Commercial Communications Policy

1. Purpose and controller

This policy explains what communications Realty Investor may send to Users of the beta version of the App (the “Beta”), which of them require prior consent and how to stop receiving them.

The controller is REALTY INVESTOR HUB, SOCIEDAD LIMITADA (Realty Investor or RI), CIF B-21948260, Carrer Jardí, 11, 08800 Vilanova i la Geltrú (Barcelona), Spain, contacto@realtyinvestor.eu.

This policy applies only to communications addressed to Users of the Beta and must be read together with the Privacy Policy, the Cookie and Similar Technologies Policy and the Terms of Use.

2. Service communications

RI may send communications that are necessary to provide the Beta, to comply with legal obligations or to respond to requests from the User. They have no promotional purpose and do not depend on commercial consent while the Beta Account is active.

• Account verification, password reset, security notices and support responses.
• Incidents, maintenance, interruptions, changes to the Terms of Use or legal policies, or the closure of the Beta.
• Alerts that the User sets up on specific projects or categories, limited to the information requested.
• Surveys or requests for feedback on the Beta, where they do not include promotional content and are aimed at improving the product.

These communications are based, as the case may be, on the performance of the contract, compliance with legal obligations or the legitimate interest of RI, in accordance with the Privacy Policy.

3. Commercial communications

Electronic communications with a promotional purpose — such as news about RI, features, roadmap, events, referral programmes, educational content, newsletters, usage reminders, highlights of projects not requested through an alert, and the announcement of the launch of the final version — require prior, free and specific consent.

Consent is collected at registration by means of a separate, unticked box. Not giving it does not prevent the User from creating an account or using the Beta.

Consent may cover sending by email and by notifications on the device, the reasonable adaptation of the content or frequency to the User’s activity in the App — including their simulated portfolio — and the measurement of opens and clicks of commercial emails, all in accordance with the Privacy Policy and the Cookie Policy.

RI will keep proof of the consent given, with the date, time and version of the text accepted.

4. Channels, sender and frequency

Commercial communications will be sent from contacto@realtyinvestor.eu or from other identified RI channels, and must clearly identify Realty Investor as the sender.

Push notifications require, in addition to commercial consent where they have a promotional purpose, that the User has granted the permission requested by the device’s operating system.

RI does not commit to a specific frequency, but will keep its mailings reasonable and proportionate, avoiding repetitive or disproportionate communications.

5. Projects and platforms

Where a communication highlights projects published by crowdfunding platforms, it will be RI’s own communication. The platforms do not access the User’s data, do not take part in the sending and do not send communications through RI.

These communications are informational or promotional in nature with regard to RI’s service and do not constitute advice, a personalised recommendation or an investment offer, in accordance with the Terms of Use.

6. Unsubscribing and withdrawal of consent

The User may withdraw their consent at any time, easily and free of charge:

• via the unsubscribe link included in each commercial email;
• by writing to contacto@realtyinvestor.eu; or
• by disabling notifications in the device settings, in the case of push notifications.

Unsubscription will be applied as soon as possible and, in any event, within a maximum of 72 hours of its receipt.

The withdrawal of consent does not affect previous mailings, does not entail the cancellation of the Beta Account and does not prevent the User from continuing to use the App. The User will continue to receive service communications.

7. Exclusion list

When the User unsubscribes from commercial communications, RI will keep their email address on an exclusion list for the sole purpose of avoiding new mailings being sent by mistake and of evidencing that the User’s decision has been respected.

This retention is based on compliance with the obligation to act on the objection or the withdrawal of consent and on the legitimate interest of RI. The data on the exclusion list will not be used for any other purpose and will be kept for as long as that purpose subsists.

The User may request the deletion of their data from the exclusion list, although this may prevent RI from avoiding future mailings resulting from a subsequent sign-up.

8. Minors and data protection

RI does not direct commercial communications at persons under 18 years of age. Registration in the Beta is reserved for persons of legal age, in accordance with the Terms of Use.

The processing of data for the sending, segmentation and measurement of communications is described in the Privacy Policy, which sets out the purposes, legal bases, retention periods, data processors and rights of the User.

9. Changes and contact

RI may update this policy for legal, technical or service-development reasons. If the change affects the scope of the consent, consent will be requested again where appropriate.

For any query, the User may write to contacto@realtyinvestor.eu or contact REALTY INVESTOR HUB, SOCIEDAD LIMITADA, Carrer Jardí, 11, 08800 Vilanova i la Geltrú (Barcelona), Spain.