Privacy Policy

Last updated: January 15, 2026

At Polxudo SpA (hereinafter "Polxudo", "we" or "the Platform"), we take the protection of your personal data seriously. This Privacy Policy describes how we collect, use, store, and protect your information when you use our real estate crowdlending platform.

1. Data Controller

The data controller is Polxudo SpA, located at Av. Apoquindo 4700, Office 1205, Las Condes, Santiago, Chile, RUT 77.845.210-3. For data protection inquiries, you may write to us at privacidad@polxudo.com.

2. Data We Collect

We collect information that you provide directly when registering, completing forms, or communicating with us. This includes: full name, email address, phone number, address, and tax identification data (RUT). We also automatically collect browsing data such as IP address, browser type, pages visited, and session duration.

3. Purpose of Data Processing

We use your information to: manage your account and participation in investment projects; comply with legal and regulatory obligations before the CMF; send communications about the status of your investments; improve the platform experience; prevent fraud and illicit activities in accordance with Law 19,913 on Money Laundering.

4. Legal Basis for Processing

The processing of your data is based on: the consent you grant upon registration; the execution of the project participation agreement; compliance with legal obligations (Law 19,628 on Protection of Private Life, CMF regulations); and Polxudo's legitimate interest in improving its services and preventing fraudulent activities.

5. Data Sharing with Third Parties

We do not sell or transfer your personal information to third parties for commercial purposes. We may share data with: financial entities involved in investment projects; legal and accounting advisors subject to confidentiality obligations; Chilean regulatory authorities when required by law; technology providers that assist us in operating the platform under data processing agreements.

6. Data Retention

We retain your personal data for the period necessary to fulfill the described purposes and applicable legal obligations. Financial records are maintained for a minimum of 5 years in accordance with Chilean tax regulations. Browsing data is deleted after 12 months.

7. Your Rights

Under current Chilean legislation, you have the right to: access your personal data; rectify inaccurate or outdated data; request the deletion of your data when no longer necessary; object to processing in certain circumstances; request data portability. To exercise these rights, write to privacidad@polxudo.com indicating your full name and RUT.

8. Data Security

We implement appropriate technical and organizational security measures to protect your information, including SSL/TLS encryption, access controls, continuous monitoring, and incident response protocols. However, no Internet transmission is completely secure, and we cannot guarantee absolute security of transmitted data.

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 the last update. We recommend reviewing this document periodically.

10. Contact

If you have questions about this Privacy Policy or about the processing of your data, contact us at: Polxudo SpA, Av. Apoquindo 4700, Office 1205, Las Condes, Santiago, Chile. Email: privacidad@polxudo.com. Phone: +56 2 2890 4512.