Privacy Policy
Last updated: January 15, 2026
1. Introduction
Lprjoqkrmm, C.A. (hereinafter "Lprjoqkrmm", "we", or "the Platform"), domiciled in Caracas, Venezuela, is committed to protecting the privacy and personal data of its users. This Privacy Policy describes how we collect, use, store, and protect your personal information when you use our real estate crowdlending platform. This policy has been prepared in compliance with Venezuelan constitutional provisions on the right to privacy (Article 60 of the Constitution of the Bolivarian Republic of Venezuela), as well as applicable regulations regarding personal data protection and electronic commerce.
2. Information We Collect
We collect different types of information depending on your interaction with our platform: Identification data: full name, national identity card or passport number, date of birth, nationality, and identity document photograph. Contact data: email address, telephone number, physical residential address. Financial data: banking information for transactions, investment history within the platform, investor risk profile. Browsing data: IP address, browser type, pages visited, time spent on the platform, and technical and analytical cookie data.
3. Purpose of Data Processing
We use your personal information for the following purposes: Management of your user account and identity verification in accordance with current anti-money laundering and counter-terrorism financing regulations in Venezuela. Processing of investments, distribution of returns, and management of your real estate portfolio within the platform. Communication of updates on projects, new investment opportunities, and changes to terms of service. Continuous improvement of our services through aggregated and anonymized analysis of browsing behavior. Compliance with legal, regulatory, and tax obligations before competent bodies of the Bolivarian Republic of Venezuela.
4. Legal Basis for Processing
The processing of your personal data is based on: The express consent you grant when registering on the platform and accepting these terms. The execution of the real estate crowdlending intermediation services contract between you and Lprjoqkrmm. Compliance with legal obligations, including regulations from the National Securities Superintendency (SUNAVAL), the National Integrated Customs and Tax Administration Service (SENIAT), and the National Financial Intelligence Unit (UNIF).
5. Data Sharing and Disclosure
We do not sell or rent your personal data to third parties. We may share information in the following circumstances: With associated real estate developers, exclusively the information necessary for managing your investment in specific projects. With financial institutions and payment processors for transaction execution. With governmental and regulatory authorities when required by law, court order, or formal request from bodies such as SUNAVAL, SENIAT, or the Public Ministry. With technology service providers who operate under strict confidentiality and data protection agreements.
6. Data Security
We implement technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include: Data encryption in transit using TLS 1.3 protocols and encryption at rest with AES-256 algorithms. Role-based access control and multi-factor authentication for authorized personnel. Periodic security audits and penetration testing conducted by independent firms. Security incident response procedures with notification to affected users within 72 hours of detection.
7. Data Retention
We retain your personal data for as long as you maintain an active account on our platform and for an additional period of ten (10) years after account closure, in accordance with record-keeping obligations established by Venezuelan financial and tax legislation. Browsing data and analytical cookies are retained for a maximum period of twenty-four (24) months, unless you request early deletion.
8. Your Rights
You have the right to: Access your personal data and obtain a copy of the information we hold about you. Rectify inaccurate or incomplete data. Request deletion of your data when it is no longer necessary for the purpose for which it was collected, subject to legal retention obligations. Object to the processing of your data for direct marketing purposes. Withdraw your consent at any time, without affecting the lawfulness of prior processing. To exercise any of these rights, contact our Data Protection Officer at privacy@lprjoqkrmm.com.
9. Contact
For any inquiries related to this Privacy Policy or the processing of your personal data, you may contact us at: Email: privacy@lprjoqkrmm.com Address: Torre Lprjoqkrmm, Floor 12, Av. Francisco de Miranda, Los Palos Grandes, Caracas 1060, Miranda, Venezuela Phone: +58 212-555-0199