This is a placeholder, not a privacy policy. It was written by the people building this software as a note to themselves about what the real document has to cover. It has not been drafted or reviewed by a lawyer, it makes no commitments, and nobody should rely on it. It must be replaced before this service is offered to anybody.

Privacy

Cypher Media Solutions operates MaxUp CRM, software that property developers and brokerages use to manage enquiries from people interested in buying a home.

Two different sets of people, and only one of them is our customer

This distinction is the thing the real document most needs to get right, so it is recorded here first.

Our customers are the developers and brokerages who use the software. We hold their staff’s names, email addresses and phone numbers so they can sign in, and records of what they did in the product.

Homebuyers are the people whose enquiries our customers manage. We store that information on our customer’s behalf and at their instruction. We are not the people who decided to collect it and we do not decide what it is used for. A homebuyer who wants to know what is held about them, or wants it corrected or deleted, should ask the developer or broker they enquired with. Under the Digital Personal Data Protection Act 2023 that business is required to tell them.

What the real document has to cover

What is collected, itemised — not “business information”.
What each item is used for, and the lawful basis for it.
Who it is shared with, including every processor and where they are.
How long it is kept, and what happens at the end of that.
How somebody exercises their rights, and who to contact.
How a complaint is made, and where it goes if we do not resolve it.
What happens to it all if this business is sold or shut down.

What we can already say is true

These are facts about how the software is built rather than commitments in a policy, and they are here because they will not change when the real document is written.

Each customer’s data is isolated from every other customer’s at the database level, not by a filter in application code.
Messages to homebuyers over WhatsApp are sent by our customers, from their own WhatsApp Business account, under their own relationship with the buyer.
We do not sell anything to anybody, and we do not use one customer’s data to serve another.

Contact

Until the real document exists, questions go to [email protected].

Last updated: never. This page has no version and no effective date, because a placeholder should not have either.