Solutions · Real estate

Telegram bots for real estate.

A point of access to information and operations, in conversation. This page places the service mechanism alongside the rules that apply in real estate — without claiming a project we have not done.

Discuss your scenario

Starting point

What real estate looks like before any software

The agency’s product is not the dwelling, but the advert about it — and the advert is made from photographs of someone’s home. The agent gets the keys, enters an occupied flat alone and photographs the rooms as they are: the kitchen with magnets on the fridge, the office with papers on it, the child’s room with the name on the door. The owner asked for the flat to be sold. What exactly he agreed to publish was never discussed, because it did not seem like a necessary discussion.

There is no system, there are four places that do not talk to each other. Ad portals, where the public version sits. A spreadsheet with properties and phone numbers. The messaging thread with the owner and another with each buyer. And the agent’s memory, which is by far the richest of the four. The same property sits at three agencies at once, with three prices and three descriptions, and the owner spoke in person only with the first one.

The buyer says everything in the first few minutes, without being asked. How much they have, where the money comes from, whether it is credit or cash, whether it is a move after a divorce, how many children, what school, why they are in a hurry. None of this appears in a form and precisely for that reason none of it has a written basis. It ends up in a note, in a message, in a head. It is the most valuable commercial information in the whole agency and the least managed.

The register of immovable property is not browsed. The information in the cadastre is obtained as a service, from the institution that keeps the register, and continuous access to the register is made through an account, on an authenticated platform. That distinction is constantly ignored in discussions about “public data”: the fact that a property exists and has a cadastral number does not make the owner’s name information that anyone collects on their own, whenever they want, in whatever volume they want.

On the day the agency moves from showing flats to assisting the transaction, it enters a second regime, with a different logic from data protection. There the obligation is not to collect less, but to collect more — client identity, beneficial owner, source of funds — and to keep what was collected for years after the relationship has ended. The two regimes do not contradict each other, but they pull in opposite directions, and the system that does not know which file is of which kind breaches both.

Channel, voice note, lead notification

Regulile

What applies in real estate, with the article it comes from

Each rule below carries the normative act that imposes it. Verification does not require you to take our word for it.

Real estate data has no separate exception. It relies on the general grounds, explicitly chosen

There is no “real estate data” category in the law. There are ordinary personal data, and each processing operation needs one of the six grounds, chosen before collection, not built afterwards. The relationship with the owner who signed a mandate and with the buyer who requested a viewing relies on contract performance or on measures taken at the person’s request before the contract. Collecting contacts from adverts published by others, prospecting and scoring buyers do not rely there — they need legitimate interest, which must be demonstrated, or consent. Data must be collected for specified, explicit and legitimate purposes, and not further processed in a manner incompatible with them.

SourceLaw 195/2024, art. 6 para. (1) lit. a), b) and f), art. 5 para. (1) lit. b) and c), art. 5 para. (2)

The real estate agent is a reporting entity, but only while participating in the transaction

The anti-money laundering regime does not apply to the agency permanently, nor from the moment it is registered. The Service’s methodological manual says that lawyers, notaries, accountants, auditors and real estate agents become subjects of the reporting regime only during participation, on behalf of the client, in any financial and real estate transaction, or while providing assistance with planning or carrying out the transaction — sale and purchase, donation, handling of funds, purchase and sale. The distinction has a direct consequence in any system: a file opened for someone who merely looked at two flats is not a precaution file and cannot be kept as if it were.

SourceThe methodological manual of the Anti-Money Laundering Prevention and Combating Service for non-financial professions, point 65 (which cites art. 11 of Law No. 308/2017)

What is collected for precaution is kept for five years, including copies of identity documents

Reporting entities keep all documents and information about clients and beneficial owners obtained within the framework of precaution measures — expressly including copies of identification documents, the archive of primary documents, business correspondence — for the active period of the business relationship and five years after its termination, or after the date of occasional transactions. At the Service’s request, the term may be extended, but by no more than another five years. For these data, the right to erasure does not apply insofar as processing is necessary to comply with a legal obligation — which means that the correct response to an erasure request is not “yes” and not “no”, but a separation between the business file and the compliance file.

SourceThe methodological manual of the Anti-Money Laundering Prevention and Combating Service, points 68 and 69; Law 195/2024, art. 6 para. (1) lit. c), art. 17 para. (3) lit. b)

Supervision of the sector is by the state, directly, and the sector is rated among the most vulnerable

For lawyers, supervision is carried out by the Bar Association; for notaries, by the Notarial Chamber; for auditors, by the Public Audit Oversight Council. For real estate agents, supervision is carried out by the Service for Prevention and Combatting Money Laundering itself, within the limits of monitoring compliance with the legislation in the field. And the vulnerability table in the national risk assessment, reproduced in the Service’s manual, gives real estate agents the “Medium-Elevated” level — the highest among the professions listed there, with the reasons stated explicitly: use of cash in real estate transactions and the absence of identification and reporting of suspicious transactions.

SourceThe methodological manual of the Anti-Money Laundering Prevention and Combating Service, point 15 lit. f) and point 30

Reporting has forms and deadlines, and one of them is measured in hours

There are three types of reporting, with different rhythms. Suspicious transactions are reported using a special form within no more than twenty-four hours from identifying the circumstances giving rise to suspicion. Cash activities or transactions of at least one hundred thousand lei, through one operation or through several that appear to be linked, are reported monthly. Transfers by bank transfer of at least five hundred thousand lei are reported by the 15th day of the following month. The twenty-four-hour deadline is the one that matters for system design: it is the only one that cannot be met by a process done at the end of the month.

SourceThe methodological manual of the Anti-Money Laundering Prevention and Combating Service, point 64 lit. a)–c) and point 66

The information from the cadastre is requested, not collected

The cadastre of immovable property is regulated by its own law, and the register is kept by a public institution whose services explicitly include supplying information from the field of the cadastre. Continuous access to the register exists as a separate service, under authentication. None of this describes an open source from which an agency completes its owner database by itself. The consequence for any system built for an agency: checking the owner is an act with a trace, carried out through a specific channel, not an automatic enrichment of the record.

SourceThe Cadastre of Immovable Property Law no. 1543-XIII of 25.02.1998, listed as the basic act on the “Legislation” page of the Public Institution Cadastre of Immovable Property; the services page of the same institution (“Services for providing information in the field of the cadastre of immovable property”; “Active access to the Real Estate Register”, with authentication)

The building has its own law, and tenant data do not belong to the agency

The condominium is regulated separately, by Law No. 187 of 14.07.2022, currently listed as a basic act in the field. For an agency that manages or intermediates in buildings, the distinction that matters is that tenant data — lists, contacts, arrears, meeting decisions — belong to a different relationship than real estate intermediation. They are not inherited together with the management contract and cannot be reused for prospecting: further processing for another purpose is permitted only if it is compatible with the original purpose, and compatibility is assessed according to the link between purposes, the context of collection, the nature of the data and the consequences for individuals.

SourceThe Law on Condominiums no. 187 of 14.07.2022, listed on the “Legislation” page of the Public Institution Cadastre of Immovable Property; Law 195/2024, art. 5 para. (1) lit. b), art. 6 para. (5)

Prospecting owners is direct marketing and stops at the first objection

The law defines direct marketing as the communication, by telephone, post or any other direct means of communication, of advertising or promotional messages for goods or services, directed at private individuals. Calling an owner who has placed their own listing, in order to offer them the agency’s services, falls exactly within that definition. The person has the right to object at any time to processing for that purpose, including profiling related to them, and upon objection processing for that purpose stops. The right must be brought explicitly to the person’s attention no later than the first communication, presented clearly and separately from any other information — therefore in the first call, not in the website policy.

SourceLaw 195/2024, art. 4 (the definition of “direct marketing”), art. 21 para. (2)–(4), art. 6 para. (1) lit. f)

Mecanica

What Telegram bots do, concretely

The same capabilities that appear on the service page, where each has its own file and back-end line.

First, we check what public door the system has

For WooCommerce stores, we use the public store API, which does not require a consumer key: the client connects only with the site address. It is a choice with real consequences, not just an aesthetic one — we replaced with it hand-written tools that kept store keys in clear text in the database. When the system has no public door, we move to authentication, but then the key becomes something to be managed, not something forgotten in a database row.

Keys stay on the server, not in the tool and not in the page

The SMS tool is internal to the platform precisely because the environment where a tool’s own code runs does not have access to environment variables — if sending were done from tool code, the key would have to be written to the database, and that key can send messages at everyone’s expense. The same with the scheduling system: the partner token is a single one, kept in the server environment, while the client only sets their company identifier.

The agent calls the tool during the conversation, with parameters and a deadline

Each tool has a description written for the model, typed parameters with what is required and what is not, and its own execution deadline — from 15 seconds for a list of services to 30 for an availability search. The deadline per tool is not a detail: without it, a slow integration blocks the conversation, and the person on the other end hears silence.

Real bookings in the salon or clinic system

Six tools over Altegio: the list of services with real prices, specialists, full availability, booking creation, cancellation and editing. Availability does not return only “free/busy”: it returns which specialists perform the requested service and the first free times for each, sorted by the earliest, precisely so the agent can propose a concrete alternative instead of saying “not available”.

The store catalogue, read live

Price and availability are read from the store at the time of the question, not from an outdated copy. The catalogue is loaded paginated, up to 30 pages of 100 products each, kept in a temporary ten-minute cache per site and normalised into a single form, read unchanged by all consumers — including the product carousel in messaging, which needs a numeric price, and the widget on the page, which needs a title.

CRMs, spreadsheets and messaging channels

amoCRM and Bitrix24 with full OAuth, token refresh and status verification. Google Sheets through a dedicated service account, separate from the rest of the credentials, with writing triggered by the agent. Telegram for lead notifications. SMS through Infobip. Plus the chat channel of a local classified ads platform, connected with its own refresh token — the kind of integration that does not exist in any international catalogue and that matters very much locally.

The service, in detail

The data

What every system in the industry addresses

The categories of data held by imobiliare, with the legal basis for retention where the law provides it.

The owner’s data and their connection to the property: Name, contact details, mandate, title deed, cadastral number, accepted price, reason for sale. The cadastral number is data about an asset, but in the agency’s hands it is an identifier that links a person to an address, so it cannot be treated as neutral information. The mandate is the document that says exactly what the agency is allowed to do on behalf of the owner, and in practice it is also the only place where one could write what is published and what is not.Keep: How long the mandate lasts and the period during which the transaction may still be contested, plus the accounting obligations. A property dossier kept after sale “for history” needs a term written in the record of processing activities, otherwise it becomes an archive without basis.SourceLaw 195/2024, art. 6 para. (1) lit. b), art. 5 para. (1) lit. c) and e), art. 30 para. (1) lit. c) and f)
Photographs and video recordings from inside the home: These are the sales material and, at the same time, a picture of the private life of people who often still live there. They may contain faces, documents, objects that reveal religious beliefs, affiliation, or the health status of someone in the household. Publication is a separate purpose from documenting the property and must be required as such. Once uploaded to portals, the images are taken up, replicated and indexed, and their removal no longer depends on the agency — the obligation to make reasonable efforts towards the other controllers remains theirs, however.Keep: Related to the duration of the listing and its withdrawal after sale. Practically: a written term for the internal archive and a withdrawal process from external channels, because the expiry of the listing on a portal is not deletion.SourceLaw 195/2024, art. 5 para. (1) lit. b) and e), art. 6 para. (1) lit. a) and b), art. 17 para. (2)
The buyer’s brief: Budget, source of funds, credit approved or not, family composition, reason for moving, urgency. It is the most commercial information in the agency and the least formalised: it does not come from a form, it comes from a conversation. When it contains the real reason for moving, it can affect private life in ways that go far beyond “search preferences”. The person must be informed, at the time of collection, about the purposes, basis, recipients, retention period and rights — including when the data were spoken, not filled in.Keep: How long the search takes and a short, written period after it ends. A brief kept for years “for when they want to sell” is a new processing operation, with a different purpose, which needs its own basis.SourceLaw 195/2024, art. 13 para. (1) and (2), art. 5 para. (1) lit. c) and e), art. 6 para. (1) lit. b)
The customer due diligence file: Copy of the identity document, the data of the beneficial owner, the checks carried out, business correspondence, the results of analyses of complex or unusual transactions. It is the only category in the agency whose retention is imposed from outside and is, not coincidentally, also the most sensitive to leaks: a copy of an ID card is the raw material of identity fraud. It is kept separately from the commercial dossier, with restricted access, precisely because it cannot be deleted on request.Keep: Five years from the termination of the business relationship or from the date of the occasional transaction; extendable at the Service’s request, but by no more than another five years.SourceThe methodological manual of the Anti-Money Laundering Prevention and Combating Service, points 68 and 69; Law 195/2024, art. 6 para. (1) lit. c), art. 32 para. (1)
Physical access: keys, viewing schedule, who enters and when: It does not look like personal data and it is the most concrete risk in the industry. Whoever has the key, at what time the apartment is free, when the owner is away, who was scheduled to come — combined, these tell a family exactly what a stranger should not know. There are also personal data of scheduled buyers. The security obligation is measured by the severity of the consequences, and here the consequence is not a fine, it is an empty house at ten o’clock.Keep: How long the mandate lasts, plus a short period for proof of activity. The access log has no place in the same location as the advert.SourceLaw 195/2024, art. 32 para. (1) and (2), art. 5 para. (1) lit. f), art. 25 para. (2)
The messaging thread, calls and contacts from the agent’s phone: The agency’s largest database sits on agents’ personal phones, in three messaging apps. It contains owners, buyers, actual prices, reasons for sale and photos. It is not declared anywhere, has no retention period and leaves the company with the person. When data pass through a channel provider or through a portal, that party is either a processor or a controller in its own right, and the role is determined by who decides the purposes and means — not by what is written in the terms of use.Keep: Undefined in practice, which is precisely the problem. A term can only be set if the thread is moved to the company’s own space; on a personal phone, the term is “until the phone is changed”.SourceLaw 195/2024, art. 4 (the definitions of “controller” and “processor”), art. 28 para. (1) and (3), art. 26 para. (1), art. 30 para. (1) lit. d) and f)

Limbajul

The words people there use

An agent that says “programming” where the industry says otherwise is immediately heard as foreign. That is why vocabulary goes into configuration, not into the glossary at the end.

Notice: The industry’s unit of work: one property, one price, one set of photos, one phone. It is not a product page — it is withdrawn, reactivated, duplicated at three agencies and lives simultaneously on portals that do not sync. Any system built for an agency is judged by what it does when the same flat appears three times.
Exclusivitate: The arrangement under which the owner works with a single agency. It changes the economics completely: without it, the agent competes with two others on the same property and is paid only if first. It explains why response speed is the industry’s obsession and why data never reach a common system.
Vizionare: The visit to the property, with a scheduled time, a key and people meeting in an occupied home. It is the moment when the industry simultaneously touches the owner’s private life and the buyer’s data, and the only step that cannot be done online.
Cadastral number: The identifier of the immovable property in the register. It is the key used to request official information about the property. In an agency database it functions as a link between a person and an address, so it is not a neutral technical code.
Extract from the immovable property register: The document that confirms who the owner is and what encumbrances exist. It is obtained as a service from the institution that keeps the register, not generated. It is also the moment when “I think it is theirs” becomes “it can be shown that it is theirs”.
Antecontract: The prior understanding by which the parties bind themselves to conclude the contract, usually accompanied by a sum paid in advance. It is the threshold from which the relationship becomes a transaction and from which the agency’s compliance regime also changes.
Condominiu: The legal form of the multi-owner block, regulated by its own law. The word matters because it brings with it a second group of people — residents — whose data have no connection with the intermediation of a sale.
Beneficial owner: The natural person behind a client who is a legal person or behind a fiduciary-type arrangement. The term comes from the anti-money laundering regime and is why the questions in the file go beyond the identity document of the person in front of you.
Politically exposed person: Client who occupies or has occupied an important public office, or who is a relative or close associate of such a person. The status triggers enhanced due diligence measures, and the examples in the Service’s methodological manual for this sector start with a family member of such a person.

Where it breaks down

What goes wrong when real estate is digitised in a hurry

The advert says more than the owner agreed to

The mandate speaks about sale and commission. The photos end up on five portals, are taken by aggregators and indexed. From the child’s room, the name on the door is visible; from the fridge, a treatment schedule can be read. No one decided to publish this; it was published because it was in frame. When the owner requests removal, the agency discovers that it controls only the first of the five places, and the duty to make reasonable efforts towards the others remains with it.

The same property at three agencies, one informed owner

The owner spoke with the first agency. The other two took over the advert, rewrote the description and added their own phone number. There are now three controllers processing the data of the same person and the same home, two of whom have informed no one of anything. The effect is seen late and badly: the owner receives calls from buyers sent by agencies they never worked with, and their request for deletion must be repeated three times, to three companies that do not know each other.

The compliance file becomes the agency archive

It starts correctly: copy of identity document, beneficial owner check, a file. Then the file becomes the place where everything goes in — including for clients who never reached a transaction and for whom the obligation had not even been triggered. The result is an archive of identity document copies kept for five years for people who only visited two flats, i.e. exactly the combination of high volume, high sensitivity and absent legal basis. Separating the two files is not a bureaucratic refinement; it is the difference between being able and not being able to respond to a deletion request.

The key and the schedule are treated as logistics, not as risk

Who has the key, when the flat is free, when the owner is away — the information circulates through messages, between agents who change, sometimes also to external collaborators. It does not look like a database, so it does not enter any assessment. The security obligation is measured, however, by the risk with different degrees of likelihood and severity for persons, and here the severity is maximum and obvious. It is the only place in the industry where a data leak does not result in a fine, but in a break-in.

The client relationship belongs to the agent, not to the agency, and leaves with them

A personal phone, three messaging apps, contacts saved with nicknames. While the agent is in the firm, it seems like the most efficient system possible. On the day they leave, the agency loses at the same time the commercial relationship and the ability to fulfil its obligations: it cannot show what data it holds, it cannot erase them on request, it cannot demonstrate what instructions it gave. And the principle of accountability requires the controller to be able to demonstrate compliance, not merely state it.

Questions

What someone in real estate asks before buying software

Can we take the owners’ contacts from the adverts they published and call them with our offer?

The fact that a phone number is visible publicly does not create a basis for processing for another purpose. The commercial call is direct marketing within the meaning defined in the law, and if the basis invoked is the agency’s legitimate interest, this must be actually weighed against the interests and rights of the person, not presumed. What is strictly necessary: the right to object brought explicitly to the person’s attention no later than the first communication, presented clearly and separately; immediate stopping of processing for that purpose upon objection; and a record of objections that is consulted before the next campaign, not after the first complaint. A sales advert is an invitation from buyers, not from agencies.

Do we need the owner’s consent to publish the indoor photos?

Publication must have a basis, and the cleanest one is the mandate itself — if the mandate states what is photographed, what is published and on which channels, the publication falls under the performance of the contract. If the mandate is silent, the agency relies on an assumption. Separate from the basis remains the principle of minimisation: photographs that show documents, faces, objects revealing someone’s beliefs or health condition in the house are not necessary to sell the flat. In practice, the most effective measure is not an extra form, but a photography rule and a review before publication.

A buyer asks us to erase their data. Do we erase everything?

It depends on which file they have. If there was only a commercial relationship — viewings, a brief, correspondence — and the basis was the contract or withdrawn consent, the data are erased without undue delay. If a precautionary file was opened because the agency assisted a transaction, the right to erasure does not apply insofar as processing is necessary for compliance with a legal obligation, and the term of that obligation is five years from the end of the relationship. The correct answer is therefore partial and must be motivated, within at most one month from the request, with the possibility of extension by two months and informing the person in the first month. This presupposes that the two files are separate in the system — if they are a single table, the agency can neither erase nor demonstrate why it did not erase.

Can we check ourselves who the owner is, by address?

The information from the cadastre is obtained through the services of the institution that keeps the register, and continuous access to the register exists as a service with an account and authentication. It is not an open database from which a record is filled in automatically. For an IT system, the practical consequence is that the owner check is a step with a trace and a basis — it is done for a specific property, in a specific file, and is recorded —, not a mass enrichment of the list of addresses. The consolidated text of the cadastre law could not be opened on the day of the check, so no article from it is cited here: what is stated above is based on the official list of acts and the institution’s services page.

Can an automated assistant pre-qualify buyers?

It can collect what the buyer says, can propose properties that match the declared criteria and can pass them to an agent. What it cannot do is make on its own a decision that affects the person to a significant extent — rejection of a client, refusal of a viewing, placement in a category that changes their treatment. The person has the right not to be subject to such a decision, and where the exceptions apply, the controller must ensure at least human intervention, the expression of the point of view and contesting the decision. In addition, the existence of an automated decision-making process must be communicated to the person at collection, together with relevant information about the logic used.

We are two agents. Do the anti-money laundering prevention rules apply to us?

It does not depend on size, it depends on what you do. The reporting regime is triggered during participation, on behalf of the client, in a real estate transaction or during the provision of assistance for planning or carrying it out. An agency that only makes the introduction and withdraws before the transaction is in a different situation from one that assists the sale to the end. What does not depend on size at all: sector supervision is carried out by the Service for the Prevention and Combating of Money Laundering itself, and the National Risk Assessment places real estate agents at the “Moderately Increased” vulnerability level, with the use of cash explicitly mentioned as a sector issue.

Can we record calls that come from ads?

Recording is an independent processing operation and needs its own legal basis, separate from the fact that the call takes place. If the basis is legitimate interest, the person has the right to object on personal grounds, and the processing stops if the agency does not demonstrate legitimate and compelling overriding reasons. Regardless of the basis, the person must be informed at the time of collection about the purpose, basis, recipients and storage period — or about the criteria used to determine the period, when it cannot be given exactly. A switchboard left on the default setting does not produce a period set by the controller; it produces an arbitrary period.

Are ad portals processors or independent controllers?

This is determined by who decides the purposes and means of the processing, not by how someone describes themselves in the terms of use. A portal that only hosts what the agency publishes, at its instruction, is a processor and requires a contract with the object, duration, nature, purpose, type of data and categories of data subjects. A portal that builds its own products from ads — statistics, recommendations, searcher profiles — decides its own purposes and is a controller for that part. The distinction changes who responds to a homeowner’s request to delete their photos, which is why it is worth clarifying in advance, not at the first request.

What do we do with the contact base when an agent leaves?

The question has a legal part and an architecture part, and the second resolves the first. Legally, the data belong to the agency as controller, and the agent processes them under its authority; the controller is obliged to take measures so that persons acting under its authority and having access to data do not process them except on its instructions. In practice, if the only copy of the client relationship is in the agent’s personal phone, the agency can neither impose instructions, nor delete, nor respond to an access request. Data protection by design requires that, by default, data cannot be accessed by an unlimited number of persons without intervention — and a personal phone is exactly the opposite.

What we cannot claimNu avem nicio lucrare livrată în imobiliare. Nu e o omisiune de redactare și nu se repară în această pagină: nu există, în inventarul nostru, niciun proiect imobiliar din care să tragem un exemplu, o cifră sau o lecție proprie, iar dosarul de față descrie industria și legea care i se aplică, nu ce am făcut noi acolo. Ce e scris mai sus se sprijină exclusiv pe acte normative și pe documente publicate de autoritățile care le aplică. Nu suntem juriști, nu emitem avize și nu ținem loc de consultanță juridică. Nu suntem consultanți de conformitate în domeniul prevenirii spălării banilor și nu proiectăm procedura de precauție a unei agenții; ce e citat aici din manualul metodic al Serviciului e citat, nu interpretat. Nu am putut deschide textul integral al Legii cadastrului bunurilor imobile nr. 1543-XIII din 25.02.1998, al Legii cu privire la condominiu nr. 187 din 14.07.2022 și al Legii nr. 308/2017 — sursa oficială consolidată a returnat 403 în ziua verificării, iar toate trimiterile de pe paginile instituțiilor duc acolo. Aceste trei acte sunt citate la nivel de act, cu numărul, data și titlul confirmate pe pagina autorității care le aplică; niciun articol din ele nu e citat ca text citit de noi, iar acolo unde numerele de articol apar, ele sunt citate așa cum le citează Serviciul în propriul manual. Nu am identificat, în listele oficiale deschise în ziua verificării, un act care să reglementeze separat profesia de agent imobiliar — afirmăm doar ce se vede în acele liste, nu absența unei reglementări în general. Nu numim nicio agenție și nu publicăm nimic despre clienții cuiva.

The service, in detail What we actually built All scenarios

The service, appliedWe have not yet delivered exactly this combination. What you read above is the mechanism of our service, verifiable on its page, set alongside the rules that govern imobiliare — each with the article it comes from. What we have actually built sits on the service page and in the portfolio.

Sources 10 sources · verified on 2026-09-07

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