Privacy Policy

Escrowvb Inversiones S.L. Tax ID: B-84729361 Registered address: Calle Gran Vía 28, 5th Floor, 28013 Madrid, Spain Email: privacidad@escrowvb.com Phone: +34 910 847 263 Data Protection Officer (DPO): dpd@escrowvb.com

We collect the following personal data when you interact with our platform: • Identification data: full name, identity document (DNI/NIE/Passport), date of birth, nationality. • Contact data: email address, telephone number, postal address. • Financial data: banking information required to process investments and returns. • Browsing data: IP address, browser type, pages visited, time spent, cookies. • Voluntarily provided data: messages sent through contact forms.

We process your personal data for the following purposes: • Management of your user account and identity verification (KYC/AML) in accordance with anti-money laundering regulations. • Processing and management of your investments in real estate crowdlending projects. • Communication of relevant information about your investments and the platform. • Compliance with legal, tax and regulatory obligations. • Improvement of our services and user experience through anonymised statistical analysis. • Sending commercial communications, only with your express consent.

The processing of your data is based on: • Performance of contract: when data is necessary to provide our investment services. • Legal obligation: to comply with applicable regulations (tax, anti-money laundering, financial regulation). • Consent: for sending commercial communications and non-essential cookies. • Legitimate interest: for improving our services and fraud prevention.

Your data may be shared with: • Authorised payment institutions that manage investor segregated accounts. • Regulatory and tax authorities when legally required (CNMV, AEAT, SEPBLAC). • Technology service providers acting as data processors, with appropriate contractual guarantees. • We do not sell or share your data with third parties for commercial purposes.

We retain your personal data for the time necessary to fulfil the described purposes and, in any case, during the applicable legal retention periods: • Tax data: 4 years (General Tax Law). • Anti-money laundering data: 10 years (Law 10/2010). • Contractual relationship data: 5 years after the end of the relationship.

As a data subject, you may exercise the following rights: • Right of access: to know what data we process about you. • Right to rectification: to correct inaccurate or incomplete data. • Right to erasure: to request deletion of your data when no longer necessary. • Right to restriction: to restrict processing in certain circumstances. • Right to data portability: to receive your data in a structured, commonly used format. • Right to object: to oppose the processing of your data in certain cases. To exercise these rights, contact us at privacidad@escrowvb.com. We will respond within a maximum of 30 days. You also have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD), located at C/ Jorge Juan, 6, 28001 Madrid (www.aepd.es).

We do not transfer personal data outside the European Economic Area. All our servers and service providers are located within the EU.

We reserve the right to update this policy to adapt it to regulatory changes or changes in our services. Any modification will be communicated through the platform with at least 30 days' notice.