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Effective Date: October 2025
Last Updated: October 7, 2025

This Privacy Policy describes how Reyes Property Management USA LLC (DBA Reyes Growth Capital) (“Company”, “we”, “our”, or “us”) collects, uses, and discloses information when you visit or use our website www.reyesgrowthcapital.com (the “Site”), our mobile applications (the “App”), or any associated services, forms, memberships, or communication platforms (collectively, the “Services”).

By accessing or using our Services, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use immediately.

1. Information We Collect

We collect personal and non-personal information necessary to operate our business, fulfill service requests, and comply with applicable laws.

1.1 Personal Information

We may collect:

• Full name, email address, and phone number

• Mailing or billing address

• Business name, license number, or company information (for Realtors, lenders, or partners)

• Financial or credit-related data voluntarily provided (e.g., income range, credit score, payment history)

• Government-issued ID for verification when applicable

1.2 Non-Personal Information

We may automatically collect:

• Browser type, IP address, device identifiers, operating system

• App usage statistics, referral URLs, and session duration

• Cookies, tracking pixels, and analytics identifiers (Google Analytics, Facebook Pixel, etc.)

1.3 Payment Information

If you make payments via our Site or App, transaction data is processed securely by Stripe or another PCI-DSS-compliant provider.
We do not store full payment card or bank information on our servers.

2. How We Collect Information

We collect data through:

• Online forms, membership applications, and contact requests

• Automated tracking tools (cookies, analytics, CRM integrations)

• Direct communication by email, phone, or chat

• Partner integrations (Realtors, lenders, or service providers)

By submitting your information, you authorize us to use it as described in this Policy.

3. How We Use Information

We use collected data to:

• Provide, personalize, and improve our Services

• Match clients with verified Realtors, lenders, or property managers

• Process transactions, applications, and service requests

• Communicate updates, confirmations, or promotional offers

• Verify professional eligibility and prevent fraud

• Comply with financial, legal, and regulatory obligations

We may also use aggregated, anonymized data for analytics and business optimization.

4. Sharing and Disclosure

We do not sell, rent, or trade personal information.
We share data only under the following conditions:

• Service Providers: For payment processing, hosting, analytics, or communication.

• Business Partners: When facilitating connections between users and real estate or financial professionals, with prior consent.

• Legal Compliance: To comply with subpoenas, court orders, or other legal obligations.

• Corporate Transactions: In case of merger, acquisition, or sale, with notice provided.

All third parties are contractually required to protect your data.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Store user preferences

• Analyze usage trends

• Deliver personalized recommendations

You may disable cookies through your browser or device settings; however, some features of our Services may not function properly without them.

6. Data Retention

We retain data only as long as needed for the purposes outlined in this policy, or as required by law.
You may request deletion or data access by emailing privacy@reyesgrowthcapital.com.

7. Your Rights

Depending on your jurisdiction, you may:

• Access, correct, or request deletion of your data

• Withdraw consent to data processing

• Request a copy of your data in portable format

• Opt out of marketing communications

To exercise your rights, email privacy@reyesgrowthcapital.com with “Privacy Request” in the subject line.

8. Data Security

We apply administrative, technical, and physical safeguards, including:

• SSL/TLS encryption

• Firewalls and multi-factor authentication

• Restricted access to sensitive systems

Despite our efforts, no digital transmission is 100% secure. You acknowledge and accept this risk when using our Services.

9. App Tracking Transparency (Apple Requirement)

Our App may request permission to track activity for analytics and marketing optimization purposes in compliance with Apple’s App Tracking Transparency (ATT) framework.
You can disable tracking in your iOS device settings at any time:
Settings → Privacy → Tracking.

10. Location Data

If you grant location access, we may collect and process approximate or precise location data to:

• Suggest nearby properties or real estate services

• Improve geographic relevance of offers

Location access is optional and may be disabled at any time in device settings.

11. Children’s Privacy

Our Services are intended for users 18 years or older.
We do not knowingly collect or process personal data from minors.
If we become aware of data collected from a child under 18, we will delete it immediately.

12. International Transfers

If you access our Services outside the U.S., your data may be transferred and processed in the United States, where privacy laws may differ.
We ensure that such transfers comply with applicable legal frameworks.

13. Changes to This Policy

We may update this Policy periodically.
The “Last Updated” date indicates the most recent revision.
Continued use of our Services constitutes acceptance of any modifications.

14. Contact Us

If you have questions or concerns about this Privacy Policy, contact us at:

Reyes Property Management USA LLC (DBA Reyes Growth Capital)
1200 Brickell Avenue, Suite 1950 #1191
Miami, FL 33131
📧 Email: privacy@reyesgrowthcapital.com
🌐 Website: www.ReyesGrowthCapital.com