Realenza

Realenza — Privacy policy

Last updated: 26 October 2026

Realenza is a closed professional network for licensed real-estate agencies and brokers. This policy explains what personal data we process, why, on what legal basis, who else sees it and how long we keep it.

It is written for two audiences: the people who use the platform on behalf of a member organization, and anyone who opens a client link that a broker has sent them. If you are in the second group, section 8 is the part written for you.


1. Who is responsible for your data

The controller of the personal data described in this policy is:

Company
[REALENZA d.o.o. — in formation]
Registered office
[street and number], [postal code] [city], Croatia
OIB (tax number)
[OIB]
Court register number (MBS)
[MBS]
E-mail for privacy matters
info@realenza.com

The entries in square brackets are completed once the incorporation of the company is finalised, and this page is updated at the same time.

We have not appointed a data protection officer, because we are not required to. Privacy questions and requests go to info@realenza.com and are handled by the management.


2. Scope, and what is deliberately not here

Realenza is a business platform. Almost all the personal data in it is professional contact data of people acting for a company: a name, a work e-mail address, a work telephone number, a brokerage licence number, and a record of what they did in the system.

Three things are deliberately absent by design, and they shape everything that follows:

  • Property owners. The platform has no field for the name, telephone number, e-mail address or any other detail of a property owner, and Members are contractually forbidden from writing such data into listing texts. We never ask for it and we do not want it.
  • The end client. A broker sends the client link outside the platform — by e-mail, by messenger, in person. We do not create an account for the client, we do not ask who they are, and we never learn their name or contact details from the platform. The only exception is the private label the broker may type for its own reference (see section 3), which the broker alone sees.
  • Payment data. We take payment by bank transfer against an invoice only. There is no card form, no payment service provider and no stored payment credential anywhere in the platform.

This policy does not cover how a Member handles the personal data of its own clients. That is the Member own responsibility, under its own privacy notice.


3. What we process

Organization data
Company name, legal form, VAT number or OIB, court register number, brokerage-register number and the link to that entry, address, postal code, city, country, telephone, e-mail, website, logo, the roles enabled (listing agency, broker), status, partner tier, the date of verification and which administrator verified it, our internal administrative notes, and the date the pilot period ends.
User account data
E-mail address (which is also the login), the password stored only as an Argon2 hash and never in readable form, first and last name, telephone number, agent licence number, role and organization-administrator flag, account status, chosen interface language, and the time of the last sign-in.
Authentication data
Refresh tokens, stored only as hashes, each with the IP address and browser identification of the session in which it was issued; password-reset and invitation tokens, likewise stored only as hashes, valid for 30 minutes and 72 hours respectively.
Listing content
Everything the agency enters about a property: titles and descriptions, price, areas, rooms, floors, year of construction and renovation, condition, features, location, street address and coordinates, mandate type and validity, co-broke commission and the note attached to it, photographs and video. Photographs are re-encoded when they are uploaded, which removes embedded metadata including any GPS coordinates from the camera.
Inquiries
The message threads between a broker and a listing agency: the sender, the organization, the time, the text of each message and the time it was read. The platform also writes system entries into a thread recording that an exact location was shared or withdrawn.
Location grants
Which organization was granted the exact location of which listing, by which user, from which thread, when it was granted and when it was revoked.
Client links
The listing or the selection shared, the broker organization and user who created it, the chosen page language, the validity date, the optional private label the broker typed to remember which client the link was for, the view counter, the time of the last view, and the time of revocation. For each opening of the page we additionally store the time, the visitor IP address and the browser identification (see section 8).
Counters
How many brokers opened a listing, how many client links were generated for it, and how many inquiries it received. These are aggregate numbers; no Member ever sees the identity of another Member client.
Audit trail
A security record of significant actions — sign-ins and failed sign-ins, listing views, creation and change of listings, inquiries, creation and revocation of client links and of location grants, creation and revocation of API keys, and administrative decisions such as approval, rejection or suspension. Each record holds the acting user, organization and role, the action, the record concerned, the time, the IP address, the browser identification and a small structured detail record.
API keys and their use
The key name, its visible prefix and its hash — never the key itself, which is displayed once and cannot be read again by anyone including us — the scopes granted, the rate limit, the times of creation, last use and revocation, and a per-day count of requests.
E-mail log
For each message the system sends: the recipient address, which template was used, the subject, whether delivery succeeded, and the error if it did not.
Billing records
Plan and period records, the price, and the reference of the invoice issued outside the platform.
Technical logs
Web and application server logs on our infrastructure, which contain the IP address, the request and the time.

We do not process special categories of personal data, and Members must not upload them.


4. Where the data comes from

Most of it comes from you or from the Member you work for: the registration form, the profile, the listings, the messages.

Some of it is generated by using the platform: counters, the audit trail, session records, API usage. When a broker opens a listing of another agency, that agency sees the name of the broker, the agency the broker works for and the time of opening; within an agency, members see which colleague opened or changed a listing, when, and what was changed.

Before a registration is approved we check the applicant against the official register of real-estate brokerage agencies — in Croatia the register kept by the Croatian Chamber of Economy — and, where relevant, we check the VAT number in the European VIES system. This is a manual check performed by an administrator. We record the outcome of the check, not a copy of the register.


5. Why we process it, and on what legal basis

Providing and administering the platform
Creating and running accounts, publishing and distributing listings, inquiries, client links, support. Legal basis: performance of a contract, Article 6(1)(b) GDPR, with the Member; for the individual user, our legitimate interest in delivering the service their employer contracted for, Article 6(1)(f).
Verifying that an applicant is a licensed brokerage
Admitting only licensed professionals is the whole purpose of a closed network. Legal basis: Article 6(1)(b) and Article 6(1)(f).
Sending transactional e-mail
Registration and approval notices, invitations, password resets, new inquiries and replies, availability reminders, expiry notices, suspension notices. Legal basis: Article 6(1)(b).
Security and the integrity of the network
Sign-in records, rate limiting, the audit trail, view and share counters, detection of bulk extraction, and evidence of who revealed an exact location or the identity of a listing agency. Legal basis: legitimate interest, Article 6(1)(f) — protecting Members from being bypassed and protecting the platform from extraction. We consider this proportionate because the data concerns professional activity carried out inside a closed system, is limited to what an access record needs, and every user is told about it before access is granted.
Invoicing and accounting
Legal basis: legal obligation, Article 6(1)(c), together with performance of the contract, Article 6(1)(b).
Handling reports, disputes and legal claims
Examining a report about a listing, establishing what happened in a dispute between Members, and establishing, exercising or defending legal claims. Legal basis: Article 6(1)(f), and Article 6(1)(c) where an authority requires it.

We do not process personal data for marketing. We send no newsletters, we run no advertising, and there is nothing to opt out of.

We do not sell personal data, and we do not share it with anyone for their own purposes.


6. Where we are not the controller

For accounts, membership administration, invoicing and the security of the platform, we are the controller and this policy applies.

For the content a Member publishes and the messages it writes, the Member decides what goes in. If a Member includes personal data there, the Member is the controller of it and warrants that it has a legal basis; we make that content available as part of running the platform. Where the roles of the parties require it, the data protection terms are settled in the membership agreement.

A broker that sends a client link is acting for its own client, under its own privacy notice. We are not that broker processor for the relationship with the client, because the client data never reaches us — the broker sends the link itself.


7. Cookies and what is stored on your device

The portal sets exactly three cookies and no others:

mls_at
The signed access token that keeps you signed in. Set as httpOnly, so no script can read it, and sent only over HTTPS in production. Lifetime about 15 minutes, then renewed automatically.
mls_rt
The refresh token that renews the session. Also httpOnly. Lifetime up to 30 days, rotated on every renewal and revoked when you sign out, change your password or your account is suspended.
NEXT_LOCALE
The interface language you chose. Readable by the page so the language survives a reload. Lifetime one year.

The first two are strictly necessary for signing in; the third stores a preference you set yourself.

Two further items are kept in the browser local storage on your own device and are never transmitted to us as such: the display currency you selected, and, for brokers, the current selection of listings you are assembling into an offer.

There are no analytics cookies, no advertising or profiling cookies, no tracking pixels and no social-network buttons anywhere in the platform. We use no analytics or advertising service of any kind. That is why there is no cookie banner.

Two features do load content from third parties directly into your browser, and you should know about them: map tiles in the broker portal are fetched from the OpenStreetMap and Esri tile services, and where a listing has a YouTube video, the thumbnail is fetched from Google servers and the player itself — in its no-cookie variant — loads only after you click play. In both cases your IP address becomes visible to that provider, as it does with any content loaded from the internet. We embed no other third-party content.

The address a listing agency enters is sent from our server to the OpenStreetMap geocoding service to place it on the map. That request contains the property address, not the identity of any person.


8. If a broker sent you a client link

This section is for the visitor of a page under /s/ or /c/ — the private property page or offer a broker prepared for you.

You do not need an account and we do not ask who you are. We do not learn your name, your e-mail address or your telephone number from the page.

When you open the page, the opening is counted so that the broker can see whether and how often it was read, and we store the time, your IP address and your browser identification string. That is the whole of the processing your visit causes. The legal basis is legitimate interest, Article 6(1)(f): the broker who sent you the offer has a legitimate interest in knowing whether it arrived and was opened.

The broker may have typed a private label to remember which client a link was for — for example a family name. Only that broker sees it; it is not shown on the page and no other Member can see it.

No cookie is set on the page and no script tracks you. If the property has a YouTube video, opening the video slide loads a thumbnail from Google, and the player loads only if you press play — see section 7. The page is excluded from search-engine indexing.

The link stops working on its expiry date, or immediately if the broker revokes it.

The page carries the name and contact details of the broker who prepared it. Your relationship over the property is with that broker; questions about how they handle your data, and requests concerning it, go to them.


9. Who else sees the data

Other Members
Inside the closed portal your professional identity is visible in the ordinary course of using it: the listing agency sees which broker sent an inquiry, the broker sees which agency answered, and the name, organization and business contact details of the users involved are shown alongside. This is the point of a professional network. The company data from your registration (name, legal form, address, VAT number or OIB, company registration number, brokerage-register number, e-mail, phone, website and logo) is visible to other active Members in the member directory: agencies see brokers, and brokers see agencies.
Our administrators
Our own staff can see organization and listing data, inquiries and the audit trail, in order to verify applicants, provide support, examine reports and investigate abuse. Access is limited to the people who need it.
Processors
Providers who act on our instructions and only on them: server infrastructure and hosting, storage and delivery of photographs and video, and delivery of e-mail. Each is bound by a data processing agreement under Article 28 GDPR. The list is short; we name our current processors on request.
Authorities
Where we are obliged to disclose data by law, or where a competent authority makes a lawful request. We check each request before responding.
A successor
If the business is transferred, merged or sold, data may pass to the acquirer, which is then bound by this policy or gives notice of any change.

10. Where the data is processed

All processing takes place on infrastructure located in the European Union, and we choose processors on that basis.

We do not transfer personal data outside the European Economic Area and we do not rely on standard contractual clauses. If that ever needs to change, this policy is updated and the change announced before it takes effect.


11. How long we keep it

We keep personal data only as long as it is needed for the purpose it was collected for, or as long as the law requires.

  • Organization and user account data: for the duration of the membership, and afterwards for as long as is needed to close the relationship and to defend possible claims.
  • Listing content: while the listing exists. After it is sold, withdrawn or expires it stops being distributed immediately, and is kept for one year.
  • Inquiries and their messages: two years after the last message in the thread.
  • Client links and the records of their views: while the link is listed in the broker account, and twelve months after it expires or is revoked.
  • Audit trail, sign-in records and session records: twelve months, and longer only where a specific incident, report or dispute requires it.
  • Server logs: up to 90 days.
  • E-mail log: twelve months.
  • API usage counters: aggregated per key and per day, 24 months.
  • Invoices and accounting records: eleven years, as Croatian accounting law requires.

When a period ends, the data is deleted or irreversibly anonymised. Backups are overwritten in the ordinary backup cycle, and data restored from a backup is subject to the same rules.


12. How we protect it

Passwords are stored only as Argon2 hashes. Refresh, reset and invitation tokens, and API keys, are stored only as hashes; API keys are shown once and cannot be recovered afterwards.

Traffic runs over HTTPS. Session cookies are httpOnly and, in production, restricted to secure connections. Sessions are stateless and rotate; reuse of a refresh token revokes the whole family of tokens for that user.

Access is role-based and isolated per organization: every query is scoped so that a Member can reach only its own data and the network data it is entitled to see. Sign-in attempts and public endpoints are rate limited, and unusual access patterns can be throttled or blocked.

Client-facing images are watermarked and photographs are stripped of embedded metadata, including GPS coordinates, when they are processed. Exact locations are reduced to an area before they leave the system towards another organization.

The database is not reachable from the internet, backups are taken regularly and kept encrypted off-site, and access by our staff follows the least-privilege principle.

No system is perfectly secure. If a breach occurs that is likely to result in a risk to the rights of the people concerned, we notify the supervisory authority within 72 hours and, where the risk is high, the people affected.


13. Your rights

Under the GDPR you have the right of access to your data, the right to have it corrected, the right to erasure, the right to restriction of processing, the right to data portability, and the right to object to processing based on our legitimate interest.

Much of this you can do yourself: any user can correct their own profile, and an organization administrator can correct the company data and deactivate a user account.

For anything else, write to info@realenza.com. We answer within one month; if a request is complex we may extend that by up to two further months and will tell you why within the first month. We may need to verify who you are before acting.

Some data cannot simply be deleted on request while it is still needed — the audit trail exists precisely so that it cannot be edited away, and accounting records are kept for the period the law prescribes. Where we cannot comply, we explain why.

If your request concerns data that a Member controls — the content of a listing, or a message a Member wrote — we forward the request to that Member and assist them in answering it.

You may also lodge a complaint with a supervisory authority. In Croatia that is the Personal Data Protection Agency (Agencija za zaštitu osobnih podataka, AZOP), Selska cesta 136, 10000 Zagreb, azop.hr. You may also complain to the authority of the country where you live or work.


14. No automated decision-making

No decision producing legal effects concerning you, or similarly significantly affecting you, is taken solely by automated means, and we do not carry out profiling.

Approval of a registration, moderation of content, suspension of an organization and the award of partner status are all decided by a person. The automatic mechanisms that do exist — the demotion and expiry of listings that have not been confirmed, and rate limiting — act on listings and on requests rather than on people, and can be reversed by a person.


15. Changes to this policy

The date at the top of this page tells you which version is in force. We update the policy when the platform changes or when the law requires it.

A material change is announced in the platform and by e-mail to organization administrators before it takes effect. Earlier versions are available from us on request.


16. Contact

For any question about this policy, or to exercise a right, write to info@realenza.com.

Postal address: [REALENZA d.o.o. — in formation], [street and number], [postal code] [city], Croatia.

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