Lead Credits and B2B CPL Terms

This Lead Credits and B2B CPL Terms document ("Agreement") is entered into between:

RERA PropTech OÜ, registry code 17251982, registered at Harju maakond, Tallinn, Kristiine linnaosa, Kuldnoka tn 22, 10619, Estonia, operating via https://rera.cy and its subdomains, as well as other country-specific domains and their subdomains ("RERA", "we", "us", "our"),

and

the business user identified in the relevant RERA account, including without limitation a real estate agency, real estate developer, bank, lender, broker, or other business customer ("Client", "you", "your").

This Agreement governs the purchase and use of prepaid credit balance on the RERA platform for lead-based services provided on a cost-per-lead ("CPL") basis.

1. Purpose and scope

1.1. RERA provides B2B lead generation and listing-related services through its platform.

1.2. Under this Agreement, the Client prepays for RERA services by topping up its account balance with service credits ("Lead Credits"), which are then applied against chargeable leads generated through the platform.

1.3. This Agreement supplements the RERA Terms of Service, Privacy Policy, Cookie Policy, and any other applicable commercial terms published by RERA or agreed separately in writing.

1.4. In the event of conflict between this Agreement and the general consumer-facing service terms, this Agreement shall prevail for B2B CPL services.

2. Definitions

For purposes of this Agreement:

2.1. Lead means a user contact or enquiry relating to the Client's listing, offer, service, financing product, or other promoted placement on the RERA platform, where the user initiates contact through one or more supported channels, including:

• WhatsApp click/contact event;
• email enquiry;
• internal platform chat/message;
• phone call/call initiation event;
• any other enquiry channel designated by RERA from time to time.

2.2. Unique Contact means an individual end user identified by one or more data points available to RERA, including but not limited to phone number, email address, account ID, device or session signals, behaviour signals, message pattern, or other anti-fraud indicators.

2.3. Deduplication Window means the period of seven (7) calendar days starting from the first recorded Lead for the same Client from the same Unique Contact.

2.4. Chargeable Lead means a Lead that is marked by RERA as eligible for billing under this Agreement.

2.5. Lead Credits means prepaid service credits purchased by the Client and available solely for payment for RERA services under this Agreement. Lead Credits are not bank deposits, electronic money, gift cards, stored value products, or a general-purpose payment instrument.

2.6. Lead Statuses:

• free – visible in the system but not chargeable;
• pending – identified as potentially chargeable and awaiting billing cycle processing and/or review;
• paid – billed and deducted from the Client's Lead Credits balance;
• refunded – a previously billed lead that has been reversed by RERA, with the corresponding amount compensated by crediting the Client’s Lead Credits balance.

2.7. Fraud Prevention Measures means the technical and organisational checks used by RERA to detect invalid, abusive, duplicated, artificial, or manipulated leads.

3. Lead Credits and payments

3.1. The Client may top up its balance through Stripe or any other payment method made available by RERA.

3.2. Funds paid by the Client are converted into Lead Credits for use only within the RERA ecosystem for services governed by this Agreement.

3.3. Lead Credits are applied against chargeable leads generated for the Client.

3.4. Unless otherwise stated at checkout or in a separate commercial offer, all prices are denominated in EUR.

3.5. VAT and other taxes, if applicable, shall be shown separately or treated as included, depending on the invoice and applicable tax rules.

3.6. The Client is responsible for keeping its billing information complete and up to date.

3.7. If a payment is reversed, charged back, or disputed through the payment provider or bank, RERA may suspend the Client account, pause service delivery, offset the disputed amount against existing balance, or require alternative payment before restoring access.

4. Lead pricing

4.1. The price of a chargeable lead may vary depending on the type of client, listing category, property segment, user intent, geography, source, platform scoring, routing logic, commercial plan, or other pricing factors determined by RERA.

4.2. The indicative lead price range is EUR 4.50 to EUR 25.00 per lead, unless otherwise agreed in writing or updated in the platform pricing.

4.3. The applicable price of a lead shall be the price assigned by the platform at the time the lead is classified for billing.

4.4. RERA may update lead pricing prospectively. Such updates do not retroactively change amounts already charged for leads with status paid.

5. When a lead is counted

5.1. A Lead is generated when a user initiates a qualifying contact action through the platform in relation to the Client's listing, offer, or service.

5.2. A Lead does not guarantee:

• that the user will respond further;
• that the user will be reachable at all times;
• that the user will book a viewing, sign a reservation, obtain financing, or complete a transaction;
• that the user is exclusive to the Client;
• that the user will meet the Client's internal qualification criteria.

5.3. RERA's service is the generation, capture, routing, and reporting of qualifying user intent and contact events, not the guarantee of a completed sale, rental, mortgage approval, or any commercial outcome.

6. Weekly deduplication rule

6.1. RERA applies a weekly deduplication model per Client.

6.2. If the same Unique Contact submits multiple enquiries to the same Client within the Deduplication Window, only one such lead will normally be treated as chargeable.

6.3. The first eligible lead within that period may receive the status pending and later paid. Subsequent related leads within the same Deduplication Window will normally be visible in the system with status free.

6.4. Deduplication applies at Client level, not necessarily at listing level. Therefore, multiple enquiries from the same person to different listings of the same Client within one week may still count as one chargeable lead.

6.5. RERA reserves the right to refine its deduplication logic where necessary to prevent abuse, correct technical anomalies, or improve fairness.

7. Fraud prevention and lead quality controls

7.1. RERA uses automated and manual checks to reduce duplicate, invalid, fraudulent, artificial, abusive, or technically corrupted leads.

7.2. Such checks may include, without limitation:

• matching by phone number, email address, account, IP/device/session signals, cookies, behavioural patterns, message similarity, and timing patterns;
• bot/spam detection;
• anomaly detection;
• suspicious activity review;
• manual moderation or support review.

7.3. Fraud Prevention Measures are intended to improve lead quality and billing fairness, but no system can guarantee the exclusion of every invalid or low-quality contact.

7.4. RERA may reclassify a lead status if new information becomes available.

8. Lead reporting and transparency

8.1. RERA will provide lead-related information in the Client dashboard or through other reporting interfaces.

8.2. The information made available may include, where applicable:

• date and time of the lead;
• listing or campaign reference;
• channel of contact;
• lead status;
• billing status;
• price;
• end-user contact details and message details, where applicable and lawful;
• relevant internal notes or support outcomes.

8.3. The dashboard record maintained by RERA constitutes the primary system of record for lead classification and billing.

9. Billing cycle and deduction mechanics

9.1. Chargeable leads may first appear with status pending and later be converted to paid.

9.2. RERA may deduct amounts from the Client's Lead Credits balance on a rolling basis or on a weekly/monthly billing cycle, depending on the commercial setup.

9.3. If the Client's balance is insufficient, RERA may:

• suspend further lead delivery;
• continue recording leads but restrict access until top-up;
• request immediate balance replenishment;
• apply other commercial restrictions.

9.4. RERA may issue invoices, receipts, statements, or balance summaries electronically.

10. Disputes, refunds, and "free" reclassification

10.1. If the Client believes a lead was incorrectly marked as chargeable, the Client may submit a dispute through support or its assigned RERA account manager.

10.2. Unless otherwise agreed in writing, the dispute must be submitted within fourteen (14) calendar days from the moment the lead becomes visible in the Client account or is marked pending/paid, whichever comes first.

10.3. The Client must provide reasonable details and supporting explanation for the dispute.

10.4. RERA may, at its discretion:

• reject the dispute;
• mark the lead as free if no deduction has yet occurred;
• mark the lead as refunded if it was already billed, with the corresponding amount credited back to the Client’s Lead Credits balance as compensation;
• request additional information.

10.5. Typical examples where RERA may approve relief include:

• duplicate lead that should have fallen within the weekly deduplication rule;
• clear spam or bot activity;
• obvious technical malfunction;
• materially corrupted or empty contact data caused by platform error;
• self-generated/internal test lead not intended as a genuine user enquiry;
• clear misrouting to the wrong Client caused by RERA.

10.6. Typical examples where RERA may reject relief include:

• the user later stopped responding;
• the Client did not answer promptly;
• the deal did not close;
• the user was not ready to transact immediately;
• the user contacted several market participants;
• the lead did not satisfy the Client's internal sales criteria;
• the Client disagrees with the commercial value of the lead after delivery.

10.7. RERA's determination on whether the lead qualifies for refund or free reclassification shall be made reasonably and in good faith, but shall be final unless otherwise required by applicable law or a separate written SLA.

11. Personal data and GDPR obligations

11.1. Leads may contain personal data submitted by platform users, including name, phone number, email address, message content, preferred contact method, and related interaction data.

11.2. The Client acknowledges that such data is shared strictly for the purpose of responding to the user's request, processing the enquiry, and pursuing legitimate follow-up related to the requested property, project, financing, or service.

11.3. The Client shall process received lead data in compliance with all applicable data protection laws, including the GDPR and applicable Cyprus and EU law.

11.4. Without limitation, the Client shall:

• use the data only for the relevant enquiry and compatible follow-up purposes;
• not sell, repackage, disclose, rent, enrich, or otherwise monetise the data unlawfully;
• not use the data for unrelated cold marketing or incompatible purposes;
• keep the data secure with appropriate technical and organisational measures;
• limit internal access to authorised personnel only;
• comply with applicable retention and deletion obligations;
• cooperate with data subject rights requests where required.

11.5. Once the lead data is shared with the Client for the Client's own business response and follow-up, the Client acts as an independent controller in respect of its own subsequent processing activities, unless the parties expressly agree otherwise in writing.

11.6. If the Client suffers a personal data breach or misuse affecting lead data received from RERA, the Client shall notify RERA without undue delay and provide sufficient information for risk assessment and mitigation.

11.7. If RERA reasonably believes that the Client has misused personal data or violated applicable privacy obligations, RERA may suspend or terminate the Client account immediately, block further lead access, and determine the treatment of any unused Lead Credits in accordance with Section 14.

12. Acceptable use of leads

12.1. The Client may use leads solely for lawful business follow-up related to the relevant enquiry.

12.2. The Client shall not:

• scrape or export lead data for unrelated databases;
• resell or transfer lead data to third parties except where strictly necessary and lawful for the requested service;
• send deceptive, excessive, or harassing communications;
• contact users outside lawful and reasonable business purposes;
• attempt to reverse-engineer RERA's fraud, scoring, pricing, or routing systems;
• manipulate the system to generate free, duplicate, or self-created leads.

12.3. RERA may monitor suspicious usage patterns and take appropriate enforcement action.

13. No exclusivity; no performance guarantee

13.1. Unless expressly agreed otherwise in writing, leads are non-exclusive.

13.2. RERA does not guarantee any minimum number of leads, conversion rate, revenue outcome, or commercial success.

13.3. RERA does not guarantee that every lead will be unique across the market, only that its own billing logic and deduplication rules will be applied in accordance with this Agreement.

14. Suspension, termination, and unused balance

14.1. RERA may suspend or terminate this Agreement or the Client account if the Client:

• breaches this Agreement;
• violates applicable law;
• misuses personal data;
• commits fraud or payment abuse;
• initiates bad-faith chargebacks;
• engages in conduct that materially harms the platform or users.

14.2. Upon termination:

• already delivered and fairly chargeable leads remain payable;
• pending disputes may still be reviewed;
• unused Lead Credits may be refunded, forfeited, or held pending investigation depending on the reason for termination and applicable law.

14.3. If termination is due to the Client's serious GDPR/privacy misconduct or fraud, RERA may freeze the balance pending legal assessment and may deduct properly accrued charges before any refund.

14.4. If RERA terminates primarily due to its own service shutdown or convenience, unused Lead Credits should generally be refundable on a prorated unused basis unless otherwise agreed.

15. Service changes

15.1. RERA may update pricing, channels, lead logic, dashboard features, fraud controls, and dispute procedures from time to time.

15.2. Material changes will become effective upon publication on the platform or other reasonable notice.

15.3. Continued use of the Lead Credits system after the effective date of an update constitutes acceptance of the updated terms.

16. Limitation of liability

16.1. To the maximum extent permitted by law, RERA shall not be liable for indirect, incidental, consequential, special, exemplary, or punitive damages, including loss of profit, loss of opportunity, or loss of goodwill.

16.2. RERA's aggregate liability arising out of this Agreement shall not exceed the total amount of Lead Credits actually used by the Client during the three (3) months preceding the event giving rise to the claim, except where such limitation is prohibited by law.

16.3. Nothing in this Agreement excludes liability that cannot be excluded under applicable law.

17. Governing law and jurisdiction

17.1. This Agreement shall be governed by and construed in accordance with the laws of the Republic of Estonia, without prejudice to any mandatory provisions of applicable European Union law.

17.2. Any dispute arising out of or in connection with this Agreement shall be subject to the exclusive jurisdiction of the courts of Estonia, unless mandatory law provides otherwise.