GDPR Compliance

Effective: September 1, 2026

Data Controller

Open Doorway AI Inc., registered at 548 Market St, Suite 72019, San Francisco, CA 94104, acts as the Data Controller for personal data processed through our platform. For our EU and EEA operations, our representative is Open Doorway AI Europe B.V., based in Amsterdam, The Netherlands. All data processing activities are documented in our Records of Processing Activities (ROPA) maintained in accordance with Article 30 of the GDPR.

Legal Basis for Processing

We process personal data under the following legal bases: Consent — when you opt into marketing communications or analytics tracking; Contract — to deliver services outlined in your subscription agreement; Legitimate Interest — to improve platform performance, prevent fraud, and conduct internal analytics; Legal Obligation — to comply with tax reporting, anti-money laundering, and regulatory requirements applicable to real estate data services.

Data Subject Rights

Under the GDPR, you have the right to access your personal data, rectify inaccurate data, erase your data (right to be forgotten), restrict processing, data portability, object to processing, and not be subject to automated decision-making. These rights can be exercised through your account dashboard or by contacting our DPO. We process requests within 30 days and will notify you of any extensions required for complex requests.

Data Transfers

Your data may be processed in the United States and other countries where our infrastructure providers operate. For transfers outside the EEA, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission, adequacy decisions where available, and our Binding Corporate Rules. Data transfer impact assessments are conducted annually to ensure appropriate safeguards remain in place.

Data Retention

We retain personal data only as long as necessary to provide services and comply with legal obligations. Active account data is retained for the duration of your subscription plus 90 days. Anonymized analytics data may be retained indefinitely for model training and market research. Financial records are retained for 7 years as required by applicable tax and auditing regulations.

Contact DPO

Our Data Protection Officer can be reached at dpo@opendoorway.ai or by mail at the address above. For GDPR-specific inquiries, complaints, or to exercise your data rights, our DPO responds within 48 hours. You also have the right to lodge a complaint with your local supervisory authority if you believe your rights under the GDPR have been infringed.