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Data processing agreement

Version of 15 September 2026. Forms part of the terms of service and applies to every customer. An administrator of your agency accepts it inside the CRM the first time they sign in, and we keep a record of who accepted which version and when. If your own procurement requires a signed copy, email hello@sentiracrm.com and we will sign this text.

1. The parties and their roles

Controller: you, the agency with an account. Processor: Nicki Price Real Estate, S.L., VAT ESB21803580, Calle Úbeda 6B, 03193 San Miguel de Salinas (Alicante), Spain.

You decide what personal data goes into the service and why. We process it only to provide the service to you, on your documented instructions, which are these terms plus whatever you do inside the software. If we ever think an instruction breaks data protection law, we will tell you and not act on it.

2. Your data stays yours

Everything your agency puts into the service, and everything the service produces for you, belongs to you: contacts, clients, owners, leads, properties, photographs, documents, notes, tasks, messages and communication history, and the workflows, automations, templates and settings you create. We acquire no rights over any of it. We do not sell it, share it with other customers, use it for our own purposes, or use it to train AI models.

3. What is processed

Subject matterProviding a customer relationship system, an AI assistant, a public website and portal feeds to an estate agency.
DurationFor as long as your account is open, plus the 30 day deletion window.
Nature and purposeStoring, organising, retrieving, transmitting, translating, summarising and erasing data so that you can run your agency.
Types of personal dataName, email, phone, language, country, budget, property interest, the content of enquiries and messages, viewing and appointment records, notes your staff write, deal and commission records, documents you upload, and for your own staff: name, work email, role and sign-in records, and, if you use company cars, when they take and hand back a car and the position of their phone at those two moments.
Categories of data subjectYour clients and prospective clients, property owners and sellers, your own staff, and collaborating agents.
Special category dataNot required by the service and not requested by it. If you choose to type it into a free-text field it will be processed as ordinary content, and that is your decision as controller.

4. Confidentiality

Everyone we allow near customer data is bound to confidentiality, and access is limited to the people who need it to run the service or to answer a support request.

5. Security

We keep appropriate technical and organisational measures, described in full and without embellishment on the trust page. The main ones: per-company scoping of every query in the application, HTTPS on every hostname, hashed passwords, session cookies that are HttpOnly and Secure, origin checks on state-changing requests, rate limits on public endpoints, restricted and neutralised file uploads, hosting in the EU, and daily automatic backups kept on separate storage in the same region.

We do not currently hold ISO 27001 or SOC 2 certification and we do not claim it.

6. Sub-processors

You give general authorisation for us to use sub-processors. The current list, with what each one receives and where it is, is on the trust page and is part of this agreement. If we intend to add or replace one we will email your account administrators at least 30 days beforehand. If you object on reasonable data protection grounds within that period and we cannot offer an alternative, you may cancel the affected part of the service and we will refund the unused part of any prepayment.

Every sub-processor is bound by terms no less protective than these.

7. International transfers

Your data is stored in Germany. Where a sub-processor outside the EEA receives personal data, the transfer is made under the European Commission's standard contractual clauses together with the measures on the trust page. We will give you the relevant details on request.

8. Helping you meet your own obligations

9. Deletion and return

You can export your data yourself, in a machine-readable form (one JSON file, or a spreadsheet per table), at any time while the account is open and for 30 days after it closes. Photographs and uploaded documents are not part of that export today; ask us and we will send them to you. At the end of that window everything is erased from the live system, and it rolls out of backups within the same period. We keep only what the law requires us to keep, which is the invoices we raised to you.

10. Audit

We will make available the information needed to demonstrate that we meet this agreement, and will answer a reasonable security questionnaire once a year at no charge. Where you need more than that, an audit may be carried out once a year, with 30 days' notice, during working hours, by you or an independent auditor bound to confidentiality, in a way that does not disturb other customers, and at your cost unless it finds a material failure by us.

11. Liability and precedence

The liability provisions of the terms of service apply to this agreement. Where this agreement and the terms of service disagree about the processing of personal data, this agreement wins.

12. Contact

Nicki Price Real Estate, S.L., VAT ESB21803580, Calle Úbeda 6B, 03193 San Miguel de Salinas (Alicante), Spain. Email hello@sentiracrm.com.