Privacy Policy

The data controller responsible for your personal data is: Arevium Capital B.V. Trading as: Spainora Country: The Netherlands Email: privacy@spainora.com Spainora is a brand of Arevium Capital B.V. All references to "Spainora," "we," "us," or "our" in this policy refer to Arevium Capital B.V.

We collect the following types of personal information: Information you provide directly: • Name and contact details (email, phone number) • Property preferences and search criteria • Messages and inquiries you submit through our contact forms • Newsletter subscription details • Any other information you choose to provide Information collected automatically: • IP address and device information • Browser type and version • Operating system • Pages visited and time spent on our website • Referral source and exit pages • Cookie data and similar technologies Information from third parties: • Property listings data from developers and agents • Analytics data from service providers

We use your personal information for the following purposes: Service Delivery: • To respond to your property inquiries • To connect you with relevant property developers and agents • To send you property recommendations matching your criteria • To provide customer support Communication: • To send newsletters (with your consent) • To send service-related notifications • To inform you about new properties or services Website Improvement: • To analyze website usage and improve user experience • To personalize content and recommendations • To troubleshoot technical issues Legal Compliance: • To comply with legal obligations • To protect our rights and prevent fraud

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds: Consent: For marketing communications and newsletters. You can withdraw consent at any time. Legitimate Interest: For improving our services, analyzing website usage, and sending relevant property information based on your inquiries. Contract Performance: When processing is necessary to respond to your inquiries and provide our services. Legal Obligation: When we are legally required to process or retain certain data.

We may share your personal information with: Property Partners: • Real estate developers and agents when you express interest in a property • These partners have their own privacy policies Service Providers: • Website hosting providers • Email service providers • Analytics providers (e.g., Google Analytics) • Customer relationship management tools Legal Requirements: • Law enforcement or regulatory bodies when required by law • Legal advisors when necessary to protect our rights We do not sell your personal data to third parties.

We use cookies and similar technologies on our website: Essential Cookies: Required for the website to function properly. Analytics Cookies: Help us understand how visitors use our website (e.g., Google Analytics). Marketing Cookies: Used to deliver relevant advertisements and track campaign effectiveness. Preference Cookies: Remember your settings and preferences. You can manage cookie preferences through your browser settings or our cookie consent banner. Note that disabling certain cookies may affect website functionality. For more information, see our Cookie Policy.

We implement appropriate technical and organizational measures to protect your personal data against: • Unauthorized access or disclosure • Accidental loss or destruction • Unlawful processing Security measures include: • SSL/TLS encryption for data transmission • Secure server infrastructure • Access controls and authentication • Regular security assessments However, no method of transmission over the internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected: Contact Inquiries: Retained for 3 years after the last interaction, unless you request earlier deletion. Newsletter Subscriptions: Retained until you unsubscribe. Website Analytics: Anonymized data retained indefinitely; identifiable data retained for 26 months. Legal Requirements: Some data may be retained longer if required by law. After the retention period, data is securely deleted or anonymized.

Under GDPR, you have the following rights regarding your personal data: Right to Access: Request a copy of your personal data. Right to Rectification: Request correction of inaccurate data. Right to Erasure: Request deletion of your data ("right to be forgotten"). Right to Restrict Processing: Request limitation of how we process your data. Right to Data Portability: Receive your data in a structured, machine-readable format. Right to Object: Object to processing based on legitimate interests. Right to Withdraw Consent: Withdraw consent at any time for consent-based processing. To exercise these rights, contact us at: privacy@spainora.com We will respond to your request within 30 days. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

Your data may be transferred to and processed in countries outside the European Economic Area (EEA). When this happens, we ensure appropriate safeguards are in place: • Standard Contractual Clauses approved by the European Commission • Transfers to countries with adequate data protection (EU adequacy decisions) • Other appropriate safeguards as required by GDPR Our service providers (such as hosting and analytics providers) may be located in the United States or other countries. We ensure they provide adequate protection for your data.

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected information from a child, please contact us immediately at privacy@spainora.com, and we will take steps to delete such information.

Our website may contain links to third-party websites, including property developer sites and social media platforms. This Privacy Policy applies only to our website. We are not responsible for the privacy practices of third-party websites. We encourage you to read the privacy policies of any external sites you visit.

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make significant changes: • We will update the "Last updated" date at the top of this policy • For material changes, we may notify you by email or through a notice on our website We encourage you to review this policy periodically.

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us: Arevium Capital B.V. (trading as Spainora) Email: privacy@spainora.com General inquiries: info@spainora.com Website: www.spainora.com Data Protection Authority: If you are not satisfied with our response, you have the right to lodge a complaint with: Autoriteit Persoonsgegevens (Dutch Data Protection Authority) Website: www.autoriteitpersoonsgegevens.nl