TIVLUXE
Privacy Policy

Privacy Policy

Last updated: January 2026

1. Introduction

Tivluxe SpA (hereinafter "Tivluxe", "we" or "the Company"), with registered address at Av. Apoquindo 4700, Office 1201, Las Condes, Santiago, Chile, and Tax ID (RUT) 77.456.789-K, is committed to protecting the privacy of our users' personal data in accordance with Law No. 19,628 on the Protection of Private Life and its current amendments, as well as applicable provisions of Chilean data protection regulations.

2. Data Controller

The data controller for your personal data is Tivluxe SpA, registered with the Santiago Commerce Registry under Folio No. 54321, incorporated in 2022, and operating under the jurisdiction of the Republic of Chile. For any inquiries regarding the processing of your data, you may contact us via email at contacto@tivluxe.com or at our postal address indicated above.

3. Personal Data We Collect

In the context of our real estate crowdlending services, we may collect the following personal data: full name, email address, and the content of messages you send us through the contact form. This data is provided directly by you when interacting with our platform. Additionally, we may collect technical browsing data such as IP address, browser type, pages visited, and visit duration through the use of cookies and similar technologies.

4. Purpose of Processing

We use your personal data for the following purposes: (a) responding to your inquiries and information requests submitted through the contact form; (b) providing you with information about our collective real estate investment services; (c) improving the functionality and user experience of our platform; (d) complying with applicable legal and regulatory obligations in Chile; and (e) maintaining the security and integrity of our systems.

5. Legal Basis for Processing

The processing of your personal data is based on: your express consent when providing your data through our forms; Tivluxe's legitimate interest in developing and improving its real estate crowdlending services; and compliance with legal obligations under current Chilean legislation, including Law No. 19,628 and securities market regulations.

6. Data Retention

Your personal data will be retained for as long as necessary to fulfill the purposes for which it was collected and to address any potential liabilities arising from processing. Contact data will be retained for a maximum period of 24 months from the last interaction, unless a legal obligation requires a different retention period.

7. Data Subject Rights

In accordance with Chilean data protection legislation, you have the right to: access your personal data in our possession; request the rectification of inaccurate or incomplete data; request the deletion or cancellation of your data when it is no longer necessary; object to the processing of your data on legitimate grounds; and request the portability of your data in a structured format. To exercise any of these rights, you may send a request to contacto@tivluxe.com accompanied by a copy of your identity document.

8. International Transfers

Tivluxe does not carry out international transfers of personal data outside Chilean territory, except when strictly necessary for the provision of essential technical services (such as server hosting) and always ensuring adequate levels of protection in accordance with applicable regulations.

9. Security Measures

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include data encryption in transit and at rest, role-based access controls, continuous security monitoring, and periodic audits of our systems.

10. Changes to this Policy

Tivluxe reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices or applicable legislation. Any modifications will be published on this page with the date of the last update. We recommend that you review this policy periodically.

11. Contact

If you have any questions or concerns about this Privacy Policy or about the processing of your personal data, you may contact us at: Tivluxe SpA, Av. Apoquindo 4700, Office 1201, Las Condes, Santiago, Chile. Email: contacto@tivluxe.com. Phone: +56 2 2345 6789.