Table of Contents
Data Privacy Policy
cre-book | Operated by The Real Estate Strategists’ Solutions Inc.
Version 1.0
Published: 22 August 2026
Last updated: 22 August 2026
Effective date: 21 September 2026
1. About this Policy
1.1 The Real Estate Strategists’ Solutions Inc. (“TRESSI”, “we”, “us”) operates the cre-book platform at cre-book.com (the “Platform”). We are the Personal Information Controller in respect of personal information collected through the Platform.
1.2 This Policy explains what personal information we collect, why we collect it, how we use and share it, how long we keep it, and the rights you have over it. It is issued in accordance with Republic Act No. 10173, the Data Privacy Act of 2012, its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (together, the “Data Privacy Act”).
1.3 This Policy forms part of the cre-book Terms and Conditions. Words defined in the Terms and Conditions have the same meaning here. Where this Policy and the Terms and Conditions differ on a matter of data processing, this Policy prevails.
1.4 Our details.
| Registered name | The Real Estate Strategists’ Solutions Inc. |
| SEC Registration No. | 2024050149001-05 |
| Registered address | 8F Ayala Triangle Gardens Tower 2, Paseo de Roxas corner Makati Avenue, Bel-Air, 1209 City of Makati, Metro Manila, Philippines |
| Data Protection Officer | Yvette Alimpia |
| DPO contact | admin@cre-book.com |
| BIR TIN | 010-935-456-00000 |
| NPC registration | Under application as of 22 August 2026 |
2. Who this Policy applies to
2.1 This Policy applies to:
(a) Property Advertisers, being brokers, salespersons, owners, developers, and their personnel who submit Advertisements;
(b) Property Finders, being people who search, browse, and submit Inquiries;
(c) Visitors, being people who use the Platform without registering; and
(d) people who contact us, subscribe to CRE Intelligence, or otherwise deal with us in connection with the Platform.
2.2 It does not apply to how a Property Advertiser handles your information after we pass an Inquiry to them. See Section 8.
3. What we collect
3.1 Information you give us
| Category | Examples | Who it applies to |
|---|---|---|
| Account information | Name, email address, mobile number, password, account type, company name | All registered Users |
| Business information | Registered business name, business address, SEC or DTI registration details, Taxpayer Identification Number | Property Advertisers |
| Professional credentials | PRC licence number and validity date, Professional Identification Card, Professional Tax Receipt number, supervising broker details, accreditation documents | Property Advertisers relying on clause 6.8(a) of the Terms |
| Identity documents | Government-issued identification, where requested under clause 14.2 of the Terms | Property Advertisers |
| Authority documents | Listing agreements, mandates, special powers of attorney, proof of ownership, where requested or submitted in a dispute | Property Advertisers and complaining owners |
| Advertisement content | Property details, address, photographs, floor plans, videos, contact details displayed on the listing | Property Advertisers |
| Inquiry content | Your name, contact details, and the message you send about a property | Property Finders |
| Payment information | Billing name and address, TIN, transaction records, partial card details | Paying Users |
| Communications | Emails, support requests, complaints, reports, and our replies | Anyone who contacts us |
| Preferences | Saved searches, saved Advertisements, notification settings, newsletter subscriptions | Registered Users |
Note. We do not require sensitive personal information as defined in the Data Privacy Act. A government-issued identification document may incidentally contain sensitive personal information. Where it does, we use only the identity and validity details and do not process the remainder.
3.2 Information collected automatically
When you use the Platform we collect device and usage information, including IP address, browser type and version, operating system, device identifiers, referring page, pages and Advertisements viewed, searches run, time and duration of visits, and interactions such as clicks and scrolls. This is collected through cookies and similar technologies described in Section 9.
3.3 Information from other sources
We may receive information about you from:
(a) the Professional Regulation Commission, where we verify a licence under clause 6.8(e) of the Terms;
(b) our payment processors, in relation to a transaction;
(c) a Property Advertiser, where they supply your details as a contact person for a listing;
(d) a person who reports an Advertisement or a User to us; and
(e) publicly available sources, where we verify a business registration.
4. Why we collect it, and our legal basis
We process personal information on the following bases under the Data Privacy Act.
| Purpose | Legal basis |
|---|---|
| Creating and administering your Account | Performance of a contract with you |
| Publishing Advertisements and displaying advertiser contact details | Performance of a contract with the Property Advertiser |
| Transmitting Inquiries automatically to the chosen Property Advertiser | Consent given when you submit an Inquiry, and performance of a contract |
| Verifying identity, business registration, and professional licensing | Compliance with a legal obligation under the Internet Transactions Act and RESA, and our legitimate interests in platform integrity |
| Processing payments, issuing invoices, and tax compliance | Performance of a contract and compliance with a legal obligation under Philippine tax law |
| Reviewing and moderating Advertisements | Our legitimate interests in operating a lawful and accurate platform |
| Retaining an automated system record of Inquiries for security, fraud prevention, record-keeping, and dispute resolution | Our legitimate interests, and compliance with record-keeping obligations under the Internet Transactions Act. See Section 7 |
| Processing transmission metadata, such as whether and when a Property Advertiser responded, to measure responsiveness | Our legitimate interests. This does not use your name, contact details, or the content of your message |
| Handling complaints, takedown requests, and disputes | Our legitimate interests and compliance with legal obligations |
| Security, fraud prevention, and enforcement of the Terms | Our legitimate interests |
| Producing aggregated market intelligence, including CRE Intelligence | Our legitimate interests, using data that no longer identifies you. See Section 11 |
| Sending saved search alerts and notifications you have activated | Consent, given when you activate the feature |
| Sending newsletters, market updates, and announcements | Consent, given when you subscribe |
| Sending transactional and security messages | Performance of a contract |
| Improving and developing the Platform | Our legitimate interests |
| Responding to lawful requests from authorities | Compliance with a legal obligation |
5. Advertisement content is public
5.1 Information submitted as part of an Advertisement is published on the Platform and is visible to anyone. This includes the property address, property details, images, and the contact details and professional credentials the Property Advertiser provides for display.
5.2 Clause 6.8(c) of the Terms requires the display of a broker’s name, PRC licence number, licence validity date, and Professional Tax Receipt number on each Advertisement. Property Advertisers consent to that publication when they submit an Advertisement.
5.3 Published Advertisement content may be indexed by search engines, syndicated to our social media channels and partner sites, and cached or copied by third parties. Removal of an Advertisement from the Platform does not remove copies already held elsewhere. Clause 11.4 of the Terms addresses this.
5.4 The Platform does not support confidential or anonymised listings. Anyone who cannot have a property identified publicly should not submit it.
6. Inquiries and your contact details
6.1 When you submit an Inquiry, our system automatically transmits your name, contact details, and message directly to the Property Advertiser responsible for that Advertisement. Transmission is automated and does not depend on anyone at TRESSI reading your message first. This is the purpose of the Inquiry function and you consent to it when you submit.
6.2 From the point of receipt, the Property Advertiser is an independent Personal Information Controller in respect of that information. See Section 8.
6.3 We do not sell your contact details, and we do not pass them to any Property Advertiser other than the one responsible for the Advertisement you inquired about.
7. Our record of Inquiries
7.1 When an Inquiry is transmitted, our system automatically keeps a record of it. We tell you this plainly because it is not obvious from using the Platform. The record is created by the system at the moment of transmission. It is not created by anyone reading your message.
7.2 We keep that record because we need it to:
(a) maintain the security and integrity of the Platform;
(b) detect, investigate, and prevent fraud, impersonation, spam, and misuse;
(c) meet our record-keeping obligations as a digital platform under the Internet Transactions Act;
(d) establish whether, when, and to whom an Inquiry was sent, so that we can resolve disputes and complaints;
(e) establish, exercise, or defend legal claims.
7.3 Our legal basis for keeping the record is our legitimate interests in the matters listed above, together with our record-keeping obligations under the Internet Transactions Act.
7.4 Our administrators can access the content of a recorded Inquiry, but only for the purposes in Section 7.2. Access is restricted to personnel who need it, and each access is itself logged.
7.5 We do not use Inquiry content for our own business development, marketing, or client acquisition, and we do not make it available to our affiliates for those purposes.
7.6 Everything that happens to your Inquiry after it is sent and recorded, including whether and how the Property Advertiser replies to you, is that Property Advertiser’s responsibility, not ours. See Section 8.
7.7 Separately from the record above, we process transmission metadata, meaning the date and time your Inquiry was sent, the property type it concerned, and whether and when the Property Advertiser replied. We use this to measure how quickly Property Advertisers respond, which affects their standing under clause 8.2 of the Terms, and to produce the statistics described in Section 11. Transmission metadata does not include your name, your contact details, or what you wrote.
7.8 Records are kept for the period in the retention schedule in Section 13 and are then deleted or anonymised.
8. Property Advertisers as independent controllers
8.1 Once a Property Advertiser receives your Inquiry, they decide how to handle your information. They are a separate Personal Information Controller and are responsible for their own compliance with the Data Privacy Act.
8.2 Under clause 15.5 of the Terms, Property Advertisers are required to use your details only to respond to your specific Inquiry. They may not add you to marketing lists, or transfer or sell your details, without your separate consent.
8.3 If a Property Advertiser misuses your information, you may report it to us at admin@cre-book.com. We can suspend or terminate their Account. You may also complain directly to the Property Advertiser or to the National Privacy Commission.
8.4 We do not control what a Property Advertiser does with your information after we pass it on, and we are not responsible for their handling of it.
9. Cookies and similar technologies
9.1 We use cookies and similar technologies on the Platform.
| Type | What it does | Can you switch it off |
|---|---|---|
| Strictly necessary | Keeps you logged in, remembers your session, protects against fraud, enables checkout | No. The Platform will not work properly without these |
| Preference | Remembers settings such as saved searches and display options | Yes |
| Analytics | Tells us which pages and Advertisements are viewed, how people search, and where the Platform is slow or failing. Includes Google Analytics and Google Site Kit | Yes |
| Advertising and measurement | Used to measure and target advertising. Includes the Meta Pixel and Google AdSense. These allow Meta and Google to receive information about your visit and may be used to show you advertising on their own services | Yes |
9.2 Meta Pixel. We use the Meta Pixel to measure the effectiveness of our advertising on Facebook and Instagram. It tells Meta that a browser visited our Platform and which pages were viewed. Meta processes that information under its own policies.
9.3 Google AdSense. We display third-party advertising supplied by Google AdSense. Google and its partners may use cookies to serve advertising based on your visits to this and other sites.
9.4 Managing cookies. You can control non-essential cookies through the cookie banner on the Platform and through your browser settings. Blocking cookies may affect how the Platform works.
10. Who we share information with
We share personal information with:
(a) Property Advertisers, being the Inquiry recipient, as described in Section 6;
(b) Hostinger, our hosting and infrastructure provider, which stores and serves the Platform from servers in Indonesia, with backup in Singapore;
(c) Payment providers, being PayMongo and WooCommerce for digital transactions, and UnionBank of the Philippines for bank transfers and cheque deposits. We do not accept cash payments;
(d) Analytics and advertising providers, being Google and Meta, as described in Section 9;
(e) Email and communications providers, being Hostinger, which generates and sends automated messages from the Platform including Inquiry notifications, and Microsoft 365, which hosts our mailboxes at admin@cre-book.com and sales@cre-book.com and delivers correspondence to and from them;
(f) Professional advisers, being our lawyers, accountants, and auditors, where necessary;
(g) Government authorities and regulators, including the Bureau of Internal Revenue, the National Privacy Commission, the Department of Trade and Industry, and the Professional Regulation Commission, where required by law or in response to a lawful request;
(h) A party to a complaint or dispute, to the extent described in clause 15.8 of the Terms; and
(i) An acquirer or investor, in connection with a financing, merger, reorganisation, or sale of the business, subject to appropriate confidentiality protection.
We do not sell personal information.
11. Aggregated and anonymised data
11.1 We produce market intelligence from Platform activity, including asking rents and prices, floor areas, building attributes, locations, listing durations, search patterns, and Inquiry statistics. This is published under CRE Intelligence and may be licensed to third parties.
11.1A Inquiry statistics means counts and proportions, such as how many Inquiries were made on the Platform in a given month, what share related to office space as against land or warehousing, which locations drew the most interest, and how demand shifted over time. These figures are built from transmission metadata described in Section 7.7. They never include your name, your contact details, or anything you wrote in an Inquiry, and they are not produced at a level of detail that would allow anyone to work out who made a particular Inquiry.
11.2 That work uses aggregated and anonymised data. It does not identify you, and it does not reproduce an individual Advertisement in a way that identifies the Property Advertiser without their consent.
11.3 Aggregated and anonymised data is no longer personal information and we may continue to use it after your Account is closed. Clause 11.6 of the Terms sets out these rights.
12. Cross-border transfers
12.1 Some of the providers listed in Section 10 process information outside the Philippines:
(a) Hostinger, our hosting provider, stores Platform data on servers in Indonesia, with backup storage in Singapore. This means that Platform data, including personal information, is stored outside the Philippines in the ordinary course;
(b) Microsoft, which hosts our mailboxes through Microsoft 365, may store and process email content, including Inquiry notifications and correspondence, in data centres outside the Philippines;
(c) Google and Meta, in connection with the analytics and advertising technologies described in Section 9, process information in the United States and elsewhere; and
(d) other providers may process information outside the Philippines in accordance with their own terms.
12.2 Where information is transferred outside the Philippines, we remain accountable for it under the Data Privacy Act and take reasonable steps to ensure a comparable level of protection, including through contractual commitments with those providers.
13. How long we keep it
| Information | Retention period |
|---|---|
| Account information, active Account | For as long as the Account is open |
| Account information, closed or deactivated Account | 60 months after closure, then deleted or anonymised |
| Advertisement content, published | For the Advertisement Term |
| Advertisement content, after expiry or removal | 60 months |
| Inquiry records | 60 months from submission |
| Transmission metadata | 60 months |
| Professional licence and accreditation records | 60 months from last verification |
| Identity and Authority documents | 60 months from collection, or the duration of any related dispute if longer |
| Payment records, invoices, and tax documents | 10 years, as required under Philippine tax rules |
| Complaint, takedown, and dispute records | 60 months from resolution |
| Acceptance records under clause 2.3 of the Terms | 60 months after the Account closes |
| Admin access logs under clause 18.4(d) of the Terms | 60 months |
| Marketing subscriptions | Until you unsubscribe, then a suppression record kept indefinitely so we do not contact you again |
| Analytics and cookie data | Per the provider’s own retention settings |
We keep information longer where required by law, or where it is needed for an ongoing dispute, investigation, or regulatory proceeding.
14. How we protect it
14.1 We apply organisational, physical, and technical measures appropriate to the risk, including access controls limiting personal information to personnel who need it, encryption of data in transit, logging of administrative access to Inquiries, password protection of Accounts, and periodic review of our security arrangements.
14.2 No system is completely secure. We cannot guarantee that unauthorised access will never occur.
14.3 You are responsible for keeping your Account credentials confidential, as set out in clauses 3.6 to 3.9 of the Terms.
14.4 If a personal data breach occurs that is likely to give rise to a real risk of serious harm, we will notify the National Privacy Commission and affected individuals in accordance with the Data Privacy Act.
15. Your rights
15.1 Under the Data Privacy Act you have the right:
(a) to be informed whether your personal information is being processed, and of the details of that processing;
(b) to object to processing, including processing for direct marketing;
(c) to access your personal information and the details of how it has been processed;
(d) to rectification, being correction of inaccurate or incomplete information;
(e) to erasure or blocking, where processing is unlawful, unnecessary, or no longer justified;
(f) to damages, where you suffer harm from inaccurate, unlawful, or unauthorised use of your information;
(g) to data portability, being an electronic copy of information you provided, in a commonly used format; and
(h) to lodge a complaint with the National Privacy Commission.
15.2 How to exercise them. Email admin@cre-book.com. We may ask you to verify your identity before acting, to make sure we do not disclose your information to someone else.
15.3 Timing. We aim to respond within fifteen (15) calendar days. Where a request is complex, we will tell you and give a revised timeframe.
15.4 Limits. We may decline a request where the Data Privacy Act permits, including where we are required by law to keep the information, where it is needed for an ongoing dispute or investigation, or where acting on it would prejudice the rights of another person. We will explain our reasons.
15.5 What deletion does not do. Deleting your Account does not withdraw an Inquiry already sent to a Property Advertiser, does not oblige that Property Advertiser to delete it, does not recall Advertisement content already syndicated or cached elsewhere, and does not affect aggregated and anonymised data under Section 11.
16. Complaints
16.1 If you are unhappy with how we have handled your personal information, contact our Data Protection Officer at admin@cre-book.com. We will acknowledge your complaint and respond.
16.2 If you remain dissatisfied, you may complain to the National Privacy Commission.
National Privacy Commission
25th to 27th Floors, The Upper Class Tower, Quezon Avenue corner Scout Reyes Street, Quezon City
Website: privacy.gov.ph
17. Children
17.1 The Platform is not intended for anyone under eighteen (18) years of age. Clause 3.1 of the Terms restricts Accounts to adults. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, contact admin@cre-book.com and we will delete it.
18. Automated processing
18.1 We use automated processing to order search results, to generate saved search alerts, and to flag possible duplicate Advertisements under clause 6.7 of the Terms.
18.2 We do not make decisions producing legal effects concerning you based solely on automated processing without human involvement. Advertisement approval, suspension, and takedown decisions are made by our administrators.
19. Third-party sites
19.1 The Platform links to and integrates with third-party websites and services. This Policy does not apply to them. We are not responsible for their content or their privacy practices, and you should read their own policies.
20. Changes to this Policy
20.1 We may update this Policy. The current version, the date it was published, and the date it takes effect appear at the top of this page. Where an update is material, the effective date will be not less than thirty (30) calendar days after the date of publication.
20.2 Where a change materially affects how we process your personal information, we will notify you by email or by prominent notice on the Platform not less than thirty (30) calendar days before it takes effect.
20.3 We keep an archive of previous versions, available on request at admin@cre-book.com.
21. Contact
Questions about this Policy, or about how we handle personal information, may be sent to our Data Protection Officer at admin@cre-book.com.
END OF POLICY
