Privacy policy

Last updated: 21 August 2026

Privacy Policy

This Privacy Policy explains how Photoholics OÜ ("we", "us", "Kinnisvara.AI") collects, uses, stores, and protects personal data when you use the Kinnisvara.AI service at kinnisvara.ai and app.kinnisvara.ai (the "Service").

We are committed to protecting your privacy and comply with the EU General Data Protection Regulation (GDPR) and the Estonian Personal Data Protection Act.

1. Data Controller

Photoholics OÜ
Registry code: 14998427
Address: Salu tn 1, Ääsmäe küla, 76402 Saue vald, Harju maakond, Estonia
Email: paul@aisolutions.center

2. Personal Data We Collect

2.1 Data you provide directly

  • Account information: name, email address, password

  • Real estate listing content: listing URLs and content you paste or upload for content generation

  • Billing information: billing name, address, VAT number (payment card data is processed by our payment provider and is not stored by us)

  • Communications: messages you send to our support team

2.2 Data from Facebook and Instagram (Meta)

When you connect a Facebook account via Facebook Login for Business, we receive:

  • Your Facebook user ID and name

  • Your profile picture and email address

  • A list of Facebook Pages you administer

  • A list of connected Instagram Business or Creator accounts

  • Access tokens that allow us to publish content and read basic insights on the Pages and Instagram accounts you explicitly select

We only access the Pages and Instagram accounts you actively select inside the Service. We do not access your personal Facebook timeline, private messages, friends list, or content on Pages you have not authorized.

2.3 Data collected automatically

  • Usage data: pages viewed, features used, generated content history

  • Technical data: IP address, browser type, device type, operating system, timestamps

  • Cookies: see Section 9

3. Legal Basis and Purpose

We process your personal data on the following legal bases:

Purpose Legal basis Providing the Service to you Performance of contract (Art. 6(1)(b) GDPR) Publishing content to your connected Facebook/Instagram accounts Performance of contract and your explicit consent when connecting the account Billing and accounting Legal obligation (Art. 6(1)(c) GDPR) Improving the Service, security, fraud prevention Legitimate interest (Art. 6(1)(f) GDPR) Marketing communications Consent, which you can withdraw at any time

4. Sharing With Third Parties

We share personal data only with the processors and partners strictly necessary to operate the Service:

  • Meta Platforms Ireland Ltd. — to publish content and retrieve Pages/Instagram data you authorize

  • Replicate, Inc. (US) — AI model hosting used to generate images and text

  • Hosting and infrastructure providers — to run our servers and databases

  • Payment processor — to process subscription payments

  • Analytics providers — to understand aggregated usage of the Service

We do not sell your personal data. We do not share your personal data for advertising purposes with third parties beyond what you explicitly publish to your own connected accounts.

5. International Data Transfers

Some of our processors (notably Replicate, Inc.) are located outside the European Economic Area. Where personal data is transferred outside the EEA, we rely on the European Commission's Standard Contractual Clauses or an adequacy decision to ensure your data receives an equivalent level of protection.

6. Retention

  • Account data: kept while your account is active and for up to 12 months after account closure, unless a longer period is required by law (e.g. accounting records — 7 years under Estonian law).

  • Facebook access tokens: kept only while the connection is active. Deleted immediately upon disconnection or account deletion.

  • Generated content: kept while your account is active. You can delete individual items at any time.

  • Support communications: kept for up to 3 years.

  • Technical logs: kept for up to 12 months.

7. Your Rights Under GDPR

You have the right to:

  • Access the personal data we hold about you

  • Rectify inaccurate or incomplete data

  • Erase your personal data ("right to be forgotten")

  • Restrict processing in certain circumstances

  • Object to processing based on legitimate interest

  • Data portability — receive your data in a machine-readable format

  • Withdraw consent at any time, where processing is based on consent

  • Lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee) or your local supervisory authority

To exercise any of these rights, email paul@aisolutions.center. We respond within 30 days.

8. Data Deletion

You can delete your account and all associated data at any time from the Settings page in the Service, or by emailing paul@aisolutions.center.

When you delete your account:

  • All personal data, generated content, and Facebook/Instagram access tokens are permanently deleted within 30 days

  • Data required to be retained by law (e.g. invoices) is archived separately and deleted at the end of the legal retention period

  • Backups are overwritten within 90 days

See our Data Deletion Instructions for full details.

9. Cookies

We use essential cookies to run the Service (session, authentication, security). We use analytics cookies only with your consent, which you can manage from the cookie banner shown on your first visit.

10. Security

We use industry-standard measures to protect personal data, including encrypted connections (HTTPS/TLS), encrypted storage of access tokens, and strict access controls. No system is 100% secure, so we cannot guarantee absolute security, but we take every reasonable step.

11. Children

The Service is not directed at children under 16. We do not knowingly collect personal data from children.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified via email or in-app notification at least 14 days before taking effect. The "Last updated" date at the top always reflects the current version.

13. Contact

For any question about this Privacy Policy or your personal data:

Email: paul@aisolutions.center
Postal: Photoholics OÜ, Salu tn 1, Ääsmäe küla, 76402 Saue vald, Harju maakond, Estonia