PRIVACY POLICY OF
EQUITO APP

If you are reading this document, it means that you are interested in Equito App, either because you want to use the Equito App platform (the “Platform”), via Web Site, or because you want to contact us for some reason. We like that you have been interested in us and, therefore, with the same interest, we want to inform you about our Privacy Policy and explain what we do with the personal data you provide us with, as well as those we collect if you browse through our website.

1. IDENTIFICATION

Name: Equito App, S.L. (hereinafter, the “Data Controller” or “Equito”)
Registered address: Ronda sant pere (urquinaona), 52 - AT, Barcelona, 08010
VAT Number: B-16857609
Public Registry: Registro Mercantil de Barcelona Tomo 47992, Folio 198, Inscripción 1 con hoja B-568662
E-mail: [email protected]

Data protection officer: https://equito.app/.

2. INFORMATION AND CONSENT

In accordance with the terms of General Data Protection Regulation (GDPR) 679/2016 (hereinafter referred to as "GDPR") and of Organic Law 3/2018, of December 5, of Data Protection and Guarantee of Digital Rights (hereinafter referred to as "LOPDGDD") the user accepts this Privacy Policy, as a website user (hereinafter referred to as the "Data Subject") and GIVES his/her informed, express, free and unequivocal CONSENT for processing of personal collected through the website https://equito.app/. In both cases, data will be collected through the forms enabled for this purpose or through the information collected by the cookies.

Also, the Data Subject consents the processing of these data by Equito to provide its services by applying the organizational and security measures required by GDPR.

All personal data requested from the Data Subject in the Platform are mandatory, not being possible to provide each of the services without the corresponding data processing by Equito. However, browsing on Platform is accessible online for free.

The Data Subject guarantees that the personal data provided to Equito are correct and accurate, so that Equito will not be responsible for any incidence resulting from the inaccuracy or falsity of the information provided by Data Subject, despite the possibility that the Data Subject has to exercise his right to rectification.

In the event that the data provided comes from third parties, the data controller or the data processor shall be responsible for complying with all applicable regulations on data protection. In addition, the Data Subject guarantees that he has obtained all consents, authorizations and/or legally required approvals before including personal data of third parties on Platform.

Equito cannot guarantee the absolute invulnerability of the systems, therefore, it does not assume any responsibility for damages derived from alterations that third parties may cause in the computer systems, electronic documents or files.

3. PURPOSE OF PROCESSING

The personal data of the Data Subject or third parties that are transferred by the Data Subject will be processed by Equito only for the following purposes:

Contact

To attend to requests for information in the case of data collected through the contact email or contact form in the Platform.

Equito App Registry

To manage the register of users in the Platform

Equito App:
Investment management

To provide the Equito App service: permit users to invest in real estate projects

Equito app

User Platform and service Data

Improve the User Experience and our service

4. LEGAL BASIS

The legal basis that legitimates the processing of personal data carried out by Equito are the following:

Contact

Legitimate interest

Equito App Registry

Execution of a contract

Equito App:
Investment management

Execution of a contract

Equito app

User Platform and service Data

Legitimate interest

5. DATA COLLECTED

Through the Platform, the following data will be collected:

Contact

1. Identification: name, last name.

2. Contact: email, telephone.

Equito App Registry

1.- Name, e-mail address, phone number

Equito App:
Investment management

1.- Name, address, e-mail address, phone number, financial information (including credit card, debit card, or bank account information), geographical location, personal description, photograph, ID, loan amount, type of house to purchase, location of the house, marriage regime, familiar situation, previous debts records.

Equito app

User Platform and service Data

1.- Technical information, including the Internet protocol (IP) address used to connect the computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

2.- Inormation about the Platform visit, including the full URL, clickstream to, through and from our Website (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page used to contact our Customer Support email.

6. RECIPIENTS AND INTERNATIONAL TRANSFERS

Equito will not give or transfer personal data to third parties. However, Equito may allow access to the personal data of the Data Subjects when this is necessary for the provision of its services (as for AML authorities, Courts, Tax administration) signing in such cases a data processor agreement with such suppliers. These agreements will in any case indicate that the processor will act on behalf of Equito, in accordance with the purposes of the latter and applying appropriate security measures, as well as technical and organizational measures that will in no case offer less protection than those applied by Equito.

If it is necessary to carry out international assignments or transfers to third parties and/or countries, Equito will always inform the Data Subjects of this circumstance and request his/her explicit consent to do so.

7. DATA HOSTING

The data that we collect from you won’t be transferred to, or stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for our suppliers. Such staff may be engaged in, among other things, the fulfilment of your payment order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Your personal data will be held at the Equito servers for a period of 5 years after termination of your commercial relation with Equito, after which, we will erase it.

8. PROFILING AND AUTOMATED DECISION MAKING

We may use some instances of your data in order to customise our services and the information we provide to you, and to address your needs - such as your country of address and transaction history. As an example, we may use information to inform you of new product updates or features that may be useful for you. When we do this, we take all necessary measures to ensure that your privacy and security are protected - and we only use pseudonymised data wherever possible. This activity has no legal effect on you.

As part of being a highly technical and innovative company, we may use Automated Decision Making (ADM) in order to improve your experience, or to help fight financial crime. For example, so that we can provide you with a fast and efficient service, we may use ADM to verify your identity documents, or to confirm the accuracy of the information you have provided to us. None of our ADM processes have a legal effect on you.

9. EXERCISE OF RIGHTS

In accordance with the provisions of GDPR, we inform you that you can exercise your rights of access, rectification, erasure, opposition, data portability and limitation of processing directly with Equito.

To facilitate the exercise of these rights, the Data Subject may send a message to this effect, indicating name, surname and e-mail address to the following e-mail address: [email protected]. The request must be answered within a maximum period of one (1) month from the receipt of the form.

10. COOKIES POLICY

In accordance with the provisions of GDPR and Spanish Law 34/2002, on Information Society Services, all personal data obtained through cookies during the use of the Platform, will be processed in accordance with the provisions of the Cookie Policy.

11. ACCEPTANCE OF THE PRIVACY POLICY

The Data Subject ACKNOWLEDGES AND AGREES TO HAVE READ AND UNDERSTOOD this Privacy Policy, the content of which constitutes the entire agreement between the Data Subject and Equito regarding the use and processing of its personal information. The Data Subject expressly agrees to be bound by the terms of the present Privacy Policy, in its entirety and scope, without exception to any of its provisions.

Equito reserves the right to update and make changes to the Privacy Policy even without prior notice to the Data Subjects. Such changes will be effective at the time of publication on the Platform, where they will be available to the Data Subject at all times. In this sense, we recommend the Data Subject to regularly consult the content of the Privacy Policy in order to be aware of any modification affecting the data processing within the Platform.

EQUITO APP, S.L.

Last update: February 21ST, 2024.

PRIVACY POLICY OF EQUITO APP

PRIVACY POLICY OF
EQUITO APP