AI Transparency Notice

Version 3.0

1. Overview

Eigentum² uses artificial intelligence (AI) in two features of the platform. This notice sets out, for each of them, what the feature does, which provider performs it, exactly what data leaves our systems, what comes back, what we do with it, and what it is worth.

We describe each feature specifically rather than in general terms. A general statement that "we use AI to improve our services" would tell you nothing you could act on, and it could not support the limits and disclaimers set out below. Where a description here would otherwise be vague, we have preferred the precise fact, including where that fact is uncomfortable — see Section 3.2 in particular.

All AI features on our platform are informational tools. They assist you when you ask them to. They make no autonomous decisions, produce no legally binding outcome, and never run on your data unless you start them.

Nothing you store with us is used to train an AI model. Neither we nor our providers train, fine-tune or improve any model on your data. This is set out in the paid API terms on which we access both providers, and it is described in Section 7.

2. When AI Runs, and When It Does Not

Neither feature runs in the background. Neither runs on upload, on save, or on a schedule. Each runs once, when you press the button that starts it, and the button says what it does.

Everything else in the platform — storing documents, recording contracts and payments, generating reminders, calculating a repayment schedule, sharing a property — is ordinary software. No AI is involved and nothing is sent to an AI provider.

3. AI-Powered Features

3.1 Property Valuation

What it does. When you request a valuation, we run a sequence of AI steps: the system researches the local market, searches for comparable properties currently offered for sale, scores how comparable they actually are, and then reasons about your property against that evidence to produce an estimated value range.

Where it is available. Inside your account, for a property you have recorded. It is also available once during sign-up, in the free valuation offered by the onboarding wizard, before your account has been confirmed. In that case the property record consists only of what you entered in the wizard, and the same steps and the same provider apply.

AI provider. OpenAI, for every step. Under OpenAI's data processing addendum, personal data originating in the European Economic Area is processed by OpenAI Ireland Limited on our instruction, whichever OpenAI entity we contract with. The processing itself takes place on OpenAI infrastructure in the United States, and that transfer rests on the Standard Contractual Clauses incorporated in the same addendum (Section 7).

What is sent to the internet-search steps

Two of the steps use a web search tool. The search terms describe the property in general market terms only:

• the country, the city, and the district where one is recorded;
• the property type (apartment or house), including its usual term in the local language;
• the living area in square metres, and a search range of roughly ±20 % around it;
• the number of rooms, where one is recorded.

The street, the house number, the postcode and the geographic coordinates are never part of a search query. Those search terms reach a search provider through OpenAI.

What is sent to the reasoning step

This step receives the property record we hold, so that the estimate reflects your actual property rather than a generic one. It includes:

• Location: the full address, including street, house number, address supplement, postcode, city, region and country, and the geographic coordinates.
• Characteristics: property type and the attributes recorded for that type; building data; area measurements and room counts; year built, condition and quality; the year of the last renovation; energy data; parking spaces; and the renovation plan.
• Legal and register attributes: monument protection, flood risk and flood-zone code, contamination status, notes on easements, whether the land register has been checked, tenure type and any remaining leasehold years, the cadastral parcel identifier, the zoning code, and the area-measurement standard applied.
• Distances to public transport, the city centre, the motorway, schools and shopping.
• Purchase data: the purchase price, its currency, and the purchase date.
• Earlier valuations of the property — up to the ten most recent — with their values, dates, methods and sources.
• Listing activity: any asking price recorded, when it was listed and delisted, how long it was listed, and the view and enquiry counts recorded for an active listing.
• Rent: the rent of an active lease, broken down by rent component, and whether the property is currently let.
• Cost items in force, with their type, amount, frequency, period and free-text description.
• Free text you have entered: the property title and description, notes on easements, custom fields, and the captions and alternative text of photographs.
• Derived and system values: the price per square metre, market liquidity and investment scores, occupancy status, ownership-verification status, the automatic flags the platform sets on a property, and where the record originated (an external source and identifier, where one is recorded).
• The web addresses of up to twenty photographs of the property. Only the addresses are transmitted in this step; the images themselves are not sent, and the model has no tool with which to retrieve them.

The scoring step in between receives the country, city and district, the property type, the living area, the room count, the year built, the condition and the floor, together with the listings found in the search step.

What is never sent for a valuation

• The names or contact details of tenants, contacts, guarantors or emergency contacts, and their dates of birth, nationalities, addresses or bank details.
• Lease contracts and their documents. Of a lease, only the rent components in force are sent, with no reference to any person.
• Loan and mortgage data of any kind: lender names, borrower names, guarantors, account numbers, balances, interest rates or bank details.
• Your name, your email address, your telephone number, your user account identifier, and the name of your organisation.
• Any document or file you have uploaded.

What the AI generates. An estimated value with a range and a confidence score, the valuation approach used and the reasoning behind it, strengths and weaknesses, key value factors, a market assessment, financial ratios, limitations, recommendations, an assessment of the quality of the data available, and the comparable properties relied upon.

How the output is used. The result is recorded against your property as a valuation whose source is marked as AI, alongside the model version used, the confidence score, the value range and the analysis. It is an informational estimate only, and Section 9 sets out what that means. It is produced only because you asked for it, and it obliges neither you nor us to anything.

What we keep of the request. We store a cryptographic hash (SHA-256) of the prompt, so that an identical request within a short window returns the existing result instead of paying for a second one. The hash cannot be turned back into the prompt. We do not store the prompt itself.

Market research and comparable listings. The market figures and the listings found in the search steps are cached under the country, city, district and property type they relate to, so that a later valuation of a different property in the same area does not repeat the search. That cache holds published market data and public listing entries. It is not linked to you, to your account or to your property, and it contains no personal data of yours.

Human oversight. You decide whether to request a valuation, whether to act on it, and whether to disregard it. You can record your own valuation instead, and you can delete an AI valuation where your role in your organisation carries the permission to delete valuations.

3.2 Reading Loan and Financing Documents

What it does. In the loan wizard you can select loan documents you have uploaded — a loan agreement, an ESIS information sheet, an annual statement, a repayment schedule — and have their figures read out automatically, so that you do not have to type them in.

AI providers. Google Ireland Limited performs this reading through the Gemini API. The same documents are sent to OpenAI instead of Google if Google's service is unavailable, and in addition to Google if the figures read do not reconcile with each other, so that a second reading can settle the discrepancy. Both services process the data in the United States; for OpenAI the arrangement described in Section 3.1 applies (Section 7).

What is sent to the AI provider — please read this carefully. The documents you select are transmitted in full and unaltered, as complete files, together with their file names. The provider renders the pages in order to read them. We do not extract, redact, crop or pre-filter anything beforehand.

This means that everything printed in those documents is transmitted, including material we never ask for and do not store from them. In a German loan file that typically includes the borrower's and any guarantor's full name and address, the lender's name, the loan or account number, and bank details such as an IBAN. If the document set you select happens to contain other information — for example a residual-debt insurance schedule with health declarations, or a credit report — that is transmitted too.

This is why the selection is yours and not ours. Please select only the documents that actually relate to the loan. You can upload documents to the platform and keep them there indefinitely without ever sending them to an AI provider: nothing is transmitted unless you select it and start the reading. Where a document contains data about another person — a co-borrower, a guarantor, a spouse — you are responsible for having a basis to transmit it, and you should consider redacting the document before you upload it if you do not.

Limits. A maximum of 10 documents and 20 MB combined per request, PDF files only. Documents of any other type are refused before anything is sent.

What the AI generates. The figures of the loan — principal, outstanding balance, instalment, interest rates, fixed-rate period, dates, totals — plus the rows of the repayment schedule and the lender name and account reference as printed in the document.

How the output is used. The values are filled into the loan form for you to check and correct before you save. We do not store the result of the reading itself. It exists only in your browser until you save the loan, and what is then stored is the loan you saved, not the reading.

Human oversight. No figure read from a document is written to your records without your confirmation. The form is a draft until you save it, every field remains editable, and you can discard the whole reading.

What this feature is not. Reading the figures out of a loan agreement you already hold is a typing aid. It is no assessment of the loan, no advice on it, and no recommendation to enter into, keep, refinance or terminate it. We do not broker loans and provide no advice on real-estate consumer loans within the meaning of §§ 34c and 34i of the German Trade Regulation Act (GewO), and nothing in this feature is a creditworthiness assessment of anyone.

4. What AI Is Not Used For

We do not use AI for:

• Automated decision-making that produces legal effects concerning you or similarly significantly affects you (Article 22 GDPR);
• Credit scoring, creditworthiness assessment, or any evaluation of your solvency;
• Tenant screening, selection, or rejection;
• Profiling of individuals, including for advertising;
• Emotion recognition or biometric categorisation;
• Generating synthetic images, audio or video, or any deepfake;
• Generating text that we publish as our own or present as human-written;
• Surveillance or monitoring of individuals, including of your use of the platform;
• Moderating, filtering or screening the content you store with us;
• Deciding whether to grant, suspend or terminate your access to the platform, or setting your price.

When reading loan documents (Section 3.2), the model does judge whether a document you selected is loan-related, and declines to extract figures from one that is not. That judgement is made only on documents you deliberately selected for that purpose, and its only consequence is that no figures are returned.

5. How AI Output Is Labelled

Every AI-generated valuation is stored and displayed with its source marked as AI, together with the model version that produced it and the confidence score it reported. It is never presented as a professional appraisal, as our own assessment, or as a human judgement, and it is never mixed indistinguishably with valuations you have recorded yourself.

6. Your Rights Regarding AI Processing

6.1 Right to Be Informed

Section 3 of this notice describes each AI feature — what it does, which provider performs it, what is transmitted, and what comes back. In addition, each feature is started by an action you take yourself, at a control that names the AI as it does so.

6.2 Right to Human Review

You may disregard any AI-generated output and make your own assessment, and you may ask us to look at a result you believe is wrong by writing to support@dein-eigentum.de. For property valuations the AI estimate is one data point among others; for any decision of consequence — a sale, a purchase, a financing, a tax return, a dispute — you should obtain a valuation from a qualified professional (a publicly appointed and sworn expert, a chartered surveyor, or a valuer certified to DIN EN ISO/IEC 17024).

6.3 Right to Rectification

An AI-generated valuation is our record of what the model returned on the data available at that time; correcting it after the fact would misrepresent what happened. Where the underlying property data is wrong, you can correct it and request a new valuation, and you can delete the earlier one where your role permits it. Where a figure read from a loan document is wrong, you correct it in the form before saving, so no incorrect value is ever stored.

6.4 Data Protection Rights

The processing of your data by AI features is subject to our Privacy Policy. You have all rights under the GDPR, including access, rectification, erasure, restriction, portability, and the right to object to processing based on legitimate interests.

6.5 No Automated Individual Decision-Making

We make no decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you within the meaning of Article 22(1) GDPR.

To be precise about what does happen automatically: when you request an AI valuation, the resulting estimate is recorded against your property without a further confirmation step, because recording it is the thing you asked for. Nothing follows from that record on its own — no price is set, no contract is affected, no assessment of you as a person is made, no third party is informed, and nothing about your account changes. You can disregard it, record your own valuation instead, or delete it.

7. AI Providers, Transfers and Retention

Both providers act as our processors under Article 28 GDPR. They process the data solely to produce the output we request and for no purpose of their own.

No training. Under the paid API terms on which we access both services, data submitted through the API is not used to train or improve the providers' models. This is a contractual commitment of each provider, not an assumption on our part.

Retention at OpenAI. Every request we make to OpenAI is sent with response storage switched off, for both features, so OpenAI keeps no copy of the prompt or the answer for later retrieval and we keep none there either. OpenAI may still hold a short-lived copy for up to 30 days for the purpose of detecting misuse of its service. That is OpenAI's own safeguard, it applies to all of its API customers, and it is not a retention we can switch off on the standard terms.

Retention at Google. Google logs prompts and responses for a limited period solely to detect and prevent violations of its prohibited-use policy and to meet legal or regulatory obligations. Google's interface for this feature offers us no setting equivalent to OpenAI's, so that logging applies.

International transfers. Both providers process the data in the United States. In each case the entity that processes data originating in the European Economic Area is the provider's Irish establishment, and onward transfer to the United States is covered by the Standard Contractual Clauses incorporated in that provider's data processing addendum (Article 46(2)(c) GDPR), and, where the receiving entity is certified under the EU-US Data Privacy Framework, additionally by the European Commission's adequacy decision of 10 July 2023 (Article 45 GDPR). The notes on international transfers and on the residual risk of access by United States authorities in Sections 7.1 and 7.5 of our Privacy Policy apply to this processing as well.

For full details, see our Privacy Policy, our Data Processing Agreement and our Subprocessor List.

8. What You Should Not Put Into Free Text and Documents

Two kinds of content reach a provider without our being able to inspect it first: the free-text fields of a property (title, description, notes on easements, custom fields, photo captions and alternative text), which are sent when you request a valuation, and whole documents, which are sent when you have them read.

We therefore ask you not to record in those free-text fields any information about a person's health, religion, ethnic origin, political opinions, trade-union membership, sex life or sexual orientation, nor any other special category of personal data within the meaning of Article 9 GDPR, and no criminal-conviction data within the meaning of Article 10 GDPR. Those fields exist to describe a property, and nothing about a valuation requires such information.

For documents, the same caution applies at the moment of selection rather than at the moment of typing: select only what relates to the loan, and consider whether a document you are about to send contains more than the loan.

If such information does reach us, our handling of it is governed by Section 4.5 of our Privacy Policy.

9. Limitations and Disclaimers

9.1 An AI Valuation Is Not an Appraisal

An AI-generated valuation is a statistical estimate derived from the data you have recorded and from market information published on the internet. In particular, and without limitation, it is not:

• a determination of market value (Verkehrswert) within the meaning of § 194 BauGB, and not a valuation report (Wertermittlung or Gutachten) within the meaning of the German Real Estate Valuation Ordinance (ImmoWertV);
• an appraisal by a publicly appointed and sworn expert, or by any certified valuer;
• a mortgage lending value (Beleihungswert) within the meaning of the Beleihungswertermittlungsverordnung (BelWertV), and not usable for any purpose under the Pfandbriefgesetz or the lending rules that refer to it;
• a valuation for tax purposes within the meaning of the Bewertungsgesetz, and therefore not a basis for a property tax (Grundsteuer), inheritance tax (Erbschaftsteuer) or gift tax (Schenkungsteuer) declaration, and not something a tax authority is obliged to accept;
• evidence in proceedings before a court, an authority, a notary or a bank;
• a recommendation to buy, to sell, to let, to finance or to invest;
• legal, tax or financial advice, and no advisory relationship arises from it.

It may differ significantly from a professional appraisal, from an official assessment, and from the price actually achieved. Factors it cannot capture — the interior condition, undocumented defects or improvements, encumbrances not recorded in the platform, micro-trends in the immediate location, and the circumstances of an individual transaction — may materially affect the actual value.

9.2 AI Output May Contain Errors

AI models can produce inaccurate, incomplete or inconsistent results, including results that are stated confidently and are nonetheless wrong. Figures read from a document may be misread. We do not warrant the accuracy, completeness or reliability of any AI-generated output. You are responsible for verifying it before relying on it, and the loan wizard is built to make that verification the normal step it is: it shows you the figures and asks you to confirm them.

9.3 Liability

Our liability for AI-generated output is governed by the liability provisions of our Terms of Service, and nothing in this notice extends, restricts or replaces them. AI valuations are provided as informational estimates only and give rise to no warranty, no guarantee, and no advisory or information obligation. Neither the provision of an AI valuation nor its content constitutes advice or a recommendation within the meaning of § 675(2) BGB.

Nothing in this Section limits our liability for injury to life, body or health, for intent or gross negligence, for the breach of a cardinal contractual obligation, under the Produkthaftungsgesetz, or in any other case where liability may not be limited by law.

10. Our Position Under the EU AI Act

We are a deployer, and in respect of the two features described above also a provider, of AI systems within the meaning of Regulation (EU) 2024/1689 (the AI Act). We set out our position openly so that you can assess it yourself.

Not prohibited practices. Neither feature engages any practice prohibited under Article 5.

Not high-risk. Neither feature falls within the high-risk categories of Annex III. In particular, neither is used to evaluate the creditworthiness of a natural person or to establish a credit score, neither is used in employment or in access to essential services, and neither is a safety component of a product. Reading the figures out of a loan document you already hold makes no assessment of any person.

Article 50. The specific transparency duties in Article 50 have applied since 2 August 2026. We have assessed each of them:

• Article 50(1) — systems that interact directly with natural persons. Neither feature is a conversational system. Each is a single request that you make and a single result that comes back, at a control that names the AI. Even on the widest reading, that an AI is at work is stated rather than obvious.
• Article 50(2) — marking of synthetic content. The reading of loan documents falls within the exemption for a system that does not substantially alter the input data or its semantics: it reports the figures printed in your document and adds nothing. A valuation does contain text the model has written. We do not disseminate that text, present it as our own, or present it as written by a person: it is stored and displayed under an explicit AI source label, with the model version alongside it (Section 5). To the extent that Article 50(2) reaches output of this kind, that labelling is how we meet its purpose, and we will apply a machine-readable marking if and to the extent the applicable harmonised standards call for one.
• Article 50(3) — emotion recognition and biometric categorisation. We operate no such system.
• Article 50(4) — deepfakes and AI-generated text on matters of public interest. We publish no AI-generated image, audio, video or text.

We provide this notice, whichever of the above applies, because we consider that the transparency the AI Act is built on should hold whether or not a particular paragraph compels it.

AI literacy (Article 4). We ensure that the persons who operate these features on our side have a sufficient understanding of them, and this notice, together with the wording at each control in the product, is how we extend that understanding to you.

This notice is additionally provided in fulfilment of Articles 12, 13 and 14 GDPR (information obligations) and with regard to Article 22 GDPR (automated individual decision-making).

11. Changes to This Notice

We will update this notice when we introduce a new AI feature, change the provider or the model family behind an existing one, or change what is transmitted. Material changes are notified through the platform, and the version and effective date above are updated in every case. Superseded versions are archived and available on request.

12. Contact

Questions about our use of AI:

Email: support@dein-eigentum.de Postal address: Ilya Baskakov, Von-Müller-Straße 15a, 82467 Garmisch-Partenkirchen, Germany

The effective date of this version is displayed above this document.