Privacy Policy

1. Data controller

The data controller for this Service is:

What If Now Ltd
Dublin, Ireland
Email: hello@whatifnow.ie

2. What data we collect

When you use righttostay.ie, we collect the following data:

We do not collect names, email addresses, phone numbers, payment information, or location data (beyond what is implicit in an IP address).

No account is required to use this Service. We do not ask you to register, log in, or provide any identifying information.

3. Special category data

Under Article 9 of the GDPR, certain types of personal data are classified as “special category” data and require additional safeguards. When you describe your tenancy situation, your question may contain sensitive personal information, such as:

• Health or disability information
• Family or relationship circumstances
• Ethnic or national origin
• Financial hardship

We do not request or require this information. If you choose to include it in your question, it will be processed solely for the purpose of generating your answer. We strongly encourage you to include only the information necessary to describe your tenancy situation.

4. Lawful basis for processing

Our lawful basis for processing your data is consent under Article 6(1)(a) of the GDPR. By actively submitting your question, you consent to the processing described in this policy.

Where your question contains special category data, our lawful basis is explicit consent under Article 9(2)(a) of the GDPR, demonstrated by your voluntary submission of the question.

You may withdraw consent at any time by ceasing to use the Service. As we do not store questions persistently, there is no ongoing processing to withdraw from.

5. How we process your data

When you submit a question:

1. Your question is sent from your browser to our server.
2. Our server forwards the question to Vertex AI (Google Gemini) for answer generation.
3. The AI generates a response based on its training data and our grounding sources (RTB decisions and Irish tenancy legislation).
4. The answer is returned to your browser and displayed.

Your question is processed in real time. It is not stored persistently and there is no conversation history.

6. Sub-processors

We have a Data Processing Agreement in place with Google Cloud in accordance with Article 28 of the GDPR.

7. Data retention

8. Cookies

We use essential cookies only for the basic operation of the website. We do not use analytics cookies, advertising or tracking cookies, or third-party cookies.

As we use only strictly necessary cookies, a cookie consent banner is not required under the ePrivacy Directive (Directive 2002/58/EC, as transposed by S.I. No. 336/2011).

9. Your rights

Under the GDPR, you have the following rights in relation to your personal data:

In practice, as we do not store questions persistently and do not create user accounts, the exercise of these rights is limited. Server logs containing your IP address are automatically deleted after 30 days.

To exercise any of these rights, please contact us at hello@whatifnow.ie.

10. Right to complain

If you are unsatisfied with how we handle your personal data, you have the right to lodge a complaint with:

Data Protection Commission (DPC)
21 Fitzwilliam Square South
Dublin 2, D02 RD28
Ireland

Website: www.dataprotection.ie
Phone: +353 (0)1 765 0100 / 1800 437 737

11. Children

This Service is not intended for children under the age of 18. We do not knowingly collect personal data from children. If you are under 18, please do not use this Service. If you believe a child has submitted data through this Service, please contact us at hello@whatifnow.ie and we will take steps to delete the relevant server logs.

12. International transfers

We do not transfer your personal data outside the European Economic Area (EEA). All processing occurs within the EU, specifically in the europe-west1 (Belgium) region of Google Cloud Platform.

13. Changes to this policy

We may update this Privacy Policy from time to time. Changes will be effective when posted on this page, and the “Last updated” date will be revised accordingly. We encourage you to review this policy periodically.