Effective Date: 2025-12-10

Vestra ("we," "our," or "us") is committed to protecting the privacy of our users worldwide. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you interact with our services, including our website, applications, and any other offerings (collectively, the "Services"). As a fractional real estate company, we understand the importance of transparency and trust in handling your personal data.

This policy applies to all information collected through our Services, as well as any related services, sales, marketing, or events. Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access or use our Services.

We may update this Privacy Policy from time to time. The most current version of the policy will govern our processing of your personal data and will always be available on our website. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. You are advised to review this Privacy Policy periodically for any changes.

1. Information We Collect

We collect various types of information to provide and improve our Services to you. This information can be broadly categorized as follows:

• Personal Data: This refers to any information that can be used to identify you directly or indirectly. The types of personal data we may collect include, but are not limited to:
  • Contact Information: Name, email address, phone number, postal address, and other similar contact data. For instance, when you contact us via email at support@vestra.club or by phone at +1(720) 580-1051, or through WhatsApp at +63 946 449 8012, we collect the information you provide to facilitate communication and support.
  • Account Information: Usernames, and other credentials used to access our Services.
  • Financial Information: Payment card details, bank account information, and other financial data necessary for processing transactions related to fractional real estate investments. This is crucial for managing your participation in our Homesite Option Purchase Platform (HOPP'R) and other real estate transactions.
  • Demographic Information: Age, gender, nationality, and other demographic details.
  • Real Estate Preferences: Information about your investment interests, property preferences, and other data relevant to your engagement with our fractional real estate offerings.
  • Communications: Records of your communications with us, including emails, chat messages, and phone calls.
• Usage Data: This includes information about how you access and use our Services. This data may include:
  • Device Information: IP address, browser type, operating system, device identifiers, and other technical information about the devices you use to access our Services.
  • Log Data: Information automatically recorded when you use our Services, such as access times, pages viewed, and the duration of your visits.
  • Location Data: General location information derived from your IP address or, with your consent, more precise location data from your mobile device.
  • Interaction Data: Details of how you interact with our website and applications, including features used, content viewed, and links clicked.
• Cookies and Tracking Technologies: We use cookies and similar tracking technologies to collect information about your browsing behavior and preferences. These technologies help us personalize your experience, analyze trends, and administer the Services. You can control cookie preferences through your browser settings.

2. How We Use Your Information

We use the information we collect for various purposes, including:

• To Provide and Maintain Our Services: This includes operating our fractional real estate platform, processing transactions, managing your investments, and delivering the services you request. For example, your financial information is used to facilitate homesite option purchases and other related real estate activities.
• To Improve and Personalize Your Experience: We use your data to understand your preferences, tailor content, and offer features that are most relevant to you. This helps us enhance the functionality and user-friendliness of our Services.
• To Communicate with You: We use your contact information to send you important updates, notifications, marketing communications, and respond to your inquiries. This includes responding to your queries submitted via email or phone.
• For Security and Fraud Prevention: We employ your information to detect, prevent, and address fraudulent activities, unauthorized access, and other security incidents. This is crucial for maintaining the integrity and safety of our platform and your investments.
• For Analytics and Research: We analyze usage data to understand how our Services are used, identify areas for improvement, and conduct research to develop new features and offerings. This may involve analyzing trends in real estate markets and user engagement.
• To Comply with Legal Obligations: We may use and disclose your information as required by applicable laws, regulations, legal processes, or governmental requests. This includes complying with regulatory filings, such as those with the U.S. Securities and Exchange Commission (SEC).
• For Business Operations: This includes internal management, auditing, and other administrative purposes necessary for the operation of our business.

3. How We Share Your Information

We may share your information with third parties in the following circumstances:

• With Service Providers: We engage third-party service providers to perform functions on our behalf, such as payment processing, data hosting, analytics, marketing, and customer support. These providers are contractually obligated to protect your information and use it only for the purposes for which it was disclosed.
• With Business Partners: We may share information with trusted business partners to offer you complementary services or joint promotions, provided you have consented to such sharing.
• In Business Transfers: In the event of a merger, acquisition, sale of assets, or other business transaction, your information may be transferred to the acquiring entity. We will notify you of any such transfer and any changes to the Privacy Policy.
• For Legal Reasons: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). This also includes enforcing our terms and conditions, protecting our rights, privacy, safety, or property, and that of our affiliates, you, or other third parties.
• With Your Consent: We may share your information with other third parties when we have your explicit consent to do so.
• Aggregated or Anonymized Data: We may share aggregated or anonymized data that does not directly identify you with third parties for various purposes, including research, analytics, and marketing. For example, insights into general real estate market trends or user demographics may be shared without revealing individual identities.

4. Data Security

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, and destruction. These measures include encryption, access controls, secure software development practices, and regular security audits. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security. We continuously review and update our security practices to adapt to evolving threats and technologies.

5. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The retention period may vary depending on the type of data and the purpose of processing. For example, financial transaction records are typically retained for longer periods due to regulatory obligations.

6. Your Privacy Rights

Depending on your jurisdiction, you may have certain rights regarding your personal data, including:

• Right to Access: You have the right to request access to the personal data we hold about you.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data.
• Right to Erasure (Right to Be Forgotten): You have the right to request the deletion of your personal data under certain circumstances.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data under certain conditions.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
• Right to Object: You have the right to object to the processing of your personal data under certain circumstances, particularly when processing is based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us using the contact information provided below. We will respond to your request in accordance with applicable data protection laws.

7. International Data Transfers

As a company operating worldwide, your information may be transferred to, and processed in, countries other than your own. These countries may have data protection laws that are different from the laws of your country. We will take appropriate safeguards to ensure that your personal data remains protected in accordance with this Privacy Policy and applicable laws, such as using standard contractual clauses approved by relevant authorities.

8. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without parental consent, we will take steps to remove that information from our servers.

9. Contact Information

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:

• Email: support@vestra.club
• Phone: +1(720) 580-1051
• WhatsApp: +63 946 449 8012