1. Introduction
At Molionex S.A.S. (hereinafter, "Molionex"), located at Av. del Libertador 4980, Floor 12, C1426BWB, Buenos Aires, Argentina, we are committed to protecting the privacy of those who use our real estate crowdlending platform. This Privacy Policy describes how we collect, use, store, and protect your personal information under Argentina's Personal Data Protection Law No. 25,326 and the provisions of the Agency for Access to Public Information (AAIP).
2. Data we collect
We collect information you provide directly when registering, completing your investor profile, or communicating with us: full name, identity document (DNI/CUIL/CUIT), email address, phone number, home address, basic financial information necessary to assess your investor profile, and bank details for managing contributions and returns. We also automatically collect browsing data such as IP address, device type, browser, pages visited, and session duration.
3. Purpose of data processing
We use your personal data to: manage your account and verify your identity in accordance with anti-money laundering regulations (UIF); administer your investments in real estate crowdlending projects; send you information about the status of projects you participate in; comply with legal, tax, and regulatory obligations before the CNV, AFIP, and other competent bodies; improve the user experience on our platform; and, with your consent, send you commercial communications about new investment opportunities.
4. Legal basis for processing
The processing of your data is based on: your express consent upon registering on the platform; the execution of the participation contract in crowdlending projects; compliance with legal obligations (Law 25,326, CNV regulations, UIF provisions, current tax legislation); and our legitimate interest in improving our services, provided your fundamental rights do not take precedence.
5. Sharing information with third parties
We do not sell or rent your personal data to third parties. We share information only with: real estate developers associated with the projects you invest in (minimum necessary data); technology service providers who assist us in platform operations, under confidentiality agreements; banking entities and payment processors for transaction management; and regulatory or judicial bodies when required by current legislation.
6. International data transfers
Some of our technology service providers may operate outside of Argentina. In such cases, we ensure that international data transfers comply with the requirements established by Law 25,326 and AAIP provisions, ensuring adequate levels of protection through standard contractual clauses or by verifying that the destination country offers an equivalent level of protection.
7. Data retention
We retain your personal data for as long as necessary to fulfill the purposes described in this policy and to comply with applicable legal obligations. Data related to investments is kept for a minimum of ten (10) years in accordance with Argentine tax and commercial regulations. Browsing data is retained for a maximum of twenty-four (24) months.
8. Your rights
As a data subject, you have the right to: access your personal data and know what information we hold about you; request the rectification of inaccurate or incomplete data; request the deletion of your data when it is no longer necessary for the purpose for which it was collected; and object to the processing of your data for direct marketing purposes. You can exercise these rights by sending an email to privacidad@molionex.com with the subject line "Exercise of ARCO rights." We will respond within the ten (10) business days established by law.
9. Data security
We implement technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or destruction. We use TLS/SSL encryption for all communications, encrypted storage of sensitive data, role-based access controls, continuous security monitoring, and periodic audits of our systems.
10. Changes to this policy
We reserve the right to update this Privacy Policy. Any changes will be published on this page with the date of the last update. If the changes are significant, we will notify you by email or through a prominent notice on the platform.
11. Contact
If you have questions about this Privacy Policy or about the processing of your personal data, you can contact us at: Molionex S.A.S. — Av. del Libertador 4980, Floor 12, C1426BWB, CABA, Argentina — privacidad@molionex.com — +54 11 5032-8741. You may also file a complaint with the Agency for Access to Public Information (AAIP) if you believe your rights have been violated.