Data Processing Terms for Your Clients' Data

1. 1.1 You decide about the data of your own clients that you enter in your personal space; for the law you are the controller. Clients of a brokerage you work for belong in the brokerage's office space under the brokerage's own contract with us (for example the office CRM of Zolia); these terms do not cover them. If you hold the licence of your brokerage yourself, for example as a one-person brokerage, the brokerage's clients count as your own clients for these terms, and you accept these terms also for your brokerage.
2. 1.2 Biturai L.L.C-FZ (Meydan Free Zone, licence no. 2312186.01, Dubai) processes that data only on your behalf as processor.
3. 1.3 Purpose: to provide the functions of Zolia that you use: storing contacts, enquiries and conversations, reminders, search, AI drafts and summaries, reports and the export of your data.
4. 1.4 Types of data: names, contact details, wishes and budgets, notes, messages, documents and appointments of your clients and their representatives.
5. 1.5 Persons concerned: your clients and prospective clients, landlords, tenants, buyers, sellers and their contact persons.
6. 1.6 Duration: as long as you use these functions; these terms end when you delete your account.
7. 1.7 If another company takes over our business and is to process the data, it takes over these terms unchanged. We tell you at least 30 days before, and you can end these terms and export your clients' data before the change.

1. 2.1 Your use of the functions of Zolia is your instruction. We process the data only for the purpose above and only as long as needed for it.
2. 2.2 If we believe an instruction breaks the law, we tell you.

1. 3.1 Confidentiality: only people who need the data for the service have access, and they are bound to confidentiality. We do not disclose the data or the results of processing to anyone unless the law requires it.
2. 3.2 Security: encryption in transit and at rest, keys in a hardware security module, separation of every space, pseudonymisation before AI processing, logged access (see the Security Schedule).
3. 3.3 Records and proof: we keep a record of the processing we carry out for you and give you the information you need to show that the data is processed lawfully.
4. 3.4 Breaches: we tell you immediately, at the latest within 24 hours after we become aware of a breach that concerns your clients' data, with what we know and what we have done, and we add details as we learn them.
5. 3.5 Requests of your clients: we forward requests that reach us to you and help you answer them. You can correct and delete each client's data in the app; where the app does not yet offer an export or deletion per client, we do it for you on request.

1. 4.1 We use Microsoft (Azure, UAE North, Dubai) for hosting and storage and Amazon Web Services in the European Union for AI models (pseudonymised content, not stored, no training), system e-mails and the receipt of e-mails to our help desk. Both are bound by written contracts with obligations at least as strict as these terms.
2. 4.2 We tell you in the app at least 30 days before we add or replace a sub-processor. If you object, you can stop using client functions or delete your account before the change.
3. 4.3 If you connect your own WhatsApp number, Meta is your own provider under your contract with Meta, not our sub-processor.

The data is stored in the UAE. AI processing and system e-mails take place in the European Union, where the General Data Protection Regulation and independent supervisory authorities protect personal data, and they are necessary to perform the contract that serves your clients' requests. Content is pseudonymised before it goes to an AI model.

You instruct us to create anonymous statistics from the data (at least 10 people behind every value, no content, no WhatsApp data) and to improve the service without content (for example error types and how often drafts are accepted). We do nothing else with your clients' data: no training of AI models with it, no contact lists for us, no marketing to your clients.

1. 7.1 You can export your clients' data at any time, in the app or, where the app does not offer it yet, on request.
2. 7.2 You decide how long you keep your clients' data, and you delete it when you no longer need it. We do not delete it only because time has passed; raw conversation history is deleted 24 months after your last use. You can delete a client's data at any time. Data under a legal hold stays as long as required.
3. 7.3 When these terms end because you delete your account, we delete the data 30 days after your request (until then you can cancel the deletion), unless the law requires us to keep it. Copies in backups expire within a further 35 days.

1. 8.1 You have a lawful reason to process your clients' data, for example their request or your contract with them.
2. 8.2 You inform your clients that you use Zolia; the app gives you a notice you can send.
3. 8.3 Before you use Zolia for real client conversations, you confirm the Broker Assurance.
4. 8.4 Do not enter clients of your brokerage in your personal space; they belong in the brokerage's office space. Data that belongs to your brokerage stays with your brokerage when you leave it.
5. 8.5 Do not enter identity documents, health data or other sensitive data unless it is necessary.
6. 8.6 You decide what you send to your clients and what you enter about them, and you are responsible towards your clients for it.

Zolia is software. Biturai L.L.C-FZ, the company behind Zolia, makes the following commitments to every person and every brokerage that uses Zolia:

1. 9.1 We do not broker. We hold no real estate brokerage licence, we do not list, sell or let property, and we do not represent buyers, sellers, landlords or tenants.
2. 9.2 No commission. We do not take a commission, or a share of a commission, on the sale or rental of property. If we charge for a service connected with a transaction, it is a fixed fee and never a share of the price or the rent.
3. 9.3 Your clients stay yours. We do not pass your clients, leads or enquiries to other brokers, brokerages, developers or anyone else, unless you choose to send them (for example to your brokerage, your own CRM or a partner you select), and we never use them to compete with you. Our AI processes them only to provide Zolia to you, and we never sell them.
4. 9.4 No paid rankings. No broker, brokerage, developer, bank or property appears higher in Zolia because someone paid us. If Zolia ever shows paid content, it is clearly marked as advertising and does not change any ranking or search result.
5. 9.5 Equal treatment. What Zolia shows you about the market, properties and other brokers does not depend on which brokerage you work for or which software your brokerage uses.
6. 9.6 Partners in the open. If a partner pays us for a service that you choose to use in Zolia (for example a mortgage calculator), we tell you before you use it. A payment never changes what Zolia shows you about brokers, brokerages or properties.

Changes. We can change this pledge only by announcing the change at least 3 months before it takes effect: in the app, by e-mail to account holders who gave us an e-mail address, and on zolia.ai. A change never applies to the past.