Data Protection Policy

This Information Notice on the processing of personal data presents to the users of the website located at openproperty.ro (“Platform”) the personal data that OPEN PROPERTY S.R.L., (hereinafter “the Company”) collects from its users and the personal data processing activities carried out by the Company through the Platform and when providing Our services.

In accordance with this Information Notice (together with the Terms and Conditions and any other documents referred to therein) we will process any personal data collected from you orthat you may provide to us.

DATA CONTROLLER AND PLATFORM OWNER

OPEN PROPERTY S.R.L. is a company established and operating in accordance with the laws of Romania, having its registered office in Pitesti, Bd. Republicii nr. 148, Cladirea C1,1st floor, office 15b, Arges County, registered at the Trade Register under no. J03/286/2024,RO49514918, is the personal data controller and the owner of the Platform.

PERSONAL DATA COLLECTED

We inform you that the following information/personal data may be collected and processed by the Company: (i) details of your visit to the Platform, please see point 6 below ( Cookies); (ii) information necessary to create your user account on the Platform and to validate your user account on the Platform (name, surname and e-mail address, contact details, address, telephone number, data from an identity document); (iii) information necessary to provide our services: – information necessary to identify and contact the person (natural person/legal entity representative), such as name, date of birth, e-mail address, telephone number, postal address, country of residence and tax residence, data from identification document (documentseries and number, date of issue, date of expiration, personal identification number or equivalent); – a recorded form of communication with us, such as recommendations, comments, requests, queries, which may be submitted through the Platform, by emails or by telephone contact; – information relating to the use of the Platform and the user account, such as login details and password, IP address and data on the user’s actions on the Platform; –information on transactions and other activities of the User, such as details of payments, applications, agreements and other data related to the use of the services offered by the Company; – documents and data received during the KYC process, such as copies of identity documents, documents uploaded to the Platform, proof of source of income, etc; -biometric data for identity verification purposes collected by us or the third party identity verification service provider and from the perspective of preventing money laundering and combating the financing of terrorism; – bank account and other financial information necessary for the performance of contractual relationships, if applicable; – any data made available by you. during our interactions, including requests, complaints. Personal data is collected by the Company when you use the Platform and the services provided by the Company, as well asthrough other types of communications we have with you in the context of providing services or marketing activities.

PROCESSING OF PERSONAL DATA

Processing of personal data means any type of operation that is performed on personal data, whether automated or not, including, but not limited to, the collection, recording, storage, arrangement, arrangement, use, modification, alteration, provision, disclosure and deletion ofthe user’s personal data by the Company. We maintain a database including User Personal Data and other information that may reflect the following User Personal Data: – first name and surname; – date of birth and personal numerical code; – residence and/or location; – meansof communication (telephone, email, etc.); – language of communication; – copies of identity document and other information and documents collected in connection with our practices or those of a third party provider of identification and verification services from the perspective of prevention of money laundering and combating the financing of terrorism (AML), including KYC and AML; – user data (login data, start and end of the user accountregistration process, etc.other information that the User has delivered to us or that we have collected on our own initiative from sources permitted by law (including from the media and the Internet); – information about the User’s agreements concluded through the Platform. Wemay process other information related to the User if there is a justified necessity for the execution of the agreements and if the processing of such data does not contravene applicable legal provisions.

LEGAL BASES AND PURPOSES OF PROCESSING

We will process all personal data that you provide to us, and any other data necessary toprovide our Services to you, in accordance with applicable legal provisions and contractualprovisions, as applicable. The same applies to all personal data collected prior to the conclusion of investment agreements, including through our online registration form. Weassure you that all your personal information and all personal data remains confidential, even if you have not concluded any purchase through the Platform. If you are the legal representative or contact person for a legal entity, we will process your personal data on the basis of our legitimate interest to ensure the exercise of our rights and fulfillment of ourobligations arising from the agreements entered into. Our main purposes in relation to theprocessing of the user’s personal data are the following: -to ensure the identification of the user; -to provide our services on the Platform and to provide information to the user, whetheror not requested in connection with our services; -to enter into and perform contracts; -to ensure the prompt and proper performance of contractual financial obligations and to protect our rights under agreements entered into with us; -to analyze user satisfaction and service preferences to enable effective service development and marketing activities; -to manage the Platform and to ensure its security. We have the right to process the User’s personal data for other purposes as well, if they are necessary for the fulfillment of our obligations underapplicable legal provisions. The legal grounds for processing personal data are the fulfillment of contractual obligations and our legitimate interest. We may also process your personal data for marketing communications, based on your consent given on the Platform.

DATA RETENTION

We will retain information about you (including personal data) for as long as necessary toprovide our services to you or as necessary to fulfill our legal obligations. We will retain and use information about you (including personal data) as necessary to comply with our legal obligations, resolve disputes and enforce our agreement with you, and for the other purposes mentioned above. By contacting us at info@openproperty.ro, you can obtain confirmation atany time as to whether or not your personal data is being processed. You have the right toaccess and export your information at any time by sending a request to info@openproperty.ro

COOKIEs

Our platform contains cookies that collect personal data. The collection of personal data isstrictly limited to what is necessary to provide you with the highest quality experience in using our Platform. We process technical data (including IP address) collected through cookies, such as information about your visits to our Platform. We collect your personal data through cookies placed on the Platform. Details on the processing of personal data by such tools are available in our Cookie Policy.

DATA CONTROL

The person responsible for the lawful processing of data, i.e. the data controller is OPEN PROPERTY S.R.L. The data controller is a person who determines the purpose and means of processing personal data.

GENERAL PRINCIPLES FOR PROCESSING PERSONAL DATA

We and all of our employees apply all due diligence and security measures required by lawfor the processing of the user’s personal data, to ensure that this process is done for a specific purpose and to protect the user’s personal data against accidental or unauthorized use, disclosure or destruction. We only allow access to the user’s personal data to: – our employees with whom a confidentiality agreement is concluded; – a third party, who processes the dataon our behalf, with whom a confidentiality agreement is concluded. We exclude any access by unauthorized third parties to the user’s personal data and our database containing such data. We have taken administrative, technical and physical measures designed to protect the personal data we hold about you from accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We have implemented appropriate security measures to prevent the loss, unauthorized use or accidental loss, unauthorized access, alteration ordisclosure of your data. In addition, we limit access to your data to only those employees,agents, contractors and other third parties on a need-to-know basis in order to carry out theirbusiness as described above. They will only process your data in accordance with our instructions and are subject to an obligation of confidentiality. We have procedures in place todeal with any suspected data breach and will notify You and the relevant regulator of a breach.

TRANSFER AND DISCLOSURE OF PERSONAL DATA

We have the right to transfer your personal data in accordance with the Terms and applicablelaw, primarily to: – third parties who perform any of our data processing tasks; – persons whose economic or professional activity includes the provision of debt collection and other related services for the collection of contractual debts (debits) of the User; – persons to whom we are obliged to transfer the User’s personal data under applicable law; – person providingaccounting services to us and persons providing legal assistance in connection with agreements with or between users; -the third party provider of identification and verificationservices from the AML perspective and the third party provider of payment services; -providers of information transmission or marketing materials; -developers of projects on the Platform. We have the right to transfer the User’s personal data to third parties in any othercase only when there is a justified interest to ensure the fulfillment of agreements concludedwith or between Users and the transfer of information does not contravene applicable law. In accordance with applicable law, we are required to enter into an appropriate agreement withany third party to whom the user’s personal data is transferred, i.e. the data processor. We willin any case evaluate the organizational and technical measures the data controller takes to ensure the protection of personal data. We have the right to transfer the User’s personal data in accordance with the Platform Documents and applicable legal provisions, mainly to: -third parties who perform any of our data processing activities as mentioned above; -persons whose business or professional activities, including the provision of debt collection/debt recovery services and other related services to recover contractual debts of the User; -persons to whom we are obliged to transfer the User’s personal data under applicable legal provisions; -persons who provide accounting services to us, aswell as persons who provide legal assistance in connection with agreements with or between Users.

OUR COMMUNICATIONS

We may use the information you provide to us, on the Platform, in accordance withapplicable law and with your consent, for direct electronic marketing purposes (e.g. receiving communications that we think may be of interest to you, targeted advertising on social networking platforms). Please note that, in respect of electronic marketing communications, you may withdraw your consent at any time by (i) unchecking the appropriate box in your membership account, (ii) clicking the unsubscribe link we provide in each communicationsent, or (iii) contacting us using the contact details provided below.

USERS’ RIGHTS AND OBLIGATIONS IN RELATION TO THE PROCESSING OFPERSONAL DATA

The User agrees to transfer to us the necessary personal data described in the Platform Documents, and in any other contracts, which data must be correct, valid and complete. TheUser agrees to inform us immediately of any changes to his/her personal data, as well as of the incorrectness or invalidity of the personal data by transmitting to the Company the correct and valid personal data to replace the incorrect and/or invalid personal data. The User shall be fully responsible for the accuracy and validity of his/her personal data while using the Platform. You have the following rights with regard to the processing of your personal data:a. the right of access to your personal data. b. the right to obtain rectification or erasure of your personal data. c. the right to obtain restriction of the processing of your personal data. This right is available to you where: i. you contest the accuracy of your personal data that weprocess; ii. the processing of your personal data is unlawful; iii. we do not need your personaldata for the purpose of the processing, but you request that we retain it for the establishment, exercise or defense of a legal claim; or iv. you object to the processing of your personal data for as long as we verify the existence of our legitimate interest in processing your personaldata. d. the right to data portability. e. the right to object to the processing of your personaldata. The User has the right to request information from the Company at any time about thepersonal data collected by the Company about him or her, as well as about the persons towhom we have provided the User’s personal data. To do so, the user must send us an e-mail.We will review and respond to the information request. We have the right to refuse thetransfer of the information specified above to the extent required by applicable legal provisions. The user has the right to request the termination of the processing of personal data by the Company, and the Company will be obliged to cease processing the user’s personaldata if the user has duly fulfilled all obligations under the agreements entered into with the Company and/or another user and the user’s agreements entered into with us and/or another user have terminated. If you have any questions regarding the processing of Your personal data or if you wish to make any request to us, as well as to exercise any of Your rights in relation to the processing of Your personal data, please contact us at: info@openproperty.ro.We will consider each request and inform you of the action taken as soon as possible. If weneed more information from you or have difficulty in dealing with your request, we willpromptly inform you that we need additional information to properly analyze your request.

DATA STORAGE

Data is stored in data centers located throughout the European Union. In accordance with the terms and conditions of the service provided by the data center, only the Company has the right to access the personal data of the users. Users’ personal data is stored and retained for aslong as required by applicable law. Thereafter, the data will be destroyed in the manner required by applicable law.

DISCLOSURE UNDER THE LAW

Notwithstanding anything to the contrary in this Notice, we may retain or disclose your information if we reasonably believe it is necessary to comply with a law, regulation, legalprocess or governmental request; to address fraud, security or technical issues; or to protectthe rights or property of us or our users. We may disclose your personal data to authorities, data protection authorities, government officials and other authorities when we are legally required to do so or to protect the safety of users and the Platform.

CONTACT

If we decide to amend this Information Notice, we will publish a new version on our Platform to replace this one. Thank you for entrusting us with your personal data and for taking the time to read our Information Notice on the processing of personal data. Please do not hesitateto contact us if you have any further questions about the processing of your personal data at the following email address: info@openproperty.ro