Terms of Service: CasaConnect

Version 1.0 • Last Updated: January 23, 2026

1. Acceptance of Terms & Contracting Entity

These Terms of Service ("Terms") constitute a legally binding agreement between Thinkable Holdings Inc., a Delaware corporation operating under the trade name "CasaConnect" (the "Company," "we," "us," or "our"), and the legal entity or registered professional you represent ("Agency," "you," or "your").

By creating an account, executing an Order Form, or using the CasaConnect platform (the "Service"), you agree to be bound by these Terms. If you are entering into these Terms on behalf of a Spanish Sociedad Limitada (S.L.) or as an Autónomo, you represent that you have the legal authority to bind that entity.

2. Description of Service

CasaConnect provides an AI-driven automation platform designed for real estate agencies, including AI-powered lead qualification, WhatsApp messaging automation, and integration with property listing databases (e.g., Resales Online, Kyero).

3. AI Accuracy and Responsibilities (EU AI Act Compliance)

3.1 Generative AI: You acknowledge that the Service utilizes Large Language Models (LLMs). While we implement safeguards, AI-generated content can occasionally be inaccurate ("hallucinations").

3.2 Agency as "Deployer": Per the EU AI Act, the Agency is the "Deployer" of the AI system. The Agency is solely responsible for monitoring and reviewing the AI’s interactions. CasaConnect is not liable for incorrect information regarding property prices, square footage, or legal conditions.

3.3 Mandatory Disclosure: You must not disable the automated "AI Disclosure" feature. Every Lead must be aware they are interacting with an AI system.

3.4 Human-in-the-Loop: The Agency warrants that a human agent will perform the final verification before any legal commitment (e.g., a viewing appointment or deposit) is finalized.

4. Third-Party Platforms (Meta/WhatsApp)

4.1 Compliance: Use of the Service requires a WhatsApp Business API account. You agree to comply with Meta’s Business Messaging Policy.

4.2 Account Health: CasaConnect is a technical intermediary. We are not responsible for account bans or "Quality Rating" drops resulting from the Agency’s messaging practices.

5. Lead Consent and Data (GDPR)

5.1 Mandatory Opt-in: The Agency warrants that it has a valid legal basis (typically explicit consent) under Article 6 of the GDPR to contact Leads via WhatsApp.

5.2 Data Processing Agreement (DPA): The processing of Lead Data is governed by our DPA, which is incorporated into these Terms by reference.

6. Subscription Fees, Taxes, and Billing

6.1 Currency: Fees are billed in USD (or EUR if specified) on a recurring basis.

6.2 Spanish VAT / Reverse Charge: For B2B services provided by a US entity (Thinkable Holdings Inc.) to a Spanish business, the Reverse Chargemechanism usually applies. The Agency is responsible for self-accounting for VAT in Spain. You must provide a valid NIF/CIF (VAT ID) upon signup.

6.3 Non-Refundability: Fees are non-refundable except as required by law.

7. Spanish Housing Law & AML Disclaimer (Critical)

7.1 Not a Brokerage: Thinkable Holdings Inc. is a technology service provider. We do not provide real estate brokerage, intermediation, or property management services as defined by Spanish Law 12/2023 (Ley de Vivienda).

7.2 AML (SEPBLAC): Because we do not act as an intermediary, Thinkable is not an "Obligated Subject" under Spanish Anti-Money Laundering laws. The Agency remains solely responsible for KYC/AML checks on its Leads.

7.3 Agency Fees: The Agency agrees not to use the Service to facilitate the collection of prohibited agency fees (e.g., charging tenants for lease management in violation of Article 20 of Ley 12/2023).

8. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, THINKABLE HOLDINGS INC. SHALL NOT BE LIABLE FOR ANY INDIRECT DAMAGES, INCLUDING LOSS OF COMMISSIONS OR PROFITS. OUR TOTAL AGGREGATE LIABILITY IS LIMITED TO THE AMOUNT PAID BY THE AGENCY IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM.

9. Intellectual Property

Thinkable Holdings Inc. retains all rights to the software, algorithms, and "system prompts" used to power the AI. The Agency retains all rights to its specific Lead Data and property listing data.

10. Termination

Either party may terminate for convenience with 30 days’ notice. Thinkable may suspend access immediately if the Agency’s use of AI is deemed "High Risk" (e.g., generating discriminatory content) or violates Meta’s policies.

11. Right to Disconnect

In accordance with Spanish digital rights (Article 88 of the LOPDGDD), the Agency is responsible for configuring its "Operating Hours" within the platform to ensure its staff and Leads' right to digital disconnection is respected outside of business hours.

12. Governing Law and Jurisdiction

These Terms shall be governed by and construed in accordance with the laws of Spain. Both parties agree that any dispute arising from these Terms shall be submitted to the exclusive jurisdiction of the Courts of Madrid, Spain.