Data Processing Addendum
Last updated: August 2026
This Data Processing Addendum (“DPA”) forms part of the agreement between the business customer (“Controller”) and Willems, Marnicq, trading as Real Estate Pro (“Processor”), for personal data the Controller submits through the Service.
This DPA applies only to personal data processed by Real Estate Pro on behalf of the business customer within Customer Content and projects. Account administration, billing, tax, fraud/security and Real Estate Pro's own legal compliance may be processed by Real Estate Pro as an independent controller, as described in the Privacy Policy.
Subject matter and duration
Processing of personal data contained in content and account data submitted by the Controller, for the duration of the customer’s use of the Service and any legally required retention period thereafter.
Nature and purpose of processing
Hosting, storing and processing uploaded media and related data to generate and deliver real-estate marketing videos and to operate, secure and support the Service.
Categories of personal data
Identity/contact data of the Controller’s users, and any personal data contained in uploaded property media or project information (for example individuals incidentally depicted).
Categories of data subjects
The Controller’s staff/users and any individuals whose personal data appears in the Controller’s uploaded content.
Processor obligations
- Process personal data only on the Controller’s documented instructions, including for transfers, unless required by law.
- Ensure persons authorised to process the data are bound by confidentiality.
- Implement appropriate technical and organisational security measures.
- Assist the Controller, insofar as possible, with data-subject requests.
- Assist with security, breach notification, and data-protection impact assessments as applicable.
- Delete or return personal data at the end of the services, subject to legal retention obligations.
- Make available information necessary to demonstrate compliance and allow for audits within reasonable, agreed limits.
Processing required by law
Where Real Estate Pro is required by law to process Customer Personal Data contrary to the Controller’s documented instructions, Real Estate Pro will inform the Controller of that legal requirement before processing, unless the law prohibits such information.
Subprocessors
The Controller gives a general written authorisation for the use of subprocessors. Accordingly:
- Real Estate Pro may engage subprocessors that are necessary to provide the Service.
- Such subprocessors must be subject to appropriate data-protection obligations.
- Real Estate Pro will provide business customers with information about relevant subprocessors on legitimate request.
- Real Estate Pro will provide reasonable advance notice of an intended addition or replacement of a subprocessor that processes Customer Personal Data.
- The Controller may object on reasonable, documented data-protection grounds before the change takes effect, and the parties will work in good faith to resolve the objection.
Confidential implementation details are not published in the ordinary customer interface and are available on legitimate request where appropriate.
International transfers
Any transfer outside the EEA occurs only under an applicable lawful transfer basis and appropriate safeguards.
Deletion / return
At the end of the relevant processing services, at the Controller’s choice and where technically feasible, Real Estate Pro will delete or return Customer Personal Data and delete existing copies, unless applicable law requires continued storage.
Audits
Real Estate Pro will make available the information necessary to demonstrate compliance with Article 28 GDPR and permit reasonable audits and inspections by the Controller or an independent auditor mandated by the Controller, subject to reasonable prior notice, confidentiality obligations, and measures to avoid unnecessary disruption. These practical safeguards will not be used to prevent a legally required audit.
Breach assistance
The Processor will inform the Controller without undue delay after becoming aware of a personal-data breach affecting the Controller’s data and will provide reasonable assistance.
Contact
Data-processing queries: realestatepro.be@gmail.com.
Real Estate Pro
Operated by Willems, Marnicq
Enterprise number 1.036.429.459 · VAT BE1036429459
Schaapsvijver 20, 3200 Aarschot, Belgium
