Translation for information only. The German version is legally binding. German original

General Terms and Conditions for Brokers (B2B)

Version: 17 October 2026

§ 1 Scope

(1) These General Terms and Conditions (hereinafter “GTC”) govern the contracts between GREM CAPITAL LIMITED, 54 Kestrel Avenue, SE24 0EB London, Vereinigtes Königreich, the provider of the platform (hereinafter “GREM”), and brokers concerning the use of the GREM real estate platform in the German edition. It is accessible via the website of the German edition (currently de.grem.capital), the user account in the web browser (hereinafter the “GREM account”), the web application that can be installed on the home screen and the GREM apps (together the “Platform”). The annex “Data Processing Agreement” forms part of these GTC.

(2) The offer is directed exclusively at traders within the meaning of § 14 BGB (German Civil Code) who operate commercially as real estate brokers, have their registered office or business address in Germany and whose account is assigned to the German market (hereinafter “brokers”): individual brokers and brokerage firms (hereinafter “agencies”), including the employees they invite. The General Terms and Conditions for Owners apply to owners; these GTC do not apply to prospects. There is no right of withdrawal for consumers.

(3) The broker’s general terms and conditions do not become part of the contract, even if GREM does not object to them. Individual agreements, in particular regarding the ENTERPRISE plan, take precedence (§ 305b BGB).

(4) The service description and the price list on the plans page in the GREM account, in the version valid at the time of booking, also form part of the contract. In the case of a contact, the terms displayed before acceptance (§ 7 paragraph 2) take precedence over these GTC to the extent that they differ.

§ 2 Contracting party, definitions and role of GREM

(1) The contracting party is GREM CAPITAL LIMITED, 54 Kestrel Avenue, SE24 0EB London, Vereinigtes Königreich, e-mail: [email protected]. Further information is contained in the Legal Notice.

(2) Definitions:

Owners: sellers and landlords who list a property in Germany; prospects: prospective buyers and tenants;
Contact: the transmission of the contact details of an owner or prospect to the broker via the Swipe Match function;
Plan: the monthly subscription (BASIS, PROFESSIONAL, OFFICE, NETWORK or ENTERPRISE); billing month: in each case one month from the first payment for the plan;
Listing slot: the unit of the plan for one active, i.e. published and visible, property;
Text form: a legible declaration on a durable medium, e.g. e-mail (§ 126b BGB).

(3) GREM provides a platform for selection: owners and prospects choose the broker themselves. GREM does not act as a broker, is not a party to the brokerage contracts, does not participate in negotiations and transactions, does not assign a broker to anyone and receives no commission from brokered transactions. Whether and on what terms (e.g. sole agency, amount of commission) a brokerage contract is concluded is decided solely by the parties involved.

§ 3 Registration and conclusion of the contract

(1) The presentation of the services does not constitute a binding offer. By registering, selecting Germany as the country and confirming these GTC, the broker offers to conclude a free-of-charge user agreement; it is concluded as soon as GREM sets up the account. There is no entitlement to the conclusion of a contract.

(2) The broker books a plan in the GREM account by selecting it and completing the payment process. The plan contract is concluded and the plan is activated as soon as the first payment has been successfully confirmed.

(3) The broker orders paid individual services outside the plan (in particular contacts, properties above the limit, slot extensions, credit packages and report audits) by means of the relevant action in the GREM account, and in the case of a contact by clicking “Accept”. If immediate card payment is required (§ 14 paragraph 5), the contract is concluded only upon successful payment.

(4) Before completing a booking, the broker can check and correct their entries. These GTC can be accessed and saved at any time; bookings and invoices can be viewed in the GREM account.

(5) The country of the account determines the plan, prices, invoicing and language. Before the first payment, the broker may change it themselves; thereafter only via support. An account for the German market lists only properties in Germany.

(6) An account that has once been operated as a broker account (in particular by virtue of the role of broker, a broker plan, verification under § 34c GewO or membership of an agency) remains commercial. It is not entitled to the free-of-charge publication of a limited number of properties intended for private individuals, even after a change of role.

(7) Login credentials must be kept secret; the broker reports any suspected misuse without undue delay.

§ 4 Agencies and employees

(1) An agency is represented by its owner or managing director; that person books the plan and submits the evidence under § 5. The agency’s plan covers all employees, whose number is unlimited.

(2) Employees register at the invitation of the agency, take over its country and its status “§34c verified” for as long as they belong to it, and act on the Platform on behalf of the agency. The agency is responsible for their conduct as for its own. Contacts may be passed on within the agency.

§ 5 Requirements: licence under § 34c GewO, verification and legal notice

(1) The broker must hold a licence under § 34c paragraph 1 sentence 1 no. 1 GewO (German Trade Regulation Code). Upon registration, the broker states and provides evidence of:

the licence number, the issuing authority, any time limit, and the licence document;
tax number or VAT identification number;
in the case of a GmbH, UG (haftungsbeschränkt), AG and GmbH & Co. KG, the register court, register number and an extract from the commercial register that is not older than three months at the time of upload;
the information for their legal notice.

(2) GREM verifies the evidence partly by automated means: the documents are read out and compared with the information provided, the register extract and the legal notice on the broker’s website. The decision on approval is taken by a GREM employee, who may request further evidence. Thereafter, the account bears the status “§34c verified”. There is no entitlement to approval; reasons are given for a rejection.

(3) Without this status, the broker cannot accept contacts and is not displayed to owners and prospects; the broker may use the plan, properties and tools from the time of booking.

(4) If the licence is time-limited, GREM gives notice 30 days before it expires. Upon expiry, the status lapses until new evidence has been approved; contacts already accepted remain with the broker.

(5) The broker notifies GREM in text form without undue delay if the licence is revoked, withdrawn, restricted or has expired, or if the company name, legal form, representation, address or register information changes. GREM may withdraw the status if the requirements cease to be met or evidence was incorrect. The verification replaces neither official supervision nor the broker’s responsibility for their professional obligations.

(6) GREM displays on a separate profile page a legal notice of the broker containing the verification information (legal form, company name, authorised representatives, address, e-mail, telephone, website, register, VAT identification number, competent supervisory authority). The broker is responsible for its completeness and accuracy under § 5 DDG (German Digital Services Act) and the Regulation on Information Obligations for Services (Dienstleistungs-Informationspflichten-Verordnung) and keeps the information up to date.

§ 6 Services of the Platform

(1) The scope of services is determined by the service description of the plan booked, in particular:

Property listings: creating, managing and publishing properties for sale and for rent in Germany on the Platform and in GREM’s shared property database;
Swipe Match: contacts from owners and prospects who have selected the broker (§§ 7 to 9);
CRM: management of contacts, enquiries, search requests and marketing steps;
AI tools without volume limits: AI chat and assistant, texts and translations in ten languages, subtitles, photo editing, virtual furnishing, floor plans, PDF exposés, flyers, landing pages, publication on social networks, express and rental valuation, express report, neighbourhood reports and the one-time creation of a personal AI avatar;
Operations for credits: videos, videos with an AI avatar, 3D tours and re-voicing (§ 13);
public broker profile with legal notice, reviews and rating (§ 15);
Export in OpenImmo format; integrations designated as “In preparation”, for example with real estate portals, are owed only from their activation;
monthly invoices and invoice archive.

(2) Tools without volume limits are available for active properties and for drafts up to the number of properties included in the plan; drafts are counted per billing month.

(3) The broker books paid services in the GREM account in the browser or in the web application; in the apps from the App Store and Google Play, no paid contacts or purchases are offered to German broker accounts. The broker receives push notifications only if they allow them on their device; e-mail and SMS are used in addition.

(4) The public display of the catalogue and map may depend on a minimum number of properties being reached in a region. GREM does not owe any success, in particular no particular number of contacts, enquiries or transactions.

(5) Videos, PDF exposés, 3D tours and landing pages created with the Platform bear a GREM mark; photos do not. It may not be removed or obscured unless otherwise agreed (ENTERPRISE).

(6) GREM may further develop and change functions where this is reasonable for the broker, in particular if the essential services of the plan are maintained. For services of third parties (e.g. social networks, payment service providers), their terms apply in addition.

§ 7 Swipe Match: contacts from owners and prospects

Selection and offer

(1) Owners see a list of brokers with the status “§34c verified” and an active plan and make their own choice. Prospects choose a broker on the property page or in a search request; telephone numbers are not displayed in listings. The transmission to the broker is based on the consent of the owner or prospect.

(2) The broker receives a personal offer. Until acceptance, the contact is anonymised (e.g. type of property, area, budget, time frame, verification badges). Before acceptance, the type and category of the contact, the price including the plan discount and the terms of exclusivity are displayed.

(3) The broker may accept or decline the offer within four working hours. Working hours are Mondays to Fridays from 8 h to 20 h and Saturdays from 9 h to 14 h (Europe/Berlin), excluding nationwide public holidays and public holidays applicable throughout the federal state of the broker’s business address; if no federal state has been specified, only nationwide public holidays are excluded. When declining, the broker selects a reason; a decline does not affect the rating, whereas exceeding the deadline may reduce it.

Acceptance and price

(4) By clicking “Accept”, the broker orders the contact with binding effect at the price displayed; this price is fixed upon acceptance. The contact details are released immediately. If a required card payment fails, the offer is deemed not to have been accepted; the broker may pay with another card within the deadline.

(5) The category of an owner contact is determined by the AI valuation of the property (in the case of a range, by its midpoint) or, without an AI valuation, by the price stated by the owner, with the note “Category based on the owner’s price”. The category of a prospect is determined by the evidence of financing or capital approved by GREM; the broker receives only verification badges and the range, not the documents. Prices and discounts are set out in the price list.

(6) The contact of a prospect who themselves makes an enquiry about one of the broker’s properties is free of charge; it is covered by the listing slot. Contacts that are subject to a charge include in particular contacts from search requests and prospects introduced by a partner broker (§ 9), even for one of the broker’s own properties.

(7) A repeat contact of the same person to the same broker or the same agency is released without payment: in the case of owners, with the same confirmed telephone number for the same property; in the case of prospects, with the same confirmed telephone number within six months of the first purchase. Another property of the same owner constitutes a new contact.

Making contact and exclusivity

(8) The broker contacts the owner via the Platform within three days of acceptance. Any outgoing call via the Platform’s telephony (from the GREM account via its telephone system or in the GREM app), irrespective of the outcome, or a message in the GREM chat counts as making contact; a manual marking is not sufficient. Mondays to Saturdays are counted, excluding Sundays and public holidays within the meaning of paragraph 3. The day of acceptance is the first day; if acceptance takes place after 18 h, the period begins on the following day.

(9) If the broker makes contact in due time, the owner will not be transmitted to any other broker for up to 14 calendar days from acceptance, as long as the owner does not end the cooperation. The owner may end it at any time (“Broker was not a good fit”); the owner’s feedback is taken into account in the rating, a property copy taken over is paused, and no credit note arises as a result.

(10) If the broker does not make contact via the Platform in due time, the contact is deemed to have been provided and remains payable; the owner may choose another broker, and a property copy taken over is paused. Calls from the broker’s own telephone and contacts outside the Platform are not recorded by the system; they are made at the broker’s risk.

(11) Conversations via the Platform are not recorded; GREM stores the time and status of calls and messages as evidence. The broker does not record conversations without the consent of the parties involved.

(12) GREM is responsible for the transmission of the contact, i.e. for ensuring that the owner or prospect has consented and has confirmed their telephone number by SMS code, but not for their willingness to conclude a transaction, their conduct and information, or the success of the brokerage.

Property and use of contact details

(13) After accepting an owner contact, the broker may take over the property as their own copy, which occupies a listing slot from publication; the owner’s listing is then removed. The broker receives enquiries from prospects concerning this property free of charge. The broker may use materials from the owner’s packages handed over by the owner only for marketing this property, including on portals; GREM marks are retained.

(14) The broker uses acquired contact details only for the relevant enquiry and does not pass them on to brokers of other companies; disclosure within the broker’s own agency and disclosures permitted by law in the course of the brokerage (e.g. to notaries) remain permissible.

§ 8 Contact guarantee, credit notes and complaints

(1) For a paid contact, GREM issues a credit note only if

the telephone number does not exist (already at the first call attempt via the Platform),
the subscriber cannot be reached on three call attempts via the Platform on different days within three days (Monday to Saturday) (telephone switched off or without network), or
the same contact was paid for twice.

These credit notes are issued automatically, as a rule within two working days.

(2) In particular, no credit note is issued in the event of no answer, a busy signal, rejection of the call or voicemail, cancellation or change of mind after a conversation, “Broker was not a good fit”, failure to meet the deadline under § 7 paragraph 8 or communication outside the Platform.

(3) If the broker has well-founded doubts about an owner (e.g. not the owner, the property does not exist, no intention to sell), the broker may report the owner. If brokers of two different companies report the same owner, the owner’s account is blocked; GREM decides on credit notes for both after review. A single report is merely noted in the owner’s history. No fixed processing time applies to reports.

(4) Credit notes are issued as invoice corrections with reference to the original invoice and appear in the GREM account as a credit balance. The credit balance is offset against the invoice for the current or following billing month and is not paid out. Upon termination, it is offset against the final invoice; any remainder stays in the account for twelve months and is offset if a plan is resumed. Mandatory statutory claims remain unaffected.

(1) When creating a property, the broker specifies whether or not they will share the commission for a buyer introduced by another broker, including one from abroad (hereinafter “partner broker”), with that partner broker (as a percentage or as a fixed amount, in each case net to the partner broker); without such a specification, the property is not published. The specification may be changed at any time; the specification at the time of the introduction is decisive. It is visible only to brokers, including brokers from abroad.

(2) The partner broker remains anonymous until the match and payment for the contact (e.g. “Broker from Spain”). The enquiry is transmitted only once the prospect has confirmed their consent via a link. For the receiving broker, the contact is subject to a charge in accordance with the price list.

(3) GREM records the agreement in a tamper-proof manner and sends both brokers a PDF confirmation. GREM is not a party to the agreement, does not pay out any shares and is not liable for their payment; settlement takes place directly between the brokers. The brokers are responsible for the permissibility of the sharing, in particular under §§ 656c, 656d BGB and § 34c GewO.

§ 10 Obligations of the broker

(1) The broker provides truthful, complete and up-to-date information on their profile, languages and properties, marks completed transactions as “sold” or “let” with the date and takes properties that are no longer available off the market. The broker keeps their contact details up to date so that notifications reach them.

(2) The broker publishes only properties for which a brokerage mandate or the owner’s consent to marketing exists, and provides evidence of this on request. The broker fulfils on their own responsibility the obligations under brokerage law, in particular the text form of the brokerage contract (§ 656a BGB), the sharing of the commission (§§ 656c, 656d BGB) and the ordering-party-pays principle for rental apartments (§ 2 paragraph 1a WoVermittG, German Housing Brokerage Act), as well as the obligations under the Money Laundering Act, the Brokers and Property Developers Regulation and the Price Indication Regulation; GREM does not verify them.

(3) For properties in Germany, the broker selects one of three options for the energy performance certificate:

“Energy performance certificate available” with the mandatory information under § 87 GEG (German Building Energy Act) (for residential buildings, the type of certificate, energy performance indicator, main energy source, year of construction and efficiency class; for non-residential buildings, the type, energy performance indicator and energy source);
“Energy performance certificate not yet available”: the listing shows “Energy performance certificate will be presented at the viewing”; the certificate must be presented at the latest at the viewing;
“Listed building – no energy performance certificate required”: only where heritage protection has been confirmed.

The broker states heritage protection and heritable building rights only where accurate and substantiates them with a document.

(4) The broker uploads only content (photos, videos, texts, floor plans, logos) to which they hold the rights, with the consent of any persons depicted. The broker does not use representations altered with AI or image editing (e.g. virtual furnishing, sky replacement) in a misleading manner; the broker labels AI-generated or AI-altered content where required by law, for example under Regulation (EU) 2024/1689.

(5) The broker complies with competition law (in particular §§ 5, 5a, 6, 7 UWG, German Act against Unfair Competition) and the General Equal Treatment Act. The broker sends advertising to contacts only with the required consent.

(6) The broker is the controller within the meaning of the GDPR for personal data of their clients and prospects; the broker ensures a legal basis, fulfils the information obligations (Art. 13, 14 GDPR) and safeguards the rights of data subjects. The annex applies to processing by GREM on the broker’s behalf.

(7) Results of AI tools and valuations are generated automatically and may be incorrect. The broker checks them before use and is responsible for published content.

(8) The following are prohibited in particular: multiple accounts or nominee persons in order to obtain the trial period again or to circumvent rules; fictitious properties or properties for which no mandate exists, and incorrect evidence; manipulation of reviews (§ 15 paragraph 3); automated scraping of the Platform, attacks on its security and malicious files; unlawful or discriminatory content or content infringing the rights of third parties.

(9) The broker indemnifies GREM against claims of third parties based on a breach of these obligations for which the broker is responsible, including reasonable costs of legal defence. GREM informs the broker without undue delay and coordinates the defence with the broker.

§ 11 Plans, trial period and change of plan

(1) The plans offered are BASIS, PROFESSIONAL, OFFICE and NETWORK and, for more than 100 properties, ENTERPRISE by agreement. The number of properties, monthly credits, price per property above the limit and discounts on contacts and credit packages are set out in the price list. Billing is monthly only; there is no free plan and no free trial period.

(2) Discounted trial period: for the first three billing months from the first payment, GREM grants a 50 % discount on the price of the plans BASIS to NETWORK; the first payment is made by card. The discount applies only to the plan, not to other services. It is granted once per company; for this purpose, GREM compares the licence number under § 34c GewO, the tax number and VAT identification number and the IBAN of the SEPA mandate. In the event of a match, the discount lapses from the following billing month. A change of plan during the trial period leaves the discount in place until the end of the three months. GREM gives notice in the account and by e-mail 14 days before the end; from the fourth billing month, the full price applies.

(3) A change to a higher plan takes effect immediately; the difference is charged pro rata for the remaining days. A change to a lower plan takes effect from the following billing month; if the broker then has more active properties than the new plan covers, the broker selects properties for archiving; otherwise, the additional properties are charged as properties above the limit after the amount has been confirmed.

§ 12 Listing slots

(1) A property occupies a listing slot in a billing month if it was active for at least one day in that month, and counts only once in that month. Drafts do not occupy a slot. Publication requires an active plan; without one, properties are not displayed.

(2) Each active property above the number of properties included in the plan is charged per billing month at the full price according to the price list as a separate invoice item; the trial period discount does not apply.

(3) If a property is deleted, marked as “sold” or “let” or paused, the slot becomes free from the following billing month; no month is charged twice.

(4) From its first publication, a listing slot has a term of six months for rental properties and for residential properties for sale below the city’s price threshold, and of twelve months for commercial properties and for residential properties for sale with a year of construction before 1949, heritage protection, a heritable building right, as an attic apartment, terraced house or semi-detached house, or above the price threshold. The price thresholds are stated in the service description. Heritage protection and heritable building rights count only after the document has been confirmed.

(5) GREM informs the broker 14 days before the end of the term; upon expiry, the property is “paused” and no longer displayed. The broker may extend the slot: monthly at 50 % of the price per listing slot of their plan, outside the limit, until the transaction is concluded or until the broker ends the extension. The billing month from which the extension is charged is displayed before activation.

(6) If the same property is listed again within six months, it is deemed to be the same property with the same term. If several brokers market the same property, each copy occupies a slot with the respective broker; a joint property page appears in the catalogue.

§ 13 Credits

(1) Credits are consumed for videos, videos with an AI avatar, 3D tours and re-voicing in accordance with the price list; a revision of the same operation for the same property within seven days costs the lower number shown there. There are no fractions of credits.

(2) Monthly credits are carried over for one month; purchased credit packages are valid for twelve months from purchase. Carried-over credits are consumed first, then current monthly credits, and purchased credits last. If they are insufficient, the operation is not carried out and a package is offered.

(3) Upon a change to a higher plan, the difference in monthly credits is credited immediately; upon a change to a lower plan, the new allowance applies from the following billing month.

(4) Upon termination, monthly credits expire at the end of the paid period; purchased credits are retained for a resumption until their twelve months have expired. Credits are not a means of payment, are not transferable and are not paid out.

§ 14 Prices, invoices and payment

(1) All prices are stated in euros net plus statutory VAT (currently 19 %) in accordance with the price list at the time of booking, and for contacts at the price displayed upon acceptance.

(2) After the SEPA mandate has been granted (paragraph 4), GREM issues a monthly invoice for each billing month showing the plan in advance and the services of the past month (in particular contacts, properties above the limit, slot extensions, credit packages, report audits) as separate items. As long as the plan is paid by card, the broker receives a separate invoice for each payment; properties above the limit and slot extensions are then invoiced separately and paid by card in the GREM account. Services paid immediately by card (paragraph 5) are likewise invoiced separately.

(3) The broker receives invoices electronically under § 14 UStG (German VAT Act) in ZUGFeRD format, as a PDF in the GREM account and by e-mail; the broker agrees to this. Corrections are made as invoice corrections with reference to the original invoice.

(4) The first payment is made by card via the payment service provider Stripe. Thereafter, the broker may grant a SEPA Core Direct Debit mandate in the GREM account; from the following billing month, the monthly invoices are collected by direct debit. Without a mandate, the plan continues to be paid monthly by card. The broker makes payments under paragraph 5 via Stripe’s payment page by card, Apple Pay or Google Pay. Before each collection, the broker receives the invoice stating the amount and debit date in the GREM account and by e-mail at the latest two bank working days in advance; the parties agree on this shortened pre-notification period. The broker ensures sufficient funds.

(5) Services outside the plan are included in the next monthly invoice up to a limit; beyond that, they must be paid immediately by card:

until the first successful SEPA direct debit: card only;
in the first eight weeks thereafter: limit equal to the plan price actually payable;
thereafter: the plan’s limit according to the price list, half of it during the trial period;
after a failed direct debit or returned direct debit: card only, until the invoice has been settled and a further eight weeks have passed without a returned direct debit; thereafter, starting again from the first level.

(6) If a collection fails or a direct debit is returned, the invoice is outstanding and can be settled by card in the GREM account. Access continues for seven more days, but at most until the end of the paid period; thereafter, the paid functions are suspended until the balance is settled, and a new billing month does not begin. If an invoice has been outstanding for more than 14 days, new publications, re-display of properties and slot extensions are blocked. §§ 286, 288 BGB remain unaffected. The broker bears the costs of a returned direct debit for which the broker is responsible.

(7) The broker may set off only claims that are undisputed or have been finally determined by a court; a right of retention exists only on the basis of the same contractual relationship.

§ 15 Reviews, rating and display order

(1) The rating (“R”) appears in the profile and on the selection card. It is based on reviews by owners and prospects who have received a contact from the broker, on feedback after the end of a cooperation (“Broker was not a good fit”) and on response behaviour: exceeded deadlines reduce it, declined offers do not. As long as fewer than three reviews are available, “New on GREM” appears instead of the rating.

(2) Only owners and prospects who have received a contact from this broker may submit reviews. Reviews or the rating cannot be influenced against payment.

(3) The broker does not review themselves, does not have themselves reviewed by persons without a business contact, does not make benefits conditional on positive reviews and does not put pressure on reviewers.

(4) The broker may report a review that the broker considers unlawful, stating reasons, to [email protected]; GREM reviews it and removes unlawful reviews. There is no entitlement to the removal of permissible criticism.

(5) Main parameters of the ranking (Art. 5 Regulation (EU) 2019/1150):

list for owners: only brokers with the status “§34c verified” and an active plan, the nearest at the top, with the distance shown; the owner may extend the radius;
property page with several brokers: by rating, the best first;
search request: several matching brokers with the status “§34c verified”; their number is stated in the service description.

Influencing the ranking against payment is not currently offered; its introduction would be notified in advance in accordance with § 23.

§ 16 Property valuations and report audit

(1) AI valuations (express and rental valuation) and the express report are automated estimates, not a market value appraisal (§ 194 BauGB, German Federal Building Code), not an expert opinion and not an assurance of an achievable price; the express report is labelled as such. The broker does not present them as expert opinions. GREM does not prepare market value appraisals.

(2) In the report audit, the broker uploads a valuation report prepared by a third party; GREM reviews it and provides an assessment in text form. The assessment is not an expert opinion, not an independent valuation and not a confirmation of the value.

(3) The report audit is subject to a charge and is not included in the plan. The price according to the price list is charged net plus VAT in the monthly invoice; plan discounts do not apply. The processing time is stated in the service description.

(4) The broker warrants that they are entitled to pass on the report, in particular vis-à-vis its author and the party that commissioned it. GREM processes personal data contained therein only for the review; the file is deleted 90 days after the assessment. GREM incorporates value information without personal data into the data basis of its AI valuation; the broker agrees to this. This is pointed out at the time of upload.

§ 17 Content and rights of use

(1) The rights to their content remain with the broker. For the duration of the contract and of the respective publication, the broker grants GREM the non-exclusive, royalty-free right, unrestricted as to territory, to store, reproduce, technically adapt (e.g. format, size, translation), edit with the tools used by the broker and make publicly available that content for the purposes of the Platform: on the Platform, in the catalogue and on the map, on property and profile pages, in the GREM apps, in the shared property database, including display to brokers from abroad, and in the channels chosen by the broker (e.g. social networks, OpenImmo export). GREM may transfer these rights to technical service providers to the extent necessary for operation.

(2) After the end of the publication or of the contract, GREM removes the content from public display within a reasonable period; statutory retention obligations, evidence (e.g. confirmations under § 9) and backups in the usual deletion cycle remain unaffected.

(3) GREM may use property data without personal reference (e.g. price, area, location, type of property, marketing duration) in aggregated form for statistics, market reports and the improvement of the valuation functions, including after the end of the contract.

(4) The broker may use results created with the tools for their marketing; no assurance is given that AI results are eligible for copyright protection or are unique. For the AI avatar, the broker uploads only their own image and sound recordings or those made with the consent of the person depicted.

§ 18 Availability and disruptions

(1) GREM operates the Platform with commercial diligence in accordance with the state of the art. Uninterrupted availability is not owed unless the service description promises otherwise. Maintenance is carried out, where possible, at times of low usage and is announced where it can be planned. GREM is not responsible for disruptions beyond its sphere of influence (e.g. force majeure, third-party networks).

(2) If, due to a disruption for which GREM is responsible, the broker cannot respond to an offer in due time or cannot make contact via the Platform within the period under § 7 paragraph 8, the period is extended by the duration of the disruption.

§ 19 Liability

(1) GREM is liable without limitation in cases of intent and gross negligence, for injury to life, body or health, under the Product Liability Act, in the event of fraudulent concealment of a defect and to the extent of any guarantee assumed.

(2) In cases of simple negligence, GREM is liable only for the breach of material contractual obligations whose fulfilment is a prerequisite for the proper performance of the contract and on whose observance the broker may regularly rely (cardinal obligations), limited to the damage typical for the contract and foreseeable at the time the contract was concluded. Otherwise, liability is excluded.

(3) GREM is not liable for the information, conduct and solvency of owners, prospects and other brokers, for the conclusion and success of brokerage contracts and transactions, for commission shares between brokers, nor for the substantive accuracy of automatically generated results (§ 10 paragraph 7, § 16). Paragraphs 1 and 2 remain unaffected.

(4) The limitations also apply to the personal liability of GREM’s corporate bodies, employees and vicarious agents.

§ 20 Term and termination

(1) The user agreement runs for an indefinite period. The broker may terminate it at any time, in text form or by deleting their account in the settings of the GREM account; GREM may terminate it by giving 30 days’ notice.

(2) The plan is renewed for one billing month at a time. The broker may terminate it at any time with effect from the end of the paid billing month in text form, in particular by e-mail to [email protected]. GREM may terminate it by giving 30 days’ notice with effect from the end of a billing month. Terminations by GREM are made in text form, stating reasons.

(3) The right to terminate for good cause (§ 314 BGB) remains unaffected. Good cause for GREM exists in particular if the licence under § 34c GewO ceases to exist and is not replaced, incorrect evidence is submitted, the broker repeatedly or seriously violates § 10 or is in substantial default of payment.

(4) Upon the end of the plan, the paid functions end, properties are no longer displayed, and services up to the end of the contract are settled with a final invoice. § 13 paragraph 4 applies to credits, § 8 paragraph 4 to credit balances, and the annex to data processed on the broker’s behalf.

§ 21 Blocking and measures in the event of violations

(1) Where there are specific indications of violations of these GTC or of the law, in the case of incorrect evidence, default in payment or security risks, GREM may take appropriate measures: a notice or warning, removal or blocking of content, restriction of functions (e.g. acceptance of contacts, publication), withdrawal of the status “§34c verified”, temporary or permanent blocking of the account, termination. GREM takes into account the seriousness and duration of the violation, fault and the legitimate interests of the broker.

(2) GREM communicates the measure and the reasons for it in text form at the latest when it takes effect, unless a statutory or official obligation precludes this or the broker has repeatedly committed violations (Art. 4 Regulation (EU) 2019/1150, Art. 17 Regulation (EU) 2022/2065). The broker may comment and request a review free of charge at [email protected]. If the broker is responsible for a block, the obligation to pay for the current billing month remains. If the reason ceases to apply, GREM lifts the measure.

(3) Anyone may report illegal content to [email protected]; GREM decides diligently and without undue delay. GREM also checks documents and duplicate properties by automated means; the status “§34c verified” is granted by an employee.

§ 22 Data protection and data access

(1) GREM processes the data of the broker and their employees as controller in accordance with the Privacy Policy, in particular for registration, verification under § 34c GewO, billing, evidence relating to contacts (consents, time and status of calls and messages), reviews and security. Verification documents relating to § 34c GewO are retained for as long as the status exists. GREM retains the event log relating to contacts (in particular acceptance, making contact, time and status of calls and messages via the Platform, credit notes) for five years. Invoices and payment records are retained for the statutory periods (§ 147 AO, German Fiscal Code; § 14b UStG) and, in the event of a request for deletion, are blocked until then.

(2) The transmission of contacts is based on the consent of the owners and prospects, which GREM stores together with the text version, date, time, language and IP address. The broker becomes controller in its own right for the data transmitted. Insofar as GREM processes data on behalf of the broker, in particular in the CRM and in the communication functions, the annex applies; it is concluded upon acceptance of these GTC.

(3) Data access (Art. 9 Regulation (EU) 2019/1150): in the GREM account, the broker has access to the data they have uploaded, contacts, enquiries, invoices and reviews. GREM has access to all data provided and generated during use and uses them for the performance of the contract, billing, security, the prevention of misuse and the improvement of the Platform, as well as without personal reference in accordance with § 16 paragraph 4 and § 17 paragraph 3. GREM passes data on to third parties only insofar as this is necessary for the functions (e.g. to owners, prospects, other brokers, service providers), is required by law or the broker consents.

(4) Both parties treat non-public business information of the other party confidentially.

§ 23 Amendments to the GTC, services and prices

(1) GREM may amend these GTC, the service description and the price list with effect for the future if there is an objective reason, such as a change in the legal situation or case law, official requirements, new functions, technical developments, security requirements or changed costs.

(2) GREM notifies amendments at least 30 days before they take effect in text form by e-mail and in the GREM account.

(3) The broker may object in text form until the amendments take effect or terminate with effect from that date. If the broker does not object and continues to use the Platform thereafter, the amendments are deemed accepted; GREM specifically points this out in the notification. In the event of an objection, the contract continues on the previous terms; GREM may then terminate it in accordance with § 20.

(4) Price changes apply at the earliest from the billing month that begins after the notice period has expired. For accepted contacts and booked individual services, the price displayed at the time of booking applies.

(5) GREM may make amendments without notice where it is obliged to do so at short notice by law or by order of an authority, or where they are necessary to avert an unforeseen, imminent danger (e.g. fraud, malware). Retroactive amendments are excluded.

§ 24 Final provisions

(1) German law applies, to the exclusion of the UN Convention on Contracts for the International Sale of Goods (CISG).

(2) If the broker is a merchant, a legal entity under public law or a special fund under public law, or has no general place of jurisdiction in Germany, the courts in Berlin have exclusive international and local jurisdiction for all disputes arising from and in connection with this contract, including the annex, to the extent permitted by law. If GREM has its registered office in Germany, the registered office of GREM replaces Berlin. GREM may also sue the broker at the broker’s general place of jurisdiction. Exclusive statutory places of jurisdiction remain unaffected.

(3) The language of the contract is German; the German version is authoritative.

(4) Declarations relating to the contract require text form, unless these GTC provide otherwise. Notifications from GREM are sent to the e-mail address stored in the account and to the GREM account.

(5) The broker may assign rights under this contract only with the consent of GREM; § 354a HGB (German Commercial Code) remains unaffected.

(6) If any provision is invalid, the remaining provisions remain valid; the invalid provision is replaced by the statutory provisions (§ 306 paragraph 2 BGB).

Between the broker as controller (hereinafter the “Client”) and GREM CAPITAL LIMITED, 54 Kestrel Avenue, SE24 0EB London, Vereinigtes Königreich, as processor (hereinafter “GREM”). This agreement forms part of the GTC for brokers and is concluded upon their acceptance.

1. Subject matter and duration

(1) GREM processes personal data on behalf of the Client insofar as the Client uses the Platform to serve its clients, prospects and business partners, in particular:

in the CRM (contacts, enquiries, search requests, notes, appointments, marketing steps);
in the case of contacts, from their transmission to the Client;
in the Client’s communication via the Platform (chat, telephony, notifications, automatic replies);
when AI tools are applied to these data at the Client’s instigation;
in the Client’s properties and documents, insofar as they contain personal data.

(2) The agreement applies for the duration of the user agreement and until the data are deleted or returned in accordance with Clause 15.

2. Processing under GREM’s own responsibility

This agreement does not cover processing that GREM carries out as a controller in its own right: accounts and requests of owners and prospects; the transmission of contacts on the basis of their consent and the storage of the consents; evidence of the time and status of calls and messages for deadlines and credit notes; reviews and rating; the verification of evidence (licence under § 34c GewO, proof of financing, documents relating to heritage protection and heritable building rights, reports in the report audit); billing and retention for tax purposes; security and the prevention of misuse; statistics and valuation data without personal reference. The Privacy Policy applies to such processing.

3. Nature and purpose of the processing

Collecting, storing, organising, displaying, searching and transmitting data and messages, their preparation by AI tools, as well as backing up, restoring and deleting them, in each case in order to provide the functions of the Platform to the Client.

4. Type of personal data

contact details (name, telephone number, e-mail address, language);
information on the property and its address, search and purchase interests (region, type of property, budget, time frame), verification badges and ranges relating to financing;
communication content (chat messages including voice and video messages, notes) and communication data (time, duration and status of calls, no conversation content);
appointments, viewings and marketing status;
image and sound recordings, insofar as persons can be identified in them.

Special categories of personal data (Art. 9 GDPR) are not envisaged; the Client records them only insofar as this is permissible and unavoidable.

5. Categories of data subjects

Owners (sellers and landlords), prospective buyers and tenants, other clients and business partners of the Client (e.g. other brokers) and the Client’s employees.

6. Instructions

(1) GREM processes the data only on documented instructions from the Client, including with regard to transfers to third countries, unless GREM is required by law to process them; in that case, GREM informs the Client of the legal requirement in advance, unless the law prohibits this.

(2) The instructions are laid down in the GTC and by the use of the functions of the Platform (e.g. creating, changing, deleting, sending). The Client issues further instructions in text form within the scope of these functions.

(3) If GREM considers that an instruction infringes data protection law, GREM informs the Client without undue delay and may suspend its execution until the matter has been clarified.

7. Obligations of the Client

The Client is responsible for the lawfulness of the processing and for safeguarding the rights of data subjects and notifies GREM without undue delay of any errors or irregularities detected. The Client uses services that it itself connects to its account (e.g. its own messenger or social media accounts) on its own responsibility; their operators are not sub-processors of GREM.

8. Confidentiality

GREM deploys only persons who have committed themselves to confidentiality or are under a statutory obligation of confidentiality, and grants access only to the extent necessary for their tasks.

9. Technical and organisational measures

(1) GREM takes the measures under Art. 32 GDPR, in particular:

Encryption in transit: access to the Platform only via TLS; connections between the servers via an encrypted internal network; database connections with TLS;
Encryption of stored data: encrypted storage media on the database servers; passwords only as a cryptographic hash value; database backups are encrypted before being stored outside the data centres;
Access control: role and authorisation concept based on the need-to-know principle; infrastructure administration interfaces only via additionally secured access; second factor for particularly sensitive administrative operations; server access only with cryptographic keys; firewalls; test and development environments separated from production;
Logging: logs of changes to settings and of administrative operations; event log relating to contacts, secured with a chain of check values;
Availability: mirroring of the database in three data centres; continuous backup with point-in-time recovery; nightly backups of the database and files at Cloudflare R2 with storage location in the EU; round-the-clock monitoring with alerting; recovery drills;
Data minimisation and files: contacts anonymised until acceptance; the Client does not receive prospects’ financing documents; uploaded files are checked according to their actual type; non-public documents are kept in protected storage without public access;
regular review of the effectiveness of the measures.

(2) GREM may adapt the measures to technical progress, provided that the agreed level of protection is not undercut.

10. Place of processing and third countries

(1) GREM processes the data in OVHcloud data centres in France (Gravelines), Germany (Limburg) and the United Kingdom (Erith); technical monitoring runs in Poland (Warsaw). Files are stored on these servers or in OVHcloud’s object storage in Germany, and backups at Cloudflare R2 with storage location in the EU; until the migration is completed, older backups remain with Hetzner Online in Germany. An adequacy decision of the European Commission exists for the United Kingdom (Art. 45 GDPR).

(2) Transfers to other third countries take place only in accordance with Art. 44 et seq. GDPR, in particular on the basis of an adequacy decision (e.g. EU-US Data Privacy Framework for certified recipients) or the standard contractual clauses of the European Commission. This concerns above all sub-processors based in the USA and the processing of videos in Singapore (Kling AI).

11. Sub-processors

(1) The Client grants GREM general authorisation to engage sub-processors. At the time the agreement is concluded, these are:

GREM CAPITAL LIMITED (London, United Kingdom), insofar as it is not itself the provider: operation and further development of the technical platform;
OVHcloud: hosting of servers, databases and object storage (France, Germany, United Kingdom, Poland);
Hetzner Online (Germany): older backups until the migration is completed;
Cloudflare: network and content delivery, protection against attacks, secured server access, relaying of calls in the app, backups (R2, storage location EU);
SendPulse: e-mail delivery;
Zadarma: SMS and telephony, including calls from the GREM account;
Google (Firebase Cloud Messaging) and Apple (Apple Push Notification service): push notifications;
OpenAI (USA): AI language models for the assistant, automatic replies, texts, translations, image editing, speech output and transcription;
AI services for image, video and audio content, insofar as transmitted content contains personal data: Black Forest Labs and Replicate (photo editing), HeyGen (videos with an AI avatar), ElevenLabs (speech output) and Kling AI (Singapore, videos from photos);
DeepL: translation of notifications;
Google (Google Maps Platform): maps and geocoding of property addresses;
Sentry, where used: error diagnostics; telephone numbers and e-mail addresses are masked beforehand.

(2) The Client receives the current list, including registered office and place of processing, on request to [email protected]. GREM informs the Client in text form at least 30 days in advance of any intended addition or replacement of a sub-processor. The Client may object for an important reason relating to data protection and, if no agreement is reached, terminate with effect from the date on which the change takes effect.

(3) GREM contractually binds sub-processors to the obligations of this agreement (Art. 28(4) GDPR) and is liable for them as for its own conduct.

12. Assistance to the Client

GREM assists the Client with appropriate technical and organisational measures in responding to requests from data subjects (Art. 12 to 22 GDPR) and in complying with the obligations under Art. 32 to 36 GDPR, taking into account the nature of the processing and the information available. GREM forwards requests from data subjects addressed to GREM to the Client without undue delay, insofar as they can be attributed to the Client.

13. Notification of personal data breaches

GREM notifies the Client of a personal data breach without undue delay after becoming aware of it, in text form, with the information available under Art. 33(3) GDPR, in phases where necessary, takes measures to contain it without undue delay and assists the Client with notifications to the supervisory authority and communication to the data subjects.

14. Evidence and inspection rights

GREM makes available the information necessary to demonstrate compliance with the obligations under Art. 28 GDPR. The Client may verify compliance by means of information, suitable evidence or, after timely notice, audits during business hours, either itself or through an auditor bound to confidentiality who is not in competition with GREM. Audits must not disrupt operations disproportionately or jeopardise the confidentiality of other customers’ data. For data centres of sub-processors, their own evidence is sufficient.

15. Deletion and return after the end of the agreement

(1) During the term, the Client may view, change and individually delete its data via the functions of the Platform.

(2) After the end of the user agreement, GREM deletes the data processed on behalf of the Client or returns them to the Client, at the Client’s choice (Art. 28(3) sentence 2 point (g) GDPR). Data are returned upon request in text form to [email protected] as a file in a common, machine-readable format; the Client makes the request before the end of the agreement or within 30 days thereafter.

(3) After the return or, if the Client has not requested a return by the end of this period, after the period has expired, GREM deletes the data, unless there is a statutory obligation to store them. If the Client deletes its account, its data are initially only no longer visible to others and are blocked, so that the account can be restored on request or a return can be requested; final deletion follows in accordance with sentence 1. Data in backups are deleted in the regular deletion cycle and are no longer processed until then. GREM confirms the deletion in text form on request. The Privacy Policy applies to data under Clause 2.

16. Liability and precedence

Art. 82 GDPR applies vis-à-vis data subjects; as between the parties, § 19 GTC applies, insofar as Art. 82 GDPR does not preclude this. In matters of data protection, this agreement takes precedence over the GTC; otherwise, the final provisions of the GTC apply.