until retired, because they don’t identify anyone. The list of pages you opened in the app is deleted after 90 days, and sign-in records and anonymous website visits after 12 months. When an agency leaves, its data is deleted or returned under its agreement with us.

11. Your rights

You can ask to see the personal data held about you, have it corrected, object to its use, or ask for it to be deleted. If you work for an agency, you can ask your agency, or contact us and we’ll pass it on. You can also complain to the Information Commissioner’s Office at ico.org.uk, though we’d appreciate the chance to put things right first.