Effective Date: 06.06.2025

This Agreement is between:

Flooz Inc., a Delaware corporation with an address at 8605 Santa Monica Blvd, PMB 94419, West Hollywood, California 90069-4109 (“Processor”),

and

Any user or entity using the Reel Estate service and acting as a data controller (“Controller”).

This Data Processing Agreement supplements the Terms of Service and reflects the parties’ agreement regarding the processing of personal data in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR) and the UK GDPR.

1. Subject Matter

This Agreement governs the processing of personal data submitted to the Reel Estate platform by the Controller for the purpose of generating video content based on property listings.

2. Roles and Responsibilities

• The Controller determines the purpose and means of personal data processing (e.g., submitting property links and generating video content).

• The Processor processes personal data solely to deliver the services requested by the Controller.

• The Processor will not process personal data for any other purpose.

3. Types of Personal Data Processed

The following categories of personal data may be processed:

• First name, last name, profile photo, and email (via Google SSO)

• Uploaded or extracted media (images from listing URLs, voice recordings, selfie videos)

• Payment status metadata (processed by Stripe, not stored directly)

• IP address, general location, device data, and usage behavior (via analytics tools)

No special category data is intentionally collected.

4. Subprocessors

The Controller agrees that the Processor may use the following subprocessors:

• Google Cloud (infrastructure and storage)

• Vercel (frontend and web hosting)

• Stripe (payment processing)

• Google Analytics (performance tracking)

• Chatbase (customer support automation, pending integration)

All subprocessors are subject to data processing agreements with Flooz Inc. and provide adequate safeguards.

5. International Data Transfers

Personal data may be transferred outside the EEA or UK (e.g., to the United States) as part of hosting, analytics, or support services. The Processor ensures such transfers rely on lawful mechanisms, including Standard Contractual Clauses (SCCs), and industry-standard security protocols.

6. Security Measures

The Processor shall implement appropriate technical and organizational measures to protect personal data, including but not limited to:

• Encryption in transit and at rest

• Secure data storage on Google Cloud infrastructure

• Access control and monitoring

• TLS/SSL certificates for all data transmission

7. Data Retention and Deletion

• Raw asset data (such as voice recordings and source images) will be automatically deleted after 30 days.

• Final video outputs may be retained indefinitely unless deletion is requested.

• Upon written request, the Processor will delete any personal data relating to a user within 30 days.

Requests should be sent to: hi@reel-estate.ai

8. Assistance and Data Subject Rights

The Processor shall assist the Controller in complying with obligations under data protection laws, including:

• Responding to data access or deletion requests

• Cooperating with supervisory authorities

• Notifying the Controller of any data breach affecting personal data

9. Audit Rights

Upon written request, the Processor shall provide information necessary to demonstrate compliance with this DPA. Audits may be performed no more than once per year and must be limited in scope to the processing activities under this Agreement.

10. Term and Termination

This DPA remains in effect for as long as the Controller uses the Service. Upon termination, the Processor will delete or return personal data unless required to retain it by law.

11. Governing Law and Jurisdiction

This DPA is governed by the laws of the State of Delaware, United States. Any disputes arising from or related to this Agreement shall be resolved through the arbitration clause outlined in the Terms of Service.

12. Acceptance

By using the Reel Estate platform, the Controller accepts this Data Processing Agreement as legally binding.

For questions or DPA-specific inquiries, contact: hi@reel-estate.ai