Privacy Policy

1. Data controller

Tectyre S.A., with RUC 1792456781001, domiciled at Av. 12 de Octubre N24-562 y Cordero, World Trade Center Building, Tower A, Floor 11, Quito, Pichincha, Ecuador, is the data controller responsible for your personal data in accordance with Ecuador's Organic Law on Personal Data Protection (LOPDP) effective since May 2023.

2. Data we collect

We collect information you provide directly when registering, verifying your identity, or contacting us:

• Identification data: full name, ID or passport number, date of birth.
• Contact data: email address, phone number, home address.
• Financial data: banking information for transfers, investment history on the platform.
• Browsing data: IP address, device type, browser, pages visited, session duration.
• KYC verification data: identity documents, proof of address, declarations of source of funds.

3. Purpose of data processing

We use your personal data for the following purposes:

• Managing your account and verifying your identity in accordance with SCVS regulations.
• Facilitating crowdlending operations between investors and developers.
• Complying with legal obligations for anti-money laundering prevention (UAFE).
• Sending you communications related to your investments and platform updates.
• Improving our services through aggregated and anonymized usage analysis.
• Responding to your inquiries and support requests.

4. Legal basis for processing

The processing of your data is based on: (a) your express consent given upon registration; (b) the execution of the financial intermediation services contract; (c) compliance with legal obligations before the Superintendencia de Compañías, Valores y Seguros, the SRI, and UAFE; (d) our legitimate interest in improving the security and functionality of the platform.

5. Data sharing with third parties

We do not sell your personal data. We may share limited information with: (a) Ecuadorian regulatory entities when required by law; (b) technology service providers operating under strict confidentiality agreements; (c) real estate developers only to the extent necessary to execute credit operations. Any international data transfer complies with LOPDP standards.

6. Data security

We implement robust technical and organizational measures: encryption in transit (TLS 1.3) and at rest (AES-256), multi-factor authentication, periodic security audits, role-based restricted access, and continuous intrusion monitoring. Our servers are hosted in certified data centers with geographic redundancy.

7. Your rights

Under the LOPDP, you have the right to: access your personal data; rectify inaccurate information; request deletion of your data when no longer necessary; object to processing under certain circumstances; request data portability; and withdraw your consent at any time. To exercise these rights, write to us at privacidad@tectyre.com.

8. Data retention

We retain your personal data for as long as necessary to fulfill the described purposes and applicable legal obligations. Financial and transaction data is retained for a minimum of 10 years in accordance with Ecuadorian tax regulations. Browsing data is automatically deleted after 24 months.

9. Changes to this policy

We reserve the right to update this Privacy Policy. Substantial modifications will be notified through the platform or by email at least 15 days in advance. The last update date is shown at the beginning of this document.

10. Contact

For privacy and data protection inquiries: privacidad@tectyre.com — Data Protection Officer, Tectyre S.A., Av. 12 de Octubre N24-562, Quito, Ecuador.