Data Usage Policy

This Data Usage Policy explains, in practical terms, how Roctoo Portal FZE ("Roctoo", "we", "us") uses the information submitted to the roctoo.com platform (the "Platform") to operate its features — including property matching, broker pipelines, and transaction records. This Policy supplements, and should be read together with, our Privacy Policy and Terms and Conditions. Where this Policy and the Privacy Policy differ on data protection matters, the Privacy Policy governs.

1. Purpose of This Policy

While our Privacy Policy explains what personal data we collect and your rights over it, this Data Usage Policy focuses specifically on how the data you and other Users submit is put to work inside the Platform — including automated scoring, matching between property Listings and buyer Demands, and how that data flows between different parts of your account and team.

2. Categories of Platform Data

• Listing data: property details, price, location, media, and status (public/private, featured/premium, verified, exclusive) submitted by Brokers, Companies, or property owners.
• Demand data: property requirements submitted by Clients, including budget range and location/category preferences.
• Activity data: actions taken on the Platform, such as searches, saved Listings, views, messages, and response times, used to gauge engagement.
• Relationship data: links between Clients and their assigned Broker, and between Brokers and their Company, used to route information to the right team members.
• Transaction and deal data: submitted payment, commission, and closed-deal records associated with a Listing or Demand.

3. How Listing and Demand Data Is Used

• Listing data you submit is used to publish your property on the Platform and to make it discoverable to Clients and Brokers searching for matching requirements.
• Demand data you submit is used to search existing Listings and to notify you (and, where applicable, your assigned Broker) when a new or updated Listing appears to match your stated requirement.
• Where a Listing is marked private or exclusive, its data is used only for the purposes and audience associated with that designation, and is not made openly searchable in the same way as a public Listing.

4. Automated Matching and Scoring ("DNA")

• The Platform uses an automated scoring system, referred to internally as "DNA", to calculate compatibility scores between Listings and Demands based on factors such as location, budget, and property type.
• Separately, activity data (such as engagement level, response rate, and recency of activity) may be used to calculate activity or intent indicators for Clients and interest indicators for Listings, which help Brokers prioritize follow-up.
• These scores are recalculated periodically (for example, on a nightly schedule) as new activity and data are recorded, so that matching results and priority indicators stay current.
• Automated scores are decision-support tools for Users and are not shared with third parties outside the Platform, and are not used to make any decision with legal or similarly significant effect on a User without the opportunity for human review.

5. How Data Flows Within Broker and Company Accounts

• Where a Client is assigned to a Broker, relevant Demand and activity data associated with that Client is made visible to the assigned Broker to support follow-up.
• Where a Broker operates under a Company profile, relevant Listing, pipeline, and deal data associated with that Broker's activity may be visible to authorized Company administrators for team oversight, in accordance with the Company's internal permissions.
• Access to a Listing or Demand granted to a property owner or third party (such as temporary owner access to review activity on their property) is time-bound and expires automatically at the end of the access period unless renewed.

6. Transaction and Deal Data

Data relating to Transactions (such as submitted payment or commission records) and Deals (closed sale or lease outcomes) is used to maintain an accurate record of pipeline and performance activity, to support administrative review and approval, and to generate reporting such as portfolio and performance statistics for Users, Brokers, and Companies.

7. Analytics and Platform Improvement

Aggregated and/or de-identified usage data may be used to understand how features such as search, matching, and messaging are used, to identify and fix issues, and to improve the accuracy of matching and scoring over time. Where such analysis is presented in reports, it is not used to identify an individual User.

8. Data Retention in Operational Systems

Operational data (such as Listing history, Demand history, match records, and deal records) is retained for as long as reasonably necessary to support ongoing Platform features (such as historical performance reporting) and to meet applicable legal and audit requirements, consistent with the retention approach described in our Privacy Policy.

9. Your Choices

• You may update or remove Listing and Demand details you have submitted through your account at any time, subject to any Listings or Demands already linked to an active Match, Proposal, or Deal.
• You may request details of the categories of data associated with your account by contacting us using the details below.
• Company administrators may manage which data is visible to individual team members through the Company's internal access settings.

10. Changes to This Policy

We may update this Data Usage Policy from time to time as Platform features evolve. Where changes are material, we will provide reasonable notice through the Platform or by email before the changes take effect.

11. Contact Us

If you have any questions about how your data is used within the Platform, please contact us: