Privacy Policy

1. Introduction

Brokerwall AS operates the Rellio platform (“we,” “our,” or “us”) and is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal data in compliance with the General Data Protection Regulation (GDPR) and the Norwegian Personal Data Act.

By accessing or using the Rellio platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Privacy Policy, you should refrain from using our services.

2. Data Controller

3. Personal Data We Collect

We may collect the following types of personal data:

• Contact Information: Name, address, email address, phone number, and profile picture.
• Property Details: Type of property and ownership, size in square meters (m²), plot size, number of bedrooms, and number of bathrooms.
• Property Images: Images of the property uploaded to the platform by users.
• Property Documents: Documents uploaded to the platform by users.
• User Messages: Messages exchanged between users through the platform.
• Calendars and Events: Events created in the calendar feature, and any calendars and events imported from Google or Microsoft.

We do not intentionally collect any special categories of personal data (such as health, religion, political views) unless required by law or necessary for compliance with a legal obligation. If you voluntarily provide us with such information, you consent to our processing of that information as part of our services.

4. Purpose of Data Collection

We process your personal data for the following purposes:

• Facilitating the Home-Selling Process: Connecting you with relevant service providers (real estate agents, photographers, surveyors, stylists, cleaning personnel, moving companies, etc.), and providing you with tools to do your work and collaborate with others.
• Service Enhancement: Improving our services by analyzing usage and feedback.
• Legal Compliance: Complying with legal obligations, such as mandatory record-keeping requirements.
• Communication: Sending you updates, notifications, and information related to your use of the platform.

5. Legal Basis for Processing

We rely on the following legal bases for processing your personal data:

• Performance of a Contract: Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract.
• Legitimate Interests: Processing is necessary for our legitimate interests in providing, maintaining, and improving our services, provided these interests are not overridden by your fundamental rights and freedoms.
• Legal Obligations: Compliance with legal obligations to which we are subject.
• Consent (where applicable): If you have given consent for specific processing activities (e.g., optional features or marketing communications). You can withdraw your consent at any time.

6. AI-Powered Image Modifications

The Rellio platform provides agents with AI-powered photo editing tools that may be used to modify images uploaded by photographers. These modifications may include, but are not limited to:

• Day-to-night transformation
• Object removal
• Color grading
• Image-to-video conversion
• Virtual staging

Photographers are required to provide explicit consent to these potential modifications as part of the platform onboarding process. This consent is obtained before any images are uploaded or editing tools are applied, ensuring photographers are fully informed of how their work may be used.

The legal basis for processing images in this manner is Consent (Article 6(1)(a) GDPR). Consent is collected via a dedicated, active opt-in step during onboarding — it is never pre-ticked or buried in general terms. A timestamped record of each photographer's consent, including the version of the consent text they agreed to, is stored securely on our platform.

Photographers may withdraw their consent at any time by contacting us at hi@brokerwall.com. Note that withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.

7. Data Retention

• Real Estate Agency Assignments: Data and documents related to a real estate agency assignment, including personal data, are stored for up to 10 years after the assignment is archived, in compliance with legal obligations.
• Non-Assignment Related Data: If your personal data is not related to a real estate agency assignment, it will be stored for 180 days after the last activity on your account.
• User Profile Deletion: If you request the deletion of your user profile, we will remove personal information from your profile. However, to address potential disputes, your personal information will remain in our administrative systems for 60 days before being permanently deleted.

Please note that you can request the deletion of information related to you at any time, unless we are legally required to retain such information for a specific period.

8. Data Sharing and Disclosure

We may share your personal data in the following circumstances:

• Service Providers: Relevant parties involved in the selling process (real estate agents, photographers, surveyors, stylists, cleaning personnel, moving companies, etc.) when necessary to fulfill the services you have requested.
• Hosting and Cloud Services: The Rellio platform is hosted on Vercel, and we store user-uploaded images and related data on Google Cloud. These services process data on our behalf and are contractually obligated to keep your data secure and confidential.
• Legal Authorities: When required by law, regulation, or legal request, or to protect our rights, property, and safety or the rights, property, and safety of others.
• Business Transactions: In the event of a merger, acquisition, bankruptcy, or other business transaction, your data may be transferred as part of that transaction, subject to standard confidentiality arrangements.

We do not sell or rent your personal data to third parties. We only share data to the extent necessary for the purposes described in this Privacy Policy or to comply with legal obligations.

9. Data Processors (Sub-processors)

We use the following third-party data processors to deliver our services. Each processor acts on our behalf under a Data Processing Agreement (DPA) and processes only the data necessary for its stated purpose.

This list is reviewed and updated regularly. If we engage a new sub-processor that materially changes how your data is processed, we will update this list and, where required, notify affected users.

10. International Data Transfers

If we transfer your personal data outside the European Economic Area (“EEA”), we will ensure that appropriate safeguards are in place to protect your data, such as using the European Commission’s Standard Contractual Clauses or transferring to a country that has been recognized as providing an adequate level of data protection.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures may include encryption, access controls, and intrusion detection systems. However, no electronic transmission or storage of information can be guaranteed to be 100% secure.

12. Cookies and Tracking Technologies

We only use cookies that are necessary for the operation of the Rellio platform, and have no interest in tracking you or harvesting your personal data for marketing purposes. We use cookies and similar technologies for the following purposes:

• Managing user sessions and authentication
• Remembering your language and other platform settings
• Enabling real-time communication features

You can manage your cookie preferences through your browser settings. Note that disabling cookies may affect the functionality of the Rellio platform.

13. Your Rights

Under the GDPR, you have the right to:

• Access: Request information about the personal data we hold about you, and obtain a copy of that data.
• Rectification: Request the correction of inaccurate or incomplete personal data.
• Erasure: Request the deletion of your personal data under certain conditions.
• Restriction of Processing: Request that we limit how we process your data in certain circumstances.
• Data Portability: Receive your personal data in a structured, commonly used, and machine-readable format, and request the transfer of that data to another controller, where feasible.
• Objection: Object to the processing of your personal data based on legitimate interests or direct marketing.
• Withdraw Consent: Where processing is based on consent, withdraw your consent at any time.

To exercise these rights, please contact us at hi@brokerwall.com. We may require verification of your identity before addressing your request.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Privacy Policy on the Rellio website or by other appropriate means. Changes are effective immediately upon posting unless otherwise stated.

15. Contact Us

If you have any questions or concerns about this Privacy Policy or our data processing practices, please contact us at:

16. Complaints

If you believe that our processing of your personal data is not in accordance with applicable data protection laws, you have the right to lodge a complaint with the Norwegian Data Protection Authority (Datatilsynet):