Manage properties, clients, agents, deals, and finances in one powerful platform.
A real estate–first CRM with the full functionality of a modern business CRM.
To the Public Offer Agreement for providing access to the CRM+ERP system HomexCRM
1. General Provisions
1.1. This Data Processing Agreement (hereinafter — “DPA”) forms an integral part of the Public Offer Agreement (hereinafter — “Agreement”) and applies exclusively to the processing of personal data within the use of the CRM system HomexCRM.
1.2. This DPA governs the processing of personal data in accordance with Regulation (EU) 2016/679 (GDPR) and other applicable data protection laws.
1.3. Within this Agreement:
• the User acts as the Data Controller;
• HomexCRM acts as the Data Processor exclusively with respect to data processed within the CRM system.
2. Subject Matter of Data Processing
2.1. HomexCRM processes personal data solely based on the User’s instructions and for the purpose of providing CRM system functionality.
2.2. Categories of data that may be processed:
• identification data (name, surname);
• contact data (email, phone number);
• customer data of the User;
• transaction, property, and communication data;
• any other data voluntarily entered by the User into the system.
2.3. Categories of data subjects:
• the User’s clients;
• the User’s employees;
• counterparties;
• any other individuals whose data is entered into the system by the User.
3. Roles and Responsibilities
3.1. HomexCRM does not determine the purposes or means of processing personal data and acts solely as a data processor.
3.2. The User is solely responsible for:
• the legality of data collection;
• ensuring lawful basis for processing;
• providing processing instructions;
• the content of data uploaded into the system.
4. Obligations of HomexCRM (Data Processor)
HomexCRM undertakes to:
4.1. Process personal data only according to the User’s instructions.
4.2. Ensure confidentiality of personal data.
4.3. Implement appropriate technical and organizational security measures, including:
• encryption where applicable;
• access control mechanisms;
• data backups;
• protection against unauthorized access.
4.4. Ensure that only authorized personnel have access to personal data.
4.5. Notify the User of any personal data breach without undue delay.
4.6. Provide reasonable assistance to the User in fulfilling GDPR obligations (data subject requests, audits, DPIAs, etc.).
5. Sub-processors
5.1. The User agrees that HomexCRM may engage third-party sub-processors (hosting providers, data centers, infrastructure services).
5.2. All sub-processors are required to maintain an adequate level of data protection in accordance with GDPR.
5.3. HomexCRM may use infrastructure located in the United States of America (USA) and other jurisdictions ensuring appropriate safeguards.
6. International Data Transfers
6.1. The User acknowledges and agrees that personal data may be transferred and stored outside the European Economic Area, including in the United States.
6.2. Such transfers are carried out in compliance with GDPR requirements and appropriate safeguards, including:
• Standard Contractual Clauses (SCC);
• other legally permitted transfer mechanisms.
7. Data Retention and Deletion
7.1. Personal data is processed for the duration of the Agreement.
7.2. Upon termination of the Agreement:
• data is stored for up to 30 calendar days;
• after that period, it may be permanently deleted.
7.3. The User may export their data before deletion.
8. Data Subject Rights
HomexCRM assists the User in fulfilling data subject rights, including:
• right of access;
• right to rectification;
• right to erasure;
• right to restriction of processing;
• right to data portability.
9. Liability
9.1. Each party is responsible for its own role under GDPR.
9.2. HomexCRM is not liable for any GDPR violations resulting from the User’s actions or instructions.
10. Final Provisions
10.1. This Agreement becomes effective upon acceptance of the main Agreement.
10.2. In case of any conflict between this DPA and other provisions of the Agreement regarding data processing, this DPA shall prevail.
10.3. HomexCRM reserves the right to update this DPA in case of changes in legislation or service infrastructure.
11. Contact
For data protection inquiries:
Email: homexcrm.official@gmail.com