PRIVACY POLICY

Navetta Properties & Inversiones Navetta SRL

Data Protection and Privacy Practices

Effective Date: March 3, 2026

1. Introduction

Navetta Properties and/or Inversiones Navetta SRL (collectively, “the Company,” “we,” “our,” or “us”) are committed to protecting the privacy of your personal information in accordance with applicable Dominican Republic data protection laws, including Law No. 172-13 on the Protection of Personal Data Stored in Files, Records, Databases, and Other Technical Means.

This Privacy Policy describes how we collect, use, share, and safeguard your information when you visit our websites navettaproperties.com and inversionesnavetta.com, including any associated subdomains (collectively, “the Website”) use our services, or interact with us in any other way. By using the Website or our services, you consent to the practices described herein. Your use of the Website is also subject to our Terms and Conditions.

2. Information We Collect

We may collect the following categories of information depending on how you interact with us:

• Personal Information: Name, address, email address, phone number, and identification documents (such as cédula or passport) provided during inquiries or transactions.

• Financial Information: Bank account details, payment information, and transaction history collected when you engage in real estate transactions with us.

• Property Information: Details about properties you are buying, selling, renting, or listing through us, including address, value, condition, and ownership documentation.

• Usage Information: IP address, browser type, device information, pages visited, time spent on pages, and property search preferences collected automatically when you browse the Website.

• Communications: Records of your communications with us via email, phone, WhatsApp, contact forms, or other channels.

3. How We Use Your Information

We use collected information for the following purposes:

• Service Delivery: To provide requested services including property sales, rentals, management, and related brokerage activities.

• Transaction Processing: To process payments, verify identities, and complete real estate transactions.

• Communication: To respond to inquiries, provide property updates, and send marketing communications. You may opt out of marketing emails at any time.

• Website Improvement: To analyze usage patterns, improve Website functionality and content, and develop new features.

• Legal Compliance: To comply with applicable laws and regulations, including anti-money laundering requirements under Law No. 155-17, tax reporting obligations, and court orders.

• Security: To protect against fraud, unauthorized access, and other security threats.

4. Sharing Your Information

We do not sell your personal information. We may share your information with the following parties only as necessary:

• Service Providers: Trusted third party providers who assist our operations (e.g., payment processors, marketing platforms, IT support, property listing portals) and are bound by confidentiality obligations.

• Transaction Partners: Parties directly involved in a real estate transaction, including attorneys, notaries, banks, title companies, and other brokers as necessary to facilitate the transaction.

• Legal Authorities: Government or regulatory bodies when required by law, court order, or to comply with anti-money laundering and other legal obligations.

• With Your Consent: Other parties when you have given us explicit consent to do so.

5. Cookies and Tracking Technologies

The Website uses cookies and similar tracking technologies to enhance your browsing experience, analyze site traffic, and personalize content. Types of cookies we use include:

• Essential Cookies: Required for basic Website functionality such as navigation and access to secure areas.

• Analytics Cookies: Help us understand how visitors interact with the Website by collecting usage data anonymously.

• Functional Cookies: Remember your preferences such as language, saved property searches, and favorites.

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect Website functionality, including property search features and saved listings.

6. Data Security

We implement commercially reasonable technical and organizational measures to protect your information from unauthorized access, use, alteration, or disclosure. These measures include encrypted data transmission (SSL/TLS), secure server infrastructure, access controls, and regular security assessments.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable law. Retention periods vary based on the type of information and our legal obligations:

• Transaction records: Retained for the period required by Dominican Republic tax and commercial law.

• Communication records: Retained for as long as necessary to address your inquiry or maintain the business relationship.

• Usage data and analytics: Retained in anonymized or aggregated form for Website improvement purposes.

When personal information is no longer needed, we will securely delete or anonymize it.

8. Your Rights

Under Dominican Republic Law No. 172-13 and applicable data protection regulations, you have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you.

• Correction: Request correction of any inaccurate or incomplete personal information.

• Deletion: Request deletion of your personal information, subject to our legal retention obligations.

• Objection: Object to the processing of your personal information for specific purposes, including marketing.

• Restriction: Request that we limit the processing of your personal information under certain circumstances.

• Data Portability: Receive your personal information in a structured, commonly used, and machine-readable format.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within the timeframe required by applicable law.

9. International Data Considerations

The Company operates in the Dominican Republic and primarily stores data within this jurisdiction. If you access the Website from outside the Dominican Republic, please be aware that your information may be transferred to, stored, and processed in the Dominican Republic, where data protection laws may differ from those in your country of residence. By using the Website, you consent to such transfer and processing.

10. Children’s Privacy

The Website and our services are not directed at individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal information from a minor, we will take steps to delete such information promptly.

11. Changes and General Provisions

Policy Updates: We may update this Privacy Policy from time to time. Changes become effective upon posting with an updated Effective Date. Your continued use of the Website constitutes acceptance of the revised policy.

Governing Law: This Privacy Policy is governed by the laws of the Dominican Republic. Any disputes arising from this policy shall be resolved in the competent courts of the Dominican Republic.

Language: This Privacy Policy is drafted in English. In the event of any conflict with a translated version, the English version shall prevail.

12. Contact Information

For questions, concerns, or to exercise your data protection rights:

Company:

Navetta Properties

Inversiones Navetta SRL

Email:

[email protected]

Websites:

navettaproperties.com

inversionesnavetta.com

Location:

Las Terrenas, Samaná, Dominican Republic