PRIVACY POLICY

Last Updated: 4 September 2026

This Privacy Policy (“Policy”) explains how BS Realty OÜ collects, uses, stores, shares and otherwise processes personal data when you use the website bsrealty.eu, its subdomains, accounts, forms, services, tools and other related functionality (collectively, the “Platform”).

This Policy applies to visitors to the Platform, registered users, representatives of real estate agencies, agents, brokers, property developers, advertisers, private property owners and other individuals interacting with BS Realty.

1. DATA CONTROLLER

The controller of personal data is:

BS Realty OÜ
Registry code: 17503538
Registered address: Harju maakond, Kose vald, Tuhala küla, Estonia

Email for privacy-related enquiries:

info@bsrealty.eu

Website:

bsrealty.eu

In this Policy, “BS Realty”, “we”, “us” and “our” refer to BS Realty OÜ.

2. PERSONAL DATA WE MAY PROCESS

Depending on how you use the Platform, BS Realty may process the following categories of personal data.

2.1. Registration and Account Data

When you create or use an account, we may process:

  • first and last name;

  • email address;

  • telephone number;

  • password in a securely protected form;

  • job title;

  • name of the agency, company or property developer;

  • company registration details;

  • business address;

  • professional contact details;

  • language and account preferences;

  • account identifier;

  • account status information.

2.2. Professional User Data

For agencies, brokers, agents, property developers and other professional users, we may also process:

  • company information;

  • registration number;

  • tax information;

  • information concerning professional status;

  • information about representatives of the organisation;

  • documents or information required to verify authority;

  • information required to verify a professional account;

  • subscription information;

  • history of use of professional functionality.

BS Realty may request additional information where reasonably necessary to verify a user’s professional status, prevent fraud or comply with applicable law.

2.3. Property Data

Where a user creates, publishes or submits information about a property, we may process:

  • the address or location of the property;

  • property characteristics;

  • property description;

  • photographs and other media;

  • price information;

  • information about the owner or person representing the owner;

  • contact information;

  • information relating to the sale or rental of the property;

  • other information voluntarily provided through the relevant forms.

Certain information about a property may not itself constitute personal data. However, it may become personal data where it directly or indirectly identifies an individual.

2.4. Enquiry and Lead Data

When a user contacts an agency, broker, agent, property developer or other professional participant through the Platform, we may process:

  • name;

  • email address;

  • telephone number;

  • message content;

  • the property to which the enquiry relates;

  • preferred method of contact;

  • date and time of the enquiry;

  • information regarding interest in buying, selling or renting property;

  • other information voluntarily included in the enquiry.

2.5. Private Property Owner Data

Where a private property owner creates information about a property for the purpose of submitting it to a professional participant in the real estate market, we may process:

  • first and last name;

  • contact details;

  • property information;

  • photographs;

  • property description;

  • proposed or expected price;

  • information concerning the intention to sell or rent the property;

  • enquiry content;

  • other information voluntarily provided.

Private property owners are not entitled to independently publish professional property listings and do not purchase professional BS Realty subscriptions.

2.6. Payment and Billing Data

In connection with paid subscriptions, advertising and additional promotional services purchased by professional users, we may process:

  • details of the service purchased;

  • price;

  • currency;

  • payment date;

  • payment status;

  • invoice number;

  • billing information;

  • tax information;

  • information required for accounting purposes.

Where payments are processed through a third-party payment service provider, payment information may be processed directly by that provider in accordance with its own privacy policy.

BS Realty processes only payment information necessary to provide the relevant service, confirm payment, maintain accounting records and comply with legal obligations.

2.7. Communications with BS Realty

If you contact us, we may retain:

  • your name;

  • contact details;

  • the content of your message;

  • communication history;

  • attached documents;

  • information necessary to respond to your enquiry or complaint.

2.8. Technical Data

When you use the Platform, certain information may be collected automatically, including:

  • Internet Protocol (IP) address;

  • device type;

  • browser type and version;

  • operating system;

  • language;

  • approximate location derived from technical information;

  • date and time of access;

  • pages visited;

  • referring source;

  • technical identifiers;

  • security logs;

  • information about activity on the Platform;

  • cookie and similar technology data.

3. SPECIAL CATEGORIES OF PERSONAL DATA

BS Realty is not intended to collect special categories of personal data, such as health information, religious or political beliefs, biometric data or other specially protected information, unless such processing is required by law or by a specific lawful situation.

Users should not include such information in property descriptions, messages, enquiries or other materials unless it is necessary.

4. SOURCES OF PERSONAL DATA

We may obtain personal data:

  • directly from you;

  • when you create an account;

  • when you complete forms on the Platform;

  • when you submit an enquiry concerning a property;

  • when you submit property information;

  • when you use a professional account;

  • through communications with BS Realty;

  • from the organisation you represent;

  • from a professional user where necessary for Platform functionality;

  • automatically when you use the Platform;

  • from lawfully available sources where permitted by applicable law.

5. PURPOSES AND LEGAL BASES FOR PROCESSING

BS Realty processes personal data only where an appropriate legal basis applies.

5.1. Providing the Platform and User Accounts

We process data to:

  • register users;

  • create and maintain accounts;

  • provide professional functionality;

  • publish and manage listings;

  • fulfil user requests;

  • operate the Platform.

The legal basis may be the performance of a contract or taking steps at the user’s request prior to entering into a contract.

5.2. Transmitting an Enquiry to a Professional Participant

Where a user independently submits an enquiry concerning a specific property or professional participant, BS Realty processes the necessary data in order to technically transmit the enquiry to the relevant recipient.

BS Realty does not distribute such enquiries among agencies, agents, brokers or property developers and does not decide which professional participant should receive a particular lead where the recipient is determined by the selected property, professional participant or the user’s own action.

After the enquiry has been transmitted, the relevant professional participant may act as an independent controller of personal data in relation to subsequent communications with the user.

5.3. Submission of Information by a Private Property Owner

Where a private property owner uses functionality provided by the Platform to submit information about a property to a professional participant, BS Realty processes the data only to the extent necessary to provide that functionality.

BS Realty does not distribute such submissions among professional participants and does not determine which agency, broker, agent or property developer should accept a particular property where the selection or direction is determined by the user through the functionality of the Platform.

5.4. Paid Services

We may process data for:

  • arranging subscriptions;

  • managing subscriptions;

  • providing paid promotion;

  • providing advertising services;

  • processing payments;

  • issuing invoices;

  • accounting and tax purposes.

The legal bases include performance of a contract and compliance with BS Realty’s legal obligations.

5.5. Security and Prevention of Abuse

We may process data to:

  • maintain account security;

  • detect fraud;

  • prevent unauthorised access;

  • protect the Platform;

  • investigate violations;

  • prevent automated abuse;

  • protect the rights of BS Realty, users and third parties.

The legal bases may include BS Realty’s legitimate interests and compliance with legal obligations.

5.6. Moderation and Enforcement of Platform Rules

We may use data to:

  • review listings;

  • investigate complaints;

  • identify violations of the Terms of Use;

  • suspend or terminate accounts;

  • process reports of illegal content;

  • comply with requirements of competent authorities.

The legal bases may include BS Realty’s legitimate interests and compliance with legal obligations.

5.7. Improving the Platform

We may analyse use of the Platform to:

  • improve functionality;

  • resolve technical issues;

  • analyse performance;

  • develop the user interface;

  • improve search quality;

  • prevent abuse.

Such processing is based on BS Realty’s legitimate interests or the user’s consent where consent is required by law.

5.8. Marketing Communications

BS Realty may send promotional or marketing communications only where an appropriate legal basis exists.

Where prior consent is required by applicable law, such communications will be sent only after consent has been obtained.

Users may opt out of marketing communications at any time by using the unsubscribe mechanism provided in the communication or by contacting BS Realty.

Opting out of marketing communications does not prevent BS Realty from sending necessary service communications relating to an account, security, payment or use of the Platform.

5.9. Compliance with Legal Obligations

We may process and retain information where necessary for:

  • accounting;

  • tax requirements;

  • compliance with judicial or administrative orders;

  • compliance with applicable law;

  • establishment, exercise or defence of legal claims;

  • cooperation with competent public authorities.

6. LEGITIMATE INTERESTS OF BS REALTY

Where processing is based on legitimate interests, such interests may include:

  • operating and developing the Platform;

  • maintaining information security;

  • preventing fraud;

  • protecting accounts;

  • maintaining listing quality;

  • protecting BS Realty’s rights and property;

  • protecting users;

  • preventing abuse;

  • improving services;

  • ensuring efficient business operations.

Before relying on this legal basis, BS Realty considers the necessity of the processing, the nature of the information and the rights and interests of affected individuals.

7. RECIPIENTS OF PERSONAL DATA

BS Realty does not sell users’ personal data as a standalone commercial product.

Depending on the functionality used, personal data may be disclosed to the following categories of recipients.

7.1. Agencies, Agents, Brokers and Property Developers

Where a user independently submits an enquiry concerning a particular property or professional participant, the necessary information is transmitted to the relevant recipient.

After receiving the enquiry, the professional participant is independently responsible for its subsequent use of the personal data in accordance with applicable law.

7.2. Professional Participant Receiving a Property Submission

Where a private property owner initiates the submission of information about a property through the relevant Platform functionality, the information is transmitted to the professional participant to whom the user directs it.

BS Realty does not distribute such a submission among professional participants where the recipient is determined by the user through the functionality of the Platform.

7.3. Technical Service Providers

For the operation of the Platform, data may be processed by providers of:

  • server infrastructure;

  • cloud services;

  • email services;

  • information security services;

  • technical support;

  • analytics;

  • data storage systems;

  • software used to operate the Platform.

Such providers receive access only to information necessary to perform the relevant functions and must process data in accordance with applicable contractual and legal requirements.

7.4. Payment Providers

Information necessary to process payments may be shared with banks, payment institutions and payment service providers.

7.5. Professional Advisers

Where necessary, information may be shared with:

  • auditors;

  • accountants;

  • lawyers;

  • tax advisers;

  • insurers;

  • other professional advisers.

7.6. Public Authorities

BS Realty may disclose data to public authorities, courts, law enforcement authorities and other competent bodies where disclosure is required by law or pursuant to a valid binding order.

7.7. Corporate Transactions

In connection with a reorganisation, merger, sale of business, acquisition, financing or transfer of relevant assets, personal data may be disclosed to a prospective or actual participant in such transaction subject to applicable law.

8. BS REALTY’S ROLE AFTER TRANSMISSION OF AN ENQUIRY

Where a user independently sends an enquiry to a particular professional participant, BS Realty provides the technical means for transmitting that enquiry.

BS Realty does not control subsequent correspondence, telephone calls, meetings, negotiations or relationships between the user and the professional participant receiving the enquiry.

After receiving the information, the relevant agency, agent, broker, property developer or other organisation may independently determine the purposes and means of further processing and may therefore have its own responsibilities as an independent data controller.

Users may contact the relevant professional participant directly regarding the subsequent use of personal data transmitted to it.

9. INTERNATIONAL TRANSFERS OF PERSONAL DATA

BS Realty is an Estonian company and the Platform serves an international real estate market.

Professional participants, properties and service providers may be located both within and outside the European Economic Area (“EEA”), including in the United Kingdom, United Arab Emirates, Türkiye and other countries.

As a result, personal data may in certain circumstances be transferred to or accessed from outside the EEA.

Where European Union data protection requirements apply to such a transfer, BS Realty uses a transfer mechanism permitted by applicable law, which may include:

  • an adequacy decision adopted by the European Commission;

  • Standard Contractual Clauses approved by the European Commission;

  • other appropriate safeguards recognised by applicable law;

  • a lawful derogation applicable to the specific circumstances, where such derogation is validly available.

Where a user independently requests that an enquiry be transmitted to a professional participant located outside the EEA, fulfilling that request may require an international transfer of the personal data provided by the user.

Where United Kingdom data protection law applies, international transfers will be handled using mechanisms recognised under applicable UK data protection law.

Users may contact BS Realty for additional information concerning applicable transfer safeguards.

10. DATA RETENTION

BS Realty retains personal data only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required by law.

When determining retention periods, we consider:

  • the duration of the user’s relationship with BS Realty;

  • whether an account remains active;

  • the nature of the service provided;

  • contractual obligations;

  • accounting and tax retention requirements;

  • the need to handle complaints;

  • applicable limitation periods;

  • security requirements;

  • BS Realty’s legal obligations.

Account data may be retained for the duration of the account and, following closure, for the period necessary to comply with legal obligations, resolve disputes and protect legitimate interests.

Financial and accounting records are retained for the period required by applicable law.

Enquiry data may be retained for a period reasonably necessary to transmit and confirm processing of the relevant request and for security, dispute resolution and legal compliance purposes.

After the applicable retention period expires, information is deleted, anonymised or otherwise removed from active use unless continued retention is required by law.

11. SECURITY OF PERSONAL DATA

BS Realty implements appropriate technical and organisational measures designed to protect personal data against:

  • unauthorised access;

  • unlawful use;

  • alteration;

  • disclosure;

  • accidental loss;

  • destruction;

  • other unlawful processing.

Security measures are selected taking into account the nature of the information processed, relevant risks, available technology and the nature of the Platform.

However, no method of transmitting or storing data can provide absolute security.

Users are also responsible for maintaining the confidentiality of their account credentials and should promptly notify BS Realty if they suspect unauthorised access to an account.

12. YOUR DATA PROTECTION RIGHTS

Where the General Data Protection Regulation (“GDPR”) or other legislation providing equivalent rights applies, you may have the right to:

  • receive information about the processing of your personal data;

  • access your personal data;

  • request correction of inaccurate personal data;

  • request completion of incomplete personal data;

  • request deletion of personal data;

  • request restriction of processing;

  • object to certain processing;

  • receive personal data in a portable format where the right to data portability applies;

  • withdraw previously provided consent;

  • lodge a complaint with a competent supervisory authority;

  • exercise rights relating to automated decision-making where applicable.

These rights are not absolute. In certain circumstances, applicable law may permit or require BS Realty to continue processing personal data despite a request from the user.

13. HOW TO EXERCISE YOUR RIGHTS

To exercise your rights or request information concerning the processing of your personal data, please contact:

info@bsrealty.eu

BS Realty may request reasonable information necessary to verify the identity of the person making the request before providing personal data or acting on the request.

Requests will be handled within the time limits required by applicable law.

14. WITHDRAWAL OF CONSENT

Where processing is based on consent, you may withdraw your consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Withdrawal of consent also does not prevent continued processing where another lawful basis applies.

15. RIGHT TO OBJECT

Where processing is based on the legitimate interests of BS Realty or a third party, you may object to such processing in circumstances provided by applicable law.

Where personal data is processed for direct marketing purposes, you have the right to object to such processing at any time.

Following a valid objection to direct marketing, personal data will no longer be processed for that purpose.

16. AUTOMATED DECISION-MAKING

BS Realty may use automated technical processes for search, sorting, display of listings, security, detection of suspicious activity and operation of the Platform.

BS Realty does not make decisions based solely on automated processing that produce legal effects concerning an individual or similarly significantly affect an individual, unless otherwise expressly disclosed to the user and permitted by applicable law.

17. COOKIES AND SIMILAR TECHNOLOGIES

BS Realty may use cookies and similar technologies for:

  • essential Platform functionality;

  • authentication;

  • security;

  • storing user preferences;

  • website analytics;

  • statistics;

  • improving the Platform;

  • advertising, where permitted by law and subject to any required consent.

Non-essential cookies and similar technologies are used on the basis of user consent where such consent is required by law.

Further information about categories of cookies, their duration and available controls is provided in the separate Cookie Policy and the relevant consent management interface.

18. ADVERTISING

The Platform may display advertising from banks, financing providers, property developers, real estate businesses and other advertisers.

The presence of advertising does not by itself mean that BS Realty provides the advertiser with personal data relating to a particular user.

Where personal data, identifiers or non-essential cookies are used for personalised advertising, such processing will take place only where an appropriate legal basis exists and, where required by law, after obtaining the user’s consent.

19. THIRD-PARTY WEBSITES AND SERVICES

The Platform may contain links to third-party websites and services.

BS Realty does not determine how personal data is processed on independent third-party websites.

Users should review the privacy policy of the relevant third party before providing personal data to it.

20. PROFESSIONAL USERS AS INDEPENDENT CONTROLLERS

Real estate agencies, brokers, agents, property developers and other professional users may independently act as controllers of personal data received through the Platform.

Such professional users are independently responsible for:

  • establishing a lawful basis for further processing;

  • providing required privacy information to individuals;

  • protecting the security of personal data received;

  • complying with applicable retention requirements;

  • handling data subject requests;

  • ensuring the lawfulness of marketing communications;

  • complying with international data transfer requirements where applicable.

This Policy does not replace the privacy policy of the relevant professional user.

21. CHILDREN’S DATA

BS Realty professional accounts are not intended for children.

A person who does not have the legal capacity required under applicable law to enter into the relevant agreement should not independently create a professional account or purchase paid professional services.

If BS Realty becomes aware that personal data relating to a child has been obtained in violation of applicable law, appropriate measures will be taken.

22. LEGAL REQUIREMENTS AND PROTECTION OF RIGHTS

BS Realty may process, retain or disclose information where reasonably necessary to:

  • comply with applicable law;

  • comply with a court order;

  • comply with a lawful request from a competent authority;

  • investigate fraud;

  • maintain security;

  • protect BS Realty’s rights;

  • protect users;

  • establish, exercise or defend legal claims.

23. CHANGES IN CORPORATE STRUCTURE

If BS Realty is involved in a reorganisation, merger, acquisition, sale of assets or other corporate transaction, personal data relating to the business may be transferred as part of that transaction subject to applicable legal requirements.

Where appropriate, users will be informed of a material change in the identity of the controller or the manner in which their personal data is processed.

24. SUPERVISORY AUTHORITY

As BS Realty OÜ is established in Estonia, individuals may contact the competent Estonian data protection supervisory authority regarding matters concerning the protection of personal data in accordance with applicable law.

This does not limit an individual’s right to lodge a complaint with another competent supervisory authority where such right is available under applicable law.

25. CHANGES TO THIS PRIVACY POLICY

BS Realty may amend this Policy from time to time, including as a result of:

  • changes to the Platform;

  • introduction of new functionality;

  • changes in technologies used;

  • changes in data processing practices;

  • changes in applicable law;

  • requirements of supervisory authorities.

The current version will be published at:

bsrealty.eu/privacy

The date of the latest update will be stated at the beginning of this Policy.

Where a change materially affects the processing of personal data and applicable law requires additional notice, BS Realty will provide such notice in an appropriate manner.