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Transparency & compliance

Sub-processors

for ImmoVision
Last updated: 12 October 2026

This list is Annex 3 to our Data Processing Agreement (DPA). It names the service providers that process personal data on behalf of our customers, with service, purpose, location of processing and basis for transfers outside the EU.

Some services only become active if an agency sets them up itself (e.g. telephony or messengers). Services that an agency connects via its own contracts (e.g. its own Microsoft 365 or Google mailbox, CRM systems, property portals) are not sub-processors of ImmoVision; they are listed in section 3.

1. General information

We only use sub-processors insofar as this is necessary for hosting, AI functions, media processing, telephony, communication or payment processing.

Each sub-processor is bound by a contract pursuant to Art. 28(4) GDPR which imposes on it essentially the same data protection obligations as our DPA. Under their contractual terms, AI providers may not use customer data to train their models.

Not every third-party provider is a sub-processor. Payment service providers and platform operators such as Meta partly process data under their own responsibility; this is indicated for the respective provider.

2. Sub-processors

Hetzner Online GmbH

Service:

Hosting: servers, database, file storage, backups

Purpose:

Operation of the website, platform, exposés, microsites and mobile app; storage of all customer data and media

Location of processing:

Germany (Industriestr. 25, 91710 Gunzenhausen; data centres in Germany)

Role:

Sub-processor

Third country / basis:

No transfer to third countries.

Google Cloud EMEA Limited (Google Cloud / Vertex AI)

Service:

AI models (Gemini, Gemini Live, Gemini image model, Veo), voice processing

Purpose:

Texts and translations, image editing and virtual staging, video clips, dictation, voice commands, transcription and summarisation, AI assistants (chat and voice), market analyses

Location of processing:

European Union: EU region and the Frankfurt (Germany) and Netherlands regions; contractual partner Google Cloud EMEA Limited, Ireland

Role:

Sub-processor

Third country / basis:

Processing in the EU. For access by group companies in third countries (e.g. support), the adequacy decision on the EU-U.S. Data Privacy Framework and the EU Standard Contractual Clauses in Google's Cloud Data Processing Addendum apply.

Note: Under the Google Cloud terms, customer data is not used to train models.

Microsoft Ireland Operations Limited (Azure OpenAI)

Service:

AI text models and real-time voice in an EU region

Purpose:

Alternative to Google for text functions and assistants, where activated by the platform operator

Location of processing:

European Union (Azure region in the EU, e.g. Sweden)

Role:

Sub-processor, where used

Third country / basis:

Processing in the EU (EU Data Boundary). For access from third countries, the EU-U.S. Data Privacy Framework and the EU Standard Contractual Clauses in the Microsoft Product Terms apply.

Note: Under the Microsoft terms, inputs are not used to train models.

Shotstack Pty Ltd

Service:

Video rendering

Purpose:

Assembly of property and social media videos from the images, clips and texts selected for this purpose

Location of processing:

Australia

Role:

Sub-processor

Third country / basis:

Third country without an adequacy decision; transfer on the basis of the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR).

Note: Property media and video texts are transmitted, as a rule no data of prospects.

Twilio Ireland Limited

Service:

Telephony, call recording, sending of WhatsApp messages

Purpose:

Telephone calls and recording after consent of the other party; transmission of WhatsApp messages — only if the agency sets up Twilio

Location of processing:

USA (processing via api.twilio.com); contracting party Twilio Ireland Limited

Role:

Sub-processor, where set up by the agency

Third country / basis:

USA: EU-U.S. Data Privacy Framework and Twilio's Binding Corporate Rules (BCR).

Voximplant

Service:

Telephony and call recording

Purpose:

Telephone calls and recording after consent of the other party — only if the agency sets up Voximplant instead of Twilio

Location of processing:

in accordance with the data processing agreement with Voximplant

Role:

Sub-processor, where set up by the agency

Third country / basis:

Transfers to third countries only on the basis of the EU Standard Contractual Clauses.

Meta Platforms Ireland Limited

Service:

WhatsApp Business Platform, Instagram, Messenger, lead forms

Purpose:

Receiving and sending messages and enquiries from an agency's customers — only if the agency sets up these channels

Location of processing:

Ireland; group companies in the USA

Role:

Processor for the transmission of messages; independent controller for Meta's own purposes (e.g. security, platform operation)

Third country / basis:

USA: EU-U.S. Data Privacy Framework and EU Standard Contractual Clauses.

3. Services with their own responsibility and services of the agency

3.1 Stripe Payments Europe Limited

Service:

Payment processing for subscriptions and credit, fraud prevention

Role:

Partly processor for payment processing; independent controller for fraud prevention, security and regulatory obligations

Note: Stripe processes payment data of our customers (agencies), not the data of their prospects. Transfers to the USA take place on the basis of the EU-U.S. Data Privacy Framework and standard contractual clauses.

3.2 Services that an agency connects via its own contracts

The following services only become active if an agency connects them itself; processing there is governed by the contract between the agency and the service:

  • own mailbox and own calendar (Microsoft 365, Google Workspace/Gmail),
  • CRM and real estate agent software (e.g. HubSpot, Propstack, onOffice),
  • property portals (e.g. via OpenImmo),
  • register for commercial electronic communications in Turkey (İYS), providers for electronic invoices and payments in Turkey,
  • webhooks and automation services set up by the agency,
  • externally embedded 360° tours.

Used without reference to individuals: public map data (OpenStreetMap/Overpass, property coordinates only), exchange rates of the Central Bank of the Republic of Turkey. Push notifications are delivered via the push services of the browser manufacturers (end-to-end encrypted content).

4. Categories of processing by sub-processors

Depending on the booked and activated function, sub-processors may process in particular the following categories of data on our behalf:

  • master data
  • contact data
  • communication data
  • property and case data
  • user account data
  • role and permission data
  • appointment and status data
  • content from forms, exposés, microsites or CRM entries
  • uploaded media and associated metadata
  • audio content, transcripts and structured information derived from them, insofar as the corresponding functions are activated
  • technical usage and log data, insofar as these serve the provision on behalf of the customer
  • conversation content with AI assistants, insofar as the visitors have consented

5. Changes to the sub-processors

We reserve the right to add, replace or technically restructure sub-processors insofar as this is necessary for the provision of services, security, scaling or further development of ImmoVision.

We inform our customers of intended changes in advance in text form (e.g. by e-mail to the agency management and by updating this page). Customers may object within 14 days for good cause under data protection law (clause 9 of the DPA).

6. Reference to current external documentation

Insofar as providers publish their own, continuously updated documents on data protection, sub-processors, security measures or cloud regions, these are additionally authoritative.

This applies in particular to:

  • Google Cloud: Cloud Data Processing Addendum and list of Google Cloud sub-processors,
  • Microsoft: Product Terms and Data Protection Addendum,
  • Stripe, Meta, Twilio: their respective data protection and data processing terms.

7. Summary list

Sub-processors

Service:Location of processing:
Hetzner Online GmbH
Hosting
Germany
Google Cloud EMEA Limited
AI (Vertex AI: Gemini, Veo)
EU regions
Microsoft Ireland Operations Limited
AI (Azure OpenAI), where used
EU region
Shotstack Pty Ltd
Video rendering
Australia (Standard Contractual Clauses)
Twilio Ireland Limited
Telephony, recording, WhatsApp transmission (if set up by the agency)
USA (DPF, BCR)
Voximplant
Telephony, recording (if set up by the agency)
in accordance with the DPA (Standard Contractual Clauses)
Meta Platforms Ireland Limited
WhatsApp, Instagram, Messenger, lead forms (if set up by the agency)
Ireland/USA (DPF, SCC)

With their own responsibility

Service:Location of processing:
Stripe Payments Europe Limited
Payment processing, fraud prevention
Ireland/USA (DPF, SCC)