Data Processing Agreement

1. Roles

• The Customer is the Data Controller
• HomeClose is the Data Processor

The Customer determines:

• What data is collected
• Why it is collected

HomeClose processes data only on behalf of the Customer.

2. Scope of Processing

HomeClose processes personal data to provide the Service, including:

• Contact and client information
• Transaction and property data
• Documents and communications
• E-signature data
• User account information

3. Types of Data

The data processed may include:

• Names, email addresses, phone numbers
• Property addresses and transaction details
• Financial-related transaction data (e.g., commissions, pricing)
• Uploaded documents (contracts, disclosures, etc.)
• Communication records

4. Purpose of Processing

HomeClose processes data solely to:

• Provide and operate the platform
• Manage real estate transactions
• Store and organize client data
• Enable communication and collaboration
• Improve and maintain the Service

5. Data Security

HomeClose implements reasonable technical and organizational measures, including:

• Secure hosting infrastructure (e.g., Vercel)
• Access controls and authentication
• Encryption in transit (HTTPS)
• Role-based access within organizations

6. Subprocessors

HomeClose may use subprocessors, including:

• Hosting providers
• Storage services
• Email delivery services
• Authentication providers

HomeClose ensures these subprocessors:

• Process data only on our instructions
• Maintain appropriate security measures

7. Data Retention

Data is retained only as long as necessary to:

• Provide the Service
• Fulfill contractual obligations
• Comply with legal requirements

Customers may request deletion of their data.

8. Customer Responsibilities

The Customer agrees to:

• Comply with applicable data protection laws
• Obtain necessary consent from clients
• Ensure data accuracy
• Not upload unlawful or unauthorized data

9. Data Subject Rights

HomeClose will assist Customers in responding to requests such as:

• Access
• Correction
• Deletion

10. Data Breach Notification

In the event of a data breach, HomeClose will:

• Notify affected Customers without undue delay
• Provide relevant details about the incident
• Take reasonable steps to mitigate impact

11. Data Deletion

Upon termination of the Service:

• Customer data will be deleted within a reasonable timeframe
• Unless retention is required by law

12. Governing Law

This DPA is governed by the laws of the State of Kentucky, United States.

13. Contact

For data protection inquiries:

Email: torstenlangguth@gmail.com