Privacy Policy

1. Data controller

The data controller for your personal data is VelaroHQ S.A., with registered address at Av. Corrientes 1234, Floor 8, Office B — C1043AAZ, City of Buenos Aires, Argentina. Tax ID (CUIT): 30-71845623-9. For any inquiries regarding data processing, you may contact us at privacidad@velarohq.com.

2. Data we collect

We collect different types of information depending on how you interact with our platform:

• Identification data: full name, national ID (DNI/CUIL), date of birth, nationality.
• Contact data: email address, phone number, home address.
• Financial data: banking information required to process investments and profit distributions.
• Usage data: IP address, browser type, pages visited, session duration, platform interactions.
• Voluntarily provided data: messages sent through the contact form.

3. Purpose of data processing

We use your personal data for the following purposes:

• To manage your registration and access to the platform.
• To process and manage your investments in real estate projects.
• To comply with legal and regulatory obligations (including CNV and UIF regulations).
• To send communications related to your investments and the platform's operation.
• To improve our services through usage pattern analysis.
• To prevent fraud and ensure transaction security.

4. Legal basis for processing

The processing of your personal data is based on: (a) your express consent when registering on the platform; (b) the execution of the investment agreement; (c) compliance with applicable Argentine legal obligations (Law 25,326 on Personal Data Protection and its Regulatory Decree 1558/2001); and (d) our legitimate interest in improving the services offered.

5. Data retention period

We retain your personal data for as long as necessary to fulfill the described purposes and, at a minimum, for the periods required by current legislation. Data linked to financial operations is kept for a minimum of 10 years in accordance with UIF regulations. After the contractual relationship ends, your data will be deleted or anonymized, unless there is a legal obligation for its retention.

6. Your rights

In accordance with Law 25,326, you have the right to:

• Access your personal data and request information about its processing.
• Rectify inaccurate or incomplete data.
• Request the deletion of your data when it is no longer necessary.
• Object to processing in certain circumstances.
• Withdraw previously granted consent.

To exercise your rights, send an email to privacidad@velarohq.com with the subject line 'Data Rights Request'. The National Directorate for Personal Data Protection (Agency for Access to Public Information) is the supervisory authority responsible for handling complaints and claims.

7. International data transfers

If it becomes necessary to transfer personal data outside Argentina, we ensure the destination country has an adequate level of protection, in accordance with Law 25,326 and the resolutions of the Agency for Access to Public Information. When such a level cannot be guaranteed, we implement standard contractual clauses to protect your data.

8. Security measures

We implement appropriate technical and organizational measures to protect your data against unauthorized access, alteration, disclosure, or destruction. These include encryption of data in transit and at rest, role-based access controls, periodic audits, and staff training.

9. Changes to this policy

We reserve the right to update this Privacy Policy at any time. Changes will be posted on this page with the date of last update. We recommend reviewing it periodically.

10. Contact

If you have questions or inquiries about this Privacy Policy, you may contact us at: privacidad@velarohq.com or at our postal address: Av. Corrientes 1234, Floor 8, Office B — C1043AAZ, CABA, Argentina.