Privacy Policy

We collect the following types of information: **Personal identification information:** Full name, ID number or passport, date of birth, nationality, home address, phone number, and email address. **Financial information:** Bank details for transfers, investment history on our platform, and documentation required for source of funds verification. **Technical information:** IP address, browser type, device used, pages visited, and time spent on our website. **Cookie information:** Data collected through cookies and similar technologies according to our Cookie Policy.

We use your personal information to: - Create and manage your user account - Process your investments and financial transactions - Comply with legal and regulatory obligations, including anti-money laundering - Send communications about your account, investments, and opportunities (with your consent) - Improve our services and user experience - Respond to your inquiries and support requests - Protect against fraud and unauthorized activities

The processing of your personal data is based on: - **Contractual execution:** To provide the crowdlending services contracted - **Legal compliance:** To comply with regulations of the Superintendency of Companies and tax laws of Ecuador - **Legitimate interest:** For fraud prevention and service improvement - **Consent:** For marketing communications and non-essential cookies

We may share your information with: - **Regulatory entities:** Superintendency of Companies, SRI, and other authorities when legally required - **Service providers:** Companies that assist us in payment processing, identity verification, and data hosting, under strict confidentiality agreements - **Real estate developers:** Limited information necessary for project execution We do not sell or rent your personal data to third parties.

We implement technical and organizational measures to protect your data: - SSL/TLS encryption for all data transmissions - Secure storage on ISO 27001 certified servers - Restricted access to authorized personnel - Continuous security monitoring and periodic audits - Security incident response protocols

We retain your personal data for the time necessary to: - Maintain your active contractual relationship - Comply with legal obligations (minimum 10 years for financial documentation under Ecuadorian regulations) - Defend potential legal claims Once these periods are met, your data will be securely deleted or anonymized.

Under Ecuador's Organic Law on Personal Data Protection, you have the right to: - **Access:** Request information about the data we hold about you - **Rectification:** Correct inaccurate or incomplete data - **Deletion:** Request deletion of your data when no longer necessary - **Opposition:** Object to the processing of your data in certain circumstances - **Portability:** Receive your data in a structured format and transfer them - **Limitation:** Request restriction of processing of your data To exercise these rights, contact us at: privacy@ikoqaklsaw.com

Your data may be transferred and stored on servers located outside Ecuador. We ensure that any international transfer complies with adequate safeguards, including standard contractual clauses and verification of the destination country's level of protection.

Our services are directed exclusively to persons over 18 years of age. We do not intentionally collect information from minors. If we detect that we have collected data from a minor, we will delete it immediately.

We may update this Privacy Policy periodically. We will notify you of significant changes through our website or by email. We recommend reviewing this policy regularly.

For any questions about this Privacy Policy or the processing of your personal data: **Ikoqaklsaw S.A.** Data Protection Officer Av. República de El Salvador N36-84 y Suecia Edificio Siglo XXI, Floor 5 Quito, Ecuador Email: privacy@ikoqaklsaw.com Phone: +593 2 456 7890