DATA PROCESSING AGREEMENT (DPA)

Effective Date: March 19, 2026
Last Updated: March 19, 2026

This Data Processing Agreement (“Agreement” or “DPA”) is entered into by and between EffortlessAI, LLC d/b/a Effortless Realtor (“Processor”) and the customer entity agreeing to the Effortless Realtor Terms and Conditions (“Controller”). This DPA forms part of the Terms and Conditions and governs Effortless Realtor’s processing of personal data on behalf of the Controller.

1. Definitions

• “Personal Data” means any information relating to an identified or identifiable natural person.

• “Processing” has the meaning given in GDPR Art. 4(2).

• “Applicable Data Protection Laws” means all applicable laws relating to data protection, including the GDPR, UK GDPR, CCPA/CPRA, and any other relevant frameworks.

• “Sub-processor” means any third party engaged by Effortless Realtor to process Personal Data on behalf of the Controller.

2. Roles of the Parties

2.1 Controller. Controller determines the purposes and means of the processing of Personal Data.

2.2 Processor. Effortless Realtor acts as Processor and shall process Personal Data only on documented instructions from Controller, including with respect to transfers of Personal Data to a third country.

3. Obligations of Processor

Effortless Realtor shall:

• Process Personal Data solely for the purpose of providing the Service and in accordance with Controller’s instructions.

• Ensure persons authorized to process Personal Data are bound by confidentiality.

• Implement appropriate technical and organizational measures to protect Personal Data as required by GDPR Art. 32.

• Assist Controller, at Controller’s expense, with data subject rights requests.

• Notify Controller without undue delay of any data breach affecting Personal Data.

• Make available to Controller information necessary to demonstrate compliance and allow for audits by Controller or a mutually agreed third party, subject to reasonable notice and confidentiality obligations.

4. Sub-processors

4.1 Effortless Realtor may engage Sub-processors. Current Sub-processors are listed at www.effortlessrealtor.com/subprocessors

4.2 Effortless Realtor shall provide advance notice of any intended changes. Controller may object on reasonable grounds; if unresolved, Controller may terminate the affected Service.

5. International Transfers

Where Effortless Realtor transfers Personal Data outside the European Economic Area, United Kingdom, or other jurisdictions requiring safeguards, such transfers shall be subject to:

• The EU Standard Contractual Clauses (SCCs) (Module 2 for controller-to-processor, Module 3 for processor-to-processor), as updated by the European Commission.

• The UK International Data Transfer Addendum (IDTA) or equivalent safeguard for UK transfers.

6. Data Retention and Deletion

Upon termination or expiration of the Service, Effortless Realtor shall, at Controller’s choice, delete or return all Personal Data, unless retention is required by law. If returned, Controller is responsible for secure deletion thereafter.

7. Audit Rights

Controller may, once annually and with at least thirty (30) days’ written notice, conduct an audit of Effortless Realtor’s compliance with this DPA. Audits shall be limited to what is reasonably necessary, conducted during normal business hours, and subject to confidentiality. Effortless Realtor may satisfy audit requirements by providing independent third-party audit reports (e.g., SOC 2, ISO 27001).

8. Liability

Liability under this DPA is subject to the limitations of liability set forth in the Terms and Conditions.

9. Governing Law

This DPA shall be governed by and construed under the same law and jurisdiction as the Terms and Conditions, unless otherwise required by Applicable Data Protection Laws.

10. Entire Agreement

This DPA, together with the Terms and Conditions and Privacy Policy, constitutes the entire agreement between the parties regarding data processing.

11. Contact

For questions regarding this DPA, please contact:

info@effortlessrealtor.com
Effortless Realtor – 81 Broadway St. Suite 201, Asheville, NC 28801