Privacy Policy

Prytrivora d.o.o. (hereinafter: "we", "us" or "Prytrivora") is committed to protecting the privacy and personal data of users of our real estate crowdfunding platform. This Privacy Policy describes how we collect, use, store, and protect your personal data in accordance with the General Data Protection Regulation (GDPR) and the Croatian Act on the Implementation of the General Data Protection Regulation (OG 42/18). This policy applies to all users of the platform prytrivora.com, regardless of whether they use the platform for browsing, registration, or active investment.

The controller of your personal data is: Prytrivora d.o.o. Ulica grada Vukovara 271, 10000 Zagreb, Croatia OIB: 48291056837 Email: privacy@prytrivora.com Phone: +385 1 234 5678

We collect the following categories of personal data: - Identification data: name, surname, date of birth, personal identification number - Contact data: email address, phone number, postal address - Financial data: banking details for investment transaction purposes - Technical data: IP address, browser type, operating system, platform usage data - Communication data: messages sent via the contact form or email

We process your personal data for the following purposes: - Providing real estate crowdfunding platform services (contract performance) - Fulfilling legal obligations, including HANFA regulatory requirements (legal obligation) - Preventing money laundering and terrorist financing in accordance with Croatian legislation (legal obligation) - Improving user experience and platform security (legitimate interest) - Sending notifications about projects and news, with your consent (consent)

We may share your personal data with: - Regulatory bodies: HANFA, Tax Administration, and other competent authorities as required by law - Service providers: business partners who help us provide the platform (hosting, payments, accounting) - Legal advisors: in case of legal proceedings or regulatory requirements We do not sell your personal data to third parties nor use it for marketing purposes without your explicit consent.

We apply appropriate technical and organizational measures to protect your personal data, including data encryption in transit and at rest, access control, regular security audits, and employee training. Our information security team regularly conducts risk assessments and vulnerability testing to ensure the highest level of protection for your data.

Under the GDPR, you have the following rights: - Right of access: request access to personal data we hold about you - Right to rectification: correct inaccurate or incomplete data - Right to erasure: request deletion of your data when no longer necessary - Right to restriction of processing: request restriction of processing in certain situations - Right to data portability: receive your data in a machine-readable format - Right to object: object to processing based on legitimate interest - Right to lodge a complaint: file a complaint with the Personal Data Protection Agency (AZOP) To exercise your rights, contact us at privacy@prytrivora.com.

We retain your personal data only for as long as necessary to fulfill the purpose for which it was collected. Financial data is retained for a minimum of 11 years in accordance with legal obligations. Technical platform usage data is retained for up to 24 months. After the retention period expires, data is securely deleted or anonymized.

We reserve the right to amend this Privacy Policy. You will be notified of all significant changes via the platform or email. We recommend regularly reviewing this policy. The date of the last amendment is indicated at the top of this page.

For any questions regarding the protection of your personal data, contact us at: Prytrivora d.o.o. Data Protection Service Email: privacy@prytrivora.com Phone: +385 1 234 5678 Ulica grada Vukovara 271, 10000 Zagreb, Croatia