VIACAP – PRIVACY POLICY

Effective Date: 1 May 2026

1. INTRODUCTION

This Privacy Policy explains how Ecommventures Ltd ("Viacap", "we", "us"), operator of viacap.io (the "Platform"), collects, uses, and protects personal data.

Viacap provides a business intelligence platform focused on institutional real estate markets, including investor profiles, transaction activity, and related professional data.

We are committed to processing personal data transparently, lawfully, and securely, in accordance with:

• The UK Data Protection Act 2018
• The UK GDPR and EU GDPR (where applicable)

2. ROLE AS DATA CONTROLLER

Viacap acts as a data controller in relation to:

• Personal data collected from users of the Platform
• Professional contact data included in our database

This means we determine how and why personal data is processed.

3. TYPES OF PERSONAL DATA WE PROCESS

3.1 Platform Users (Clients)

When you interact with Viacap (e.g. account creation, purchase), we may collect:

• Name
• Email address
• Company / role
• Country
• Payment-related metadata (processed via third parties such as Stripe)

3.2 Professional Data in the Viacap Database

Viacap maintains a database of professional individuals active in institutional real estate.

This may include:

• Name and surname
• Job title and employer
• Professional email address
• Public professional profiles (e.g. LinkedIn)
• Associated investment activity or transactions

This data is strictly professional (B2B) in nature and does not include sensitive personal data.

3.3 Website Usage Data

When you access the Platform, we may collect:

• IP address
• Device and browser information
• Usage behaviour and interaction data

This may be collected via cookies and similar technologies.

4. SOURCES OF DATA

We obtain personal data from:

• Publicly available sources (e.g. company websites, press releases)
• Third-party data providers
• Industry publications and disclosures
• Direct interactions with users

We do not knowingly collect data from unlawful sources.

5. PURPOSES OF PROCESSING

We process personal data for the following purposes:

5.1 Providing the Platform

• Deliver access to data and analytics
• Manage user accounts
• Process transactions

5.2 Improving the Platform

• Analyse usage patterns
• Enhance data quality and coverage
• Develop new features

5.3 Business Intelligence Services

• Maintain and update our professional database
• Enable users to identify relevant business contacts

5.4 Legal and Compliance

• Comply with legal obligations
• Prevent fraud and misuse

6. LEGAL BASIS FOR PROCESSING

We rely on the following legal bases:

6.1 Contractual Necessity

Where processing is required to:

• Provide access to the Platform
• Deliver paid services

(Article 6(1)(b) GDPR)

6.2 Legitimate Interests

We process professional contact data based on legitimate interest, specifically:

Building and maintaining a database of institutional real estate professionals to facilitate business connections and market transparency.

We have assessed that:

• The data is professional (not personal/private)
• The impact on individuals is limited
• The use is reasonably expected in a B2B context

(Article 6(1)(f) GDPR)

7. HOW THE DATA IS USED BY CLIENTS

Viacap provides access to professional data to its clients.

However:

• Viacap does not control how clients use the data
• Clients act as independent data controllers

Clients are responsible for:

• Complying with GDPR and applicable marketing laws
• Ensuring lawful use of contact data

Viacap is not responsible for misuse of data by clients.

8. DATA RETENTION

We retain personal data only as long as necessary:

• Client account data: up to 6 years (legal/accounting requirements)
• Prospect/sample requests: up to 12 months
• Database records: retained while relevant to business purposes

We may retain limited data in a suppression list to ensure opt-outs are respected.

9. YOUR RIGHTS

If you are located in the UK, EEA, or other applicable jurisdictions, you may have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion
• Object to processing
• Restrict processing
• Request data portability (where applicable)

You also have the right to lodge a complaint with a data protection authority.

10. OPT-OUT (IMPORTANT)

If your professional data is included in the Viacap database:

• You may request removal at any time
• You may object to processing based on legitimate interest

To do so, contact: hello@viacap.io

Upon request:

• Your data will be removed or restricted
• You may be added to a suppression list to prevent re-inclusion

11. DATA SHARING

We may share personal data with:

• Service providers (hosting, infrastructure, analytics)
• Payment processors (e.g. Stripe)
• Legal or regulatory authorities where required

We do not sell personal data.

We may share aggregated, anonymised data.

12. INTERNATIONAL TRANSFERS

Where data is transferred outside the UK/EEA:

• We ensure appropriate safeguards are in place (e.g. Standard Contractual Clauses)

13. DATA SECURITY

We implement appropriate technical and organisational measures, including:

• Encryption
• Secure servers
• Access controls

However, no system is completely secure, and we cannot guarantee absolute security.

14. COOKIES

We use cookies and similar technologies to:

• Operate the Platform
• Analyse usage
• Improve performance

You can control cookies through your browser settings. Disabling cookies may affect the functionality of the Platform.

15. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time.

The latest version will always be available on our website.

16. CONTACT

For any privacy-related queries or requests:

Email: hello@viacap.io
Address: 27 Old Gloucester Street, London WC1N 3AX