Data Processing Agreement

[ DATA PROCESSING ADDENDUM (DPA) Effective Date: [08/01/2026] This Data Processing Addendum ("DPA") forms part of the Terms of Service between VIA BOCA LLC ("Company," "Controller," "we," "our") and the customer or organization using Estate Scorer ("Customer"). This DPA applies whenever personal data subject to the GDPR, UK GDPR, or similar data protection laws is processed through the Estate Scorer platform. ________________________________________ 1. Definitions For purposes of this DPA: • Controller means the entity determining the purposes and means of processing personal data. • Processor means the entity processing personal data on behalf of the Controller. • Personal Data means information relating to an identified or identifiable natural person. • Processing includes collecting, recording, organizing, storing, adapting, retrieving, using, disclosing, transmitting, restricting, deleting, or destroying personal data. • Applicable Data Protection Law means the GDPR, UK GDPR, and any other applicable privacy legislation. ________________________________________ 2. Scope This DPA governs processing performed through Estate Scorer when personal data is processed on behalf of Customers. Where the Customer determines the purposes and means of processing, the Customer acts as Controller and VIA BOCA LLC acts as Processor for those processing activities. For personal data collected directly by VIA BOCA LLC for its own business purposes, VIA BOCA LLC acts as an independent Controller. ________________________________________ 3. Nature of Processing Processing may include: • collection of account information; • property-related information; • user-submitted questionnaire responses; • AI-assisted report generation; • customer support communications; • payment administration; • fraud detection; • security monitoring; • analytics; • cloud storage; • backup and disaster recovery. ________________________________________ 4. Categories of Personal Data Depending upon use of Estate Scorer, processing may include: • names; • email addresses; • account identifiers; • IP addresses; • billing metadata; • property addresses; • questionnaire responses; • usage information; • support communications; • subscription information. Estate Scorer is not intended for the routine processing of special categories of personal data under Article 9 GDPR. Users should not submit unnecessary sensitive personal information. ________________________________________ 5. Processing Instructions VIA BOCA LLC shall process personal data only: • pursuant to documented instructions from the Customer; • as necessary to provide the Service; • to comply with applicable law; • to protect the security and integrity of the platform. If applicable law requires processing beyond Customer instructions, VIA BOCA LLC will notify the Customer unless prohibited by law. ________________________________________ 6. Confidentiality VIA BOCA LLC shall ensure that personnel with access to personal data are bound by confidentiality obligations or are subject to appropriate statutory duties of confidentiality. Access shall be limited to individuals with a legitimate business need. ________________________________________ 7. Security Measures VIA BOCA LLC implements commercially reasonable technical and organizational measures designed to protect personal data. Security measures may include: • encryption in transit using TLS; • encryption at rest where appropriate; • role-based access controls; • authentication requirements; • least-privilege access; • audit logging; • infrastructure monitoring; • vulnerability management; • incident response procedures; • secure cloud hosting. No security measure can guarantee absolute protection. ________________________________________ 8. Subprocessors The Customer authorizes VIA BOCA LLC to engage subprocessors necessary for operation of Estate Scorer. Examples may include providers for: • cloud infrastructure; • payment processing; • artificial intelligence services; • customer support; • fraud detection; • analytics; • email delivery; • monitoring; • backups. VIA BOCA LLC shall require subprocessors to maintain contractual obligations appropriate to the services they perform. ________________________________________ 9. International Transfers Personal data may be processed in the United States and other jurisdictions where VIA BOCA LLC or its service providers operate. Where required by applicable law, transfers shall be supported through appropriate safeguards such as: • Standard Contractual Clauses (SCCs); • adequacy decisions; • other lawful transfer mechanisms. ________________________________________ 10. Data Subject Requests Where legally required and technically feasible, VIA BOCA LLC shall provide reasonable assistance to Customers in responding to requests involving: • access; • correction; • deletion; • portability; • restriction; • objection. The Customer remains responsible for responding to data subjects unless otherwise agreed. ________________________________________ 11. Security Incidents If VIA BOCA LLC becomes aware of a confirmed personal data breach affecting Customer data, the Company shall, without undue delay and where required by applicable law: • investigate the incident; • contain the event; • mitigate potential harm; • notify affected Customers where legally required; • cooperate in responding to regulatory obligations. Notification does not constitute an admission of fault or liability. ________________________________________ 12. Return or Deletion Upon termination of Services and subject to applicable law, VIA BOCA LLC may delete or anonymize Customer personal data after expiration of applicable retention periods. Backup copies may temporarily remain within secure disaster recovery systems until overwritten during ordinary retention cycles. ________________________________________ 13. Audits To the extent required by applicable law, VIA BOCA LLC may provide reasonable information demonstrating compliance with this DPA. The Company may satisfy audit obligations through: • independent audit reports; • security certifications; • compliance documentation; • written responses. Physical on-site audits are subject to reasonable notice, confidentiality protections, and operational limitations. ________________________________________ 14. Liability This DPA is subject to the liability limitations contained within the Estate Scorer Terms of Service. Nothing in this DPA expands liability beyond those agreed contractual limitations except where prohibited by applicable law. ________________________________________ END DATA PROCESSING ADDENDUM ________________________________________ AI TRANSPARENCY STATEMENT Effective Date: [08/01/2026] VIA BOCA LLC is committed to transparency regarding the use of artificial intelligence within Estate Scorer. ________________________________________ 1. Purpose Estate Scorer uses artificial intelligence to help users analyze residential real estate information and generate informational reports intended to support—but not replace—human decision-making. AI assists in organizing, summarizing, evaluating, and presenting information more efficiently. ________________________________________ 2. How AI Is Used Artificial intelligence may be used to: • summarize property characteristics; • explain market indicators; • generate written report sections; • identify potential considerations; • organize available information; • score certain factors according to proprietary methodologies; • produce educational explanations. AI assists in preparing reports but does not independently approve or reject transactions. ________________________________________ 3. Human Responsibility Users remain solely responsible for all decisions based upon Estate Scorer Reports. The Company does not make decisions regarding: • whether to purchase a property; • whether financing should be obtained; • whether an offer should be submitted; • whether insurance should be purchased; • whether a transaction should proceed. Professional judgment remains essential. ________________________________________ 4. AI Limitations Artificial intelligence has significant limitations. Outputs may: • contain factual errors; • omit relevant information; • misinterpret user input; • reflect outdated data; • produce inconsistent responses; • misunderstand property-specific circumstances. AI cannot independently inspect a property, verify legal ownership, detect hidden defects, predict future events, or guarantee investment outcomes. ________________________________________ 5. Data Sources Estate Scorer combines user-provided information with data obtained from trusted third-party sources where available. Such sources may include public records, economic datasets, mapping services, and other information providers. Availability and accuracy of third-party information may vary. ________________________________________ 6. Third-Party AI Providers Estate Scorer may utilize third-party AI technologies supplied by trusted vendors to generate reports and related content. Those providers process information solely to perform requested AI services, subject to contractual obligations and applicable law. The specific AI model or provider may change over time as technology evolves. ________________________________________ 7. Continuous Improvement VIA BOCA LLC continually evaluates and improves Estate Scorer's AI systems. This may include: • refining prompts; • adjusting scoring methodologies; • improving report quality; • reducing inaccuracies; • enhancing safety mechanisms; • improving consistency. Updates may change the structure or wording of reports without prior notice. ________________________________________ 8. Fairness Estate Scorer is designed to assist users without intentionally discriminating on the basis of legally protected characteristics. Users should not rely on AI-generated outputs to make decisions that violate applicable anti-discrimination laws, including fair housing requirements. ________________________________________ 9. Transparency Where practical, Estate Scorer seeks to distinguish AI-generated analyses from factual information obtained from external sources. Users should independently verify material facts before relying on any report. ________________________________________ 10. No Professional Advice AI-generated content does not constitute: • legal advice; • financial advice; • investment advice; • mortgage advice; • appraisal services; • engineering opinions; • inspection reports; • insurance recommendations; • tax advice. Qualified professionals should be consulted where appropriate. ________________________________________ 11. User Feedback Users are encouraged to report suspected inaccuracies, technical issues, or misleading AI outputs. Feedback helps improve future versions of Estate Scorer but does not guarantee immediate corrections. ________________________________________ 12. Future Development Artificial intelligence technologies continue to evolve. Estate Scorer may introduce new AI capabilities, retire existing models, or integrate additional providers to improve service quality, security, efficiency, or reliability. Material changes may be reflected through updates to this Statement or other legal documentation. ]