Data Processing Addendum

Version: 2026-03-16

Operational DPA package
This Addendum supplements the Terms of Service for Customers that require processor terms under GDPR, UK GDPR, CCPA/CPRA, UAE PDPL, KSA PDPL, or similar data protection laws.

1. Scope and Order of Precedence

This Data Processing Addendum applies when Realty Cruiser processes Customer Data on behalf of the Customer. If there is a conflict between this Addendum and the Terms of Service solely as to data protection obligations, this Addendum controls to the extent of that conflict.

2. Roles

  • Customer: Controller or business determining the purposes and means of processing Customer Data.
  • Realty Cruiser: Processor or service provider processing Customer Data only on documented instructions, except where applicable law requires otherwise.

3. Subject Matter and Duration

The subject matter is the provision of a global real estate CRM with optional scraping orchestration, messaging, analytics, and AI-assisted features. Processing continues for the duration of the Customer's use of the Service and any post-termination retention period required by law, security needs, suppression obligations, or documented deletion workflows.

4. Nature and Purpose of Processing

  • Hosting and organizing CRM records, tasks, deals, notes, and account data.
  • Transmitting communications through enabled providers and maintaining consent, unsubscribe, and blacklist records.
  • Providing analytics, AI-assisted drafting, summaries, and market analysis features enabled by the Customer.
  • Exporting, deleting, or anonymizing records at Customer direction.

5. Categories of Data and Data Subjects

Data categories may include account data, CRM records, contact details, property and listing metadata, communication logs, consent evidence, technical logs, and Customer-submitted prompts or notes. Data subjects may include Customer personnel, prospective buyers or sellers, property owners, tenants, counterparties, and other individuals whose data the Customer chooses to process through the Service.

6. Customer Instructions and Lawful Use

The Customer instructs Realty Cruiser to process Customer Data to provide the Service. The Customer is responsible for ensuring the lawfulness of the data it provides, including any scraped or imported data, and for issuing only lawful instructions.

7. Confidentiality and Security

Realty Cruiser will implement reasonable technical and organizational measures designed to protect Customer Data, including access controls, audit logging, role-based restrictions, and suppression workflows. Persons authorized to process Customer Data will be subject to appropriate confidentiality obligations.

8. Subprocessors

The Customer authorizes Realty Cruiser to use subprocessors that are necessary to provide the Service. The current subprocessor schedule is published at the Subprocessor Schedule. Realty Cruiser will remain responsible for the performance of its subprocessor obligations to the extent required by applicable law and contract.

9. International Transfers

Where Customer Data is transferred across borders, Realty Cruiser will use an applicable transfer mechanism such as contractual clauses, processor commitments, vendor safeguards, or another lawful basis recognized by the relevant jurisdiction. The Customer acknowledges that regional product features do not by themselves guarantee exclusive local hosting unless separately contracted.

10. Assistance with Data Subject Requests

Taking into account the nature of the processing, Realty Cruiser will provide reasonable assistance to help the Customer respond to valid access, correction, deletion, restriction, portability, objection, suppression, and consent-withdrawal requests where required by applicable law.

11. Deletion and Return

Upon termination or Customer request, Realty Cruiser will make available deletion, deep-scrub, anonymization, or export functionality as provided by the Service, subject to retention needed for legal compliance, audit logs, blacklist and suppression obligations, security, fraud prevention, billing, and dispute resolution.

12. Audit Information

Realty Cruiser may satisfy reasonable information requests about its processor controls by providing published policies, product documentation, audit summaries, architectural notes, or other materials it makes available to Customers, provided such disclosure does not compromise security, other customers, or privileged information.

13. Region-Specific Notes

  • GDPR and UK GDPR: This Addendum is intended to support Article 28 style processor terms.
  • CCPA/CPRA: Realty Cruiser will process Customer Data for business purposes and not sell Customer CRM data for cross-context behavioral advertising.
  • UAE and KSA regimes: Where UAE PDPL or KSA PDPL applies, the parties will cooperate on localization reviews, transfer mechanisms, and data subject rights workflows to the extent required by those laws.