Privacy Notice

1. What personal data we collect

Depending on how you use the Platform, we may process:

• Account data — name, email address, hashed password, phone number, preferred language, and account role (user, broker, or admin).
• Listing & FSBO data — property address, descriptions, photographs you upload, asking price, and property characteristics (bedrooms, bathrooms, size, lot size, build year, tenure).
• Valuation/appraisal inputs — address and property details you enter to get an estimate (size, lot, build year, tenure, condition, amenities).
• Saved searches & preferences — search filters you save (neighbourhood, price range, property type, etc.).
• Favorites & recently-viewed — listings you save or view while signed in.
• Inquiry messages — the content of messages you send through the Platform to brokers or sellers, and your contact details.
• Uploaded photographs — images submitted with FSBO listings or appraisal requests. Photos may contain embedded metadata (such as device or location data); we use them only to provide the service you requested.
• Chatbot conversations — the content of conversations with our AI assistant, BoB.
• Technical & usage data — IP address, browser and device type, pages and listings viewed, search terms, and timestamps, collected automatically via server logs and (with consent) analytics.

We do not require special categories of sensitive data to use the Platform, and we ask you not to send us any (see section 8).

2. How we collect it

We collect data directly from you (when you register, submit a listing, request a valuation, send an inquiry, or chat with BoB); automatically (server logs, and — only with your consent — cookies and analytics, as described in our Cookie & Privacy Notice); and from third parties (listing data from brokers and public sources, which can include broker or agent contact details). When a listing is first obtained from a public broker source, we rely, where applicable, on the public availability of that information and on the notification exceptions under the Wbp BES; brokers and rights-holders can request correction or removal at any time (section 11).

3. Why we process it & our legal basis

We process personal data only for the purposes below, each on a lawful ground under Article 8 of the Wbp BES — performance of our agreement with you ("contract"), our legitimate interest ("legitimate interest"), a legal obligation, or your consent:

• creating and managing your account, and providing account-gated features — contract;
• showing listings, saved searches, favorites, recently-viewed, and recommendations — contract;
• publishing and managing FSBO listings, and producing valuation estimates — contract;
• routing your inquiries to brokers or sellers and sending transactional emails — contract;
• operating the BoB assistant and (where we log conversations) reviewing quality and safety — contract and, for optional logging, consent;
• keeping the Platform secure and preventing fraud or abuse — legitimate interest;
• geocoding property addresses for maps and search-by-location — legitimate interest;
• analytics to understand usage and improve the Platform — consent (opt-in via the cookie banner);
• complying with applicable law — legal obligation.

Where we rely on your consent, you can withdraw it at any time (in your cookie settings, account settings, or by contacting us); this does not affect processing carried out before you withdraw. We do not sell your personal data.

4. Who we share it with

We share personal data with:

• Brokers and sellers — when you send an inquiry, we forward your message and contact details to the relevant party, who then handles your data as their own controller;
• Service providers (processors) who process data on our instructions, including: Hetzner (Germany — our application servers and database); Cloudflare (USA — content delivery and security); Google Analytics / Tag Manager (USA — consent-gated analytics; we do not send your name or email to Google Analytics); Postmark (USA — transactional email); our self-hosted automation (n8n, on our EU servers); and our AI provider — Anthropic (Claude) or OpenAI (ChatGPT), depending on the active configuration (both USA) — which processes BoB conversation content as our processor to generate responses. We use the Nominatim geocoding service (OpenStreetMap) for map coordinates, sending only the property address — no user data;
• Authorities — where we are legally required to disclose data to a competent BES authority or court.

We put a written processor agreement in place with our processors, as required by Article 14 Wbp BES.

5. International transfers

Some processors are outside Bonaire. Our application data is stored in the European Union (Germany), which provides a high level of protection under the GDPR. Some providers are in the United States (Google, Cloudflare, Postmark, and our AI provider); we use these only where they participate in the EU–US Data Privacy Framework or have entered into EU Standard Contractual Clauses, which we rely on as an adequate safeguard under Article 43 of the Wbp BES. A current list of our processors and their locations is available on request.

6. How long we keep it

We keep personal data only as long as needed for the purpose it was collected (Article 10 Wbp BES). Our typical retention periods are:

• Account data — while your account is open, and up to 2 years after you close it;
• Inquiry messages — up to 2 years from the last activity on the conversation;
• Saved searches, favorites, recently-viewed — for the life of your account; deleted promptly when you close it;
• FSBO listing data and photos — while the listing is active, plus about 1 year after it is archived, or until you ask us to delete them;
• Valuation/appraisal inputs — up to 2 years from the request;
• BoB chat transcripts — up to 90 days, unless you ask us to delete sooner;
• Server/access logs — 30–90 days;
• Analytics data — up to 14 months.

We may keep data longer where the law requires it (for example, a pending legal claim) or shorter where you exercise your deletion rights and there is no overriding reason to keep it.

7. Security

We use appropriate technical and organisational measures to protect personal data against loss and unauthorised access, in line with Article 13 Wbp BES — including encryption in transit (HTTPS), access controls, hashed passwords, and security requirements on our processors. No system is completely secure; if a significant incident affects your data, we will let you know as soon as reasonably practicable.

8. Cookies, analytics & sensitive data

For how we use cookies and similar technologies — including the strictly-necessary sign-in cookie and the consent-gated analytics cookies — see our Cookie & Privacy Notice. Analytics load only after you accept. Please do not send us sensitive information you are not asked for (such as bank details, passport or tax numbers, health or other special-category data), and in particular do not share it with our AI assistant (see section 8 of the Terms of Service).

9. Children

The Platform is intended for adults; you must be at least 18 to hold an account. Under the Wbp BES, processing the data of a person under 16 requires consent from a parent or guardian. We do not knowingly collect data from minors. If you believe a minor's data has been provided to us without the appropriate consent, please contact us and we will delete it.

10. Your rights

Under the Wbp BES you may:

• Access (Art. 27) — ask for an overview of the personal data we hold about you, its purposes, recipients, and origin;
• Correct, delete, or block (Art. 28) — ask us to correct inaccurate data, delete data we no longer need, or block data whose accuracy is disputed;
• Object (Art. 32) — object, on compelling personal grounds, to processing based on our legitimate interest;
• Opt out of direct marketing (Art. 33) at any time;
• Ask for human review (Art. 34) of any decision made solely by automated means that significantly affects you.

To exercise a right, email info@bonaire-brokers.com with "Privacy request" in the subject and enough information to identify you. We respond within four weeks. Any fee will not exceed USD 5 (Article 31 Wbp BES) and is refunded if we have to make a correction.

11. Complaints & corrections

If you have a concern, please contact us first at info@bonaire-brokers.com — including to report content that is inaccurate, outdated, or published without authorisation. You also have the right to lodge a complaint with the Commissie toezicht bescherming persoonsgegevens BES (CBP BES), the independent supervisory authority for Bonaire, Sint Eustatius, and Saba.

12. Changes to this Notice

We may update this Notice from time to time. When we make a material change we will update the effective date above and, where feasible, notify registered users by email. Continued use of the Platform after a change takes effect means you accept the updated Notice.

13. Contact

Bonaire Brokers b.v., Kaya Ir Statius van Eps 17, Belnem, Bonaire, Caribbean Netherlands (KvK 13489 · CRIB 310028814). Email info@bonaire-brokers.com or call +599 795 77 77.