Privacy at Reagent

We do not track individuals, by design.

Reagent turns property and showroom tours into AI-guided experiences, and we built the analytics the same way we would want them built for us: no cookies on tour pages, no consent banner between a user and a tour, and no persisted identifier that could follow a person around - by design and by access control. This page explains what data exists across everything we run, who controls it and the choices you have.

The short version

• Tour pages set no cookies and store no tracking identifier on your device. The only thing a tour ever stores is your own opt-out choice, if you make one - a fixed flag that cannot identify you or link your visits. Visits are measured anonymously and reported only as combined statistics.
• No statistic is ever shown for fewer than 5 visits, so no individual visit can be singled out.
• We keep your country and device type only - the network address and browser details they come from are discarded, never stored.
• We honour Global Privacy Control everywhere, and it takes precedence over any recorded consent.
• People who appear as AI presenters do so with a documented consent trail, keep all rights to their likeness and can have it deleted at any time.
• Lead details exist only when a buyer submits a form on purpose, and go to the property's publisher.

Guided tours (tours.reagenthq.ai)

Tours are published by our customers - property developers and brands. For tour analytics the publisher is the data controller and Reagent is the processor operating the measurement.

What is measured. Which rooms are viewed and for how long, completion, and use of tour features such as finish and layout options. Visits arriving through a shared link count toward that link's totals - links measure distribution channels, never people.

How it stays anonymous.

• No cookies, no local storage. A visit gets a random session number that evaporates when the tab closes; two visits by the same person cannot be connected.
• One caveat: a small number of named Reagent staff can access the raw event store for debugging and operations. Even there, a session is a random number's room sequence - no name, no network address, no device identity - and no product surface, ours or our customers', ever renders an individual journey.
• Country is derived from the network address and the address is then discarded. Device class (phone, tablet, desktop) is derived from the browser the same way. No IP address, no fingerprint, no hash of either is retained anywhere.
• Every reported statistic is aggregate, with small-cell suppression: below 5 sessions a figure shows totals only, across every dimension (link, room, date, device). "When was this link last opened" is reported to the day, never the time.

Opting out. Every tour links to a privacy page with a working measurement toggle, in the tour's language. If your browser sends the Global Privacy Control signal, measurement never starts - and GPC overrides any consent recorded anywhere on our surfaces.

Retention. Detailed measurement events are deleted after 13 months at the latest; only aggregate statistics, which identify no one, are kept beyond that.

One carve-out. If a tour hits a technical problem, a small error report is sent even when measurement is off: which tour, what went wrong, device class. It carries no session id, no network address and no identifier of any kind. It exists to keep tours working, not to measure anyone, which is why it sits outside the measurement opt-out.

Our privacy posture

European regulators (France's CNIL and Italy's Garante) publish conditions under which suitably anonymous audience measurement is exempt from the ePrivacy consent requirement - the conditions behind tools like the CNIL-tested Matomo configuration. We designed Reagent's tour analytics to those conditions and documented, condition by condition, how our configuration meets them - in several places more strictly than the tested configurations (no IP retained at all rather than masked; no persisted identifier rather than a 13-month cookie).

To be precise about what that means: no regulator has certified or validated Reagent. Our position is a reasoned, documented analysis against the published conditions - the same category of self-assessment published by privacy-focused analytics providers - and we make the full assessment available to customers' data protection officers before signature.

Enquiries and leads

When a buyer submits an enquiry through a tour, the details they enter (name, contact details, message) go to the publisher of that tour so they can respond - processing steps taken at the buyer's own request. The form states this at the point of collection. Enquiry data is never mixed into the anonymous analytics; deleting an enquiry also deletes the tour-session context that was attached to it.

AI presenters and likeness

Tour presenters are AI-generated. Some are fully synthetic avatars that resemble no real person. Others are created from recordings of real people - typically our customers' own staff - who record a short video and voice sample for the purpose. The commitments below apply to the real-person path:

• Every presenter rests on a documented consent trail, captured when the recordings are submitted.
• The person keeps all rights to their face and voice; the publisher commissions the presenter, and Reagent holds a limited licence to process the recordings for that purpose only.
• Recordings and presenters live in Reagent's locked accounts with specialist AI providers acting under contract as processors. None of the material is used to train AI models.
• Presenters speak only scripts the publisher has reviewed; there is no public gallery or marketplace.
• Deletion on request, at any time: recordings, voice model and presenter.

The full plain-language explanation lives at app.reagenthq.ai/likeness.

This website

reagenthq.ai (the site you are on) uses analytics cookies only with your consent, via the consent banner, with non-essential cookies blocked until you choose. The strictest (EU) rules are applied to every visitor, everywhere. If your browser sends Global Privacy Control, analytics stays off regardless of any banner choice. Details and the current cookie list: cookie policy.

The Reagent app

Customers' operators sign in to the Reagent app with their work email and are identified in product analytics by that email - necessary to operate and support the product, under the customer agreement. Reagent is the controller for this data; operators receive a separate notice.

Who we share data with

Reagent runs on a small set of infrastructure providers acting under contract as processors: hosting and content delivery, analytics event storage and query (anonymous events only, never personal details), sign-in, transactional email, tour ingestion and AI presenter generation. We publish the full named list to customers and keep data-transfer safeguards (EU adequacy mechanisms and standard contractual clauses, with transfer impact assessments) in place for each. We do not sell data, share it with advertisers or use one customer's data in another customer's product.

Your rights

For tour analytics there is, by design, no stored data that can identify you - which also means there is nothing we could look up about your visit if asked. For enquiries you submitted, the publisher of the tour is the controller and the right first contact; we support them in honouring access and deletion requests. For anything on this website or about your likeness as a presenter, contact us and we will act on it directly.

Contact

Reagent AI Pte. Ltd., Singapore.
Contact form: reagenthq.ai.

Data protection officer (designated under section 11(3) of Singapore's Personal Data Protection Act): Matt Mulligan, reachable via the contact form. This is a Singapore PDPA designation, not a GDPR Article 37 designation; for GDPR matters the same person is our privacy contact.

Last updated: 20 July 2026