DR Privacy Notice

Law 172-13 Disclosures — Effective Date: June 25, 2026

This Dominican Republic Privacy Notice (this "DR Notice") supplements the SEVND Privacy Policy and applies to natural persons resident in the Dominican Republic ("you"). It describes how SEVND, S.R.L. ("SEVND," "we," "our," or "us") collects, uses, discloses, and otherwise processes your personal data, and the rights you have under Article 44(2) of the Constitution of the Dominican Republic, Law No. 172-13 on the Comprehensive Protection of Personal Data ("Law 172-13"), Law No. 358-05 on Consumer Protection ("Law 358-05"), and other applicable Dominican law.

SEVND is the data controller ("responsable del tratamiento") for personal data described in this DR Notice. Capitalized terms not defined herein have the meaning given to them in the SEVND Privacy Policy or in Law 172-13. If there is any conflict between this DR Notice and the Privacy Policy with respect to Dominican Republic residents, this DR Notice prevails.

1. Your Rights Under Law 172-13 at a Glance

Subject to the conditions described in this DR Notice, Dominican Republic residents have the following rights with respect to their personal data:

Right to Be Informed (Article 5, Law 172-13) — to receive, at or before the time of collection, clear, written information about the existence of the file or database, its purpose, the categories of recipients, and the identity and address of the controller.
Right to Access (Article 10, Law 172-13) — to be informed of, and obtain access to, the personal data we process about you, free of charge, at intervals of not less than six months unless a legitimate interest in earlier access is shown.
Right to Rectification (Article 14, Law 172-13) — to request that we correct inaccurate, incomplete, or out-of-date personal data.
Right to Update — to request that we update your personal data so that it remains accurate and complete.
Right to Suppression (Erasure) — to request that we delete personal data that was unlawfully processed, that is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and no other legal basis exists for our continued processing.
Right to Confidentiality and Security — to expect that we will keep your personal data confidential, will apply security measures appropriate to its sensitivity, and will require our staff and processors to honor the duty of professional secrecy.
Right to Object — to oppose the processing of your personal data on grounds relating to your particular situation, and to opt out of direct-marketing communications.
Right to Withdraw Consent — where processing is based on your consent, to withdraw that consent at any time, without affecting the lawfulness of processing before withdrawal.
Right to File a Complaint — to file a complaint with Pro-Consumidor (for matters relating to the protection of consumer data) or to bring an action before the competent Dominican courts.

Section 4 explains how to submit a request and how we verify it.

2. Categories of Personal Data We Process

In the prior twelve (12) months, SEVND has collected the following categories of personal data about Dominican Republic residents. The table describes each category, the typical examples, the purpose for which it is collected, the source, and whether it is transferred internationally.

Category	Examples	Purpose	Source	Transferred Abroad?
A. Identification and contact	Name, alias, cédula or passport number, postal address, email, phone (including WhatsApp), online identifiers.	Account creation; login; communication; identity verification; legal compliance; fraud prevention.	Directly from you; identity-verification providers; cloud and email infrastructure.	Yes, to cloud and email service providers.
B. Account and authentication	Username, password (hashed), session tokens, multi-factor codes, account preferences.	Securing access to the Site and Marketplace; supporting account recovery.	Directly from you; automatically through the Site.	Yes, to cloud and authentication service providers.
C. Listing and business data (sellers)	Business description, financial metrics, traffic and customer data, IP descriptions, photos, operational details.	Listing the business on the Marketplace; supporting diligence; calculating fees.	Directly from you; voluntary third-party data connections.	Yes, to cloud and analytics service providers.
D. Buyer profile data	Acquisition criteria, investor profile, budget range, preferred contact channel and time.	Matching qualified buyers with listings; supporting communications.	Directly from you.	Yes, to cloud service providers.
E. Transaction data	Records of payments, fees, Closing Fees, and tax-related information.	Processing transactions; invoicing under Law 32-23 on Electronic Invoicing; accounting and tax compliance.	Directly from you; payment processors.	Yes, to payment processors and cloud accounting providers.
F. Communications and correspondence	Email, contact-form submissions, chat and WhatsApp messages, support tickets, feedback.	Responding to inquiries; providing support; improving the Site.	Directly from you.	Yes, to cloud email and messaging providers.
G. Internet / network activity	Browsing history on the Site, page interactions, referring URLs, session data.	Operate, secure, and improve the Site; measure marketing effectiveness; troubleshoot.	Automatically through cookies, pixels, SDKs, and similar technologies.	Yes, to analytics and marketing-tool providers.
H. Approximate location	City- or country-level location derived from IP address.	Security and fraud prevention; serving content appropriate to your region. We do not collect precise geolocation.	Automatically from your IP address.	Yes, to analytics and security providers.
I. Sensitive personal data (Article 76, Law 172-13)	Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, health, sex life, biometric or genetic data.	We do not require sensitive data to use the Site. Where any sensitive data is processed (for example, biometric data collected by an identity-verification provider under Law 4-23), we obtain your express, free, conscious, and informed consent.	Identity-verification providers (only with your express consent).	Where consent is given, yes, to the verification provider.

3. Purposes, Legal Basis, Recipients, and Retention

3.1 Purposes

SEVND collects, uses, and discloses personal data for the following purposes:

providing, operating, securing, and improving the Site, the SEVND Marketplace, and our services;
creating, administering, and maintaining your account, including authentication and account recovery;
processing transactions, calculating and collecting fees (including the Closing Fee), and producing receipts, tax-related reports, and electronic invoices under Law 32-23;
verifying identity and performing know-your-customer, anti-money-laundering, sanctions-screening, and fraud-prevention checks, including through third-party providers;
communicating with you about your account, your transactions, listings, support requests, and changes to our terms or policies, through email, in-Site messaging, or WhatsApp if you have chosen that channel;
marketing SEVND products and services where permitted by law, and managing email and other communication preferences;
personalizing the Site and recommending listings, content, and resources that may interest you;
performing analytics, research, and quality assurance, including measuring engagement and the effectiveness of marketing;
detecting, investigating, and preventing security incidents, fraud, abuse, or other illegal activity (including activity prohibited by Law 53-07);
complying with legal obligations, responding to lawful requests from public authorities, and enforcing our agreements; and
any other purpose disclosed at the point of collection or to which you consent.

3.2 Legal Basis

Under Law 172-13, the general rule is that processing of personal data requires the data subject's free, unambiguous, specific, and informed consent (Article 6(7)). Article 27 of Law 172-13 establishes exceptions, including where processing is necessary for: (a) data obtained from publicly accessible sources; (b) the exercise of governmental functions or compliance with a legal obligation; (c) marketing lists limited to name, identity document number, tax identification, and other biographical information; or (d) a commercial, employment, contractual, scientific, or professional relationship with the data subject, where the processing is necessary for its development or compliance. SEVND relies on consent and on these exceptions, as applicable, for the processing described in this DR Notice.

3.3 Categories of Recipients

We may disclose personal data to the following categories of recipients for the purposes above:

service providers and processors (encargados del tratamiento) that help us operate the Site and Marketplace (for example, hosting, security, analytics, customer support, email and WhatsApp delivery, payment processing, identity verification, and cloud storage);
professional advisors (legal, accounting, audit, tax, and insurance) acting on our behalf;
advisors, lenders, escrow partners, and similar partners that you choose to engage in connection with a transaction;
other users of the Site or Marketplace, but only as needed to facilitate communication or a transaction you initiated, and consistent with the Platform Terms;
Dominican Republic and foreign government agencies, courts, regulators, and law-enforcement authorities (including Pro-Consumidor and the Dirección General de Impuestos Internos), where we believe disclosure is required by law, legal process, or to protect our rights, users, or the public; and
actual or potential acquirers, investors, lenders, or successors in connection with a financing, merger, acquisition, reorganization, or sale of substantially all of our assets, subject to customary confidentiality protections.

3.4 Retention

SEVND retains each category of personal data for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide our services, maintain business records, comply with legal and tax obligations under Dominican Republic law, resolve disputes, prevent fraud and abuse, and enforce our agreements. Retention periods vary by category and are determined based on the nature and sensitivity of the data, the purpose for which it is processed, applicable legal requirements (including statutes of limitation and recordkeeping laws), and our legitimate business needs. When personal data is no longer needed, we delete or de-identify it.

4. How to Submit a Request

4.1 By Email

To exercise any of your rights under Law 172-13, please email privacy@sevnd.com with the subject line identifying the request type (for example, "Solicitud de Acceso — Law 172-13"). Include enough information for us to (a) reasonably verify your identity and (b) understand and respond to your request.

4.2 By Mail

You may also send a written request to: SEVND, S.R.L., Attn: Privacy, Santo Domingo, Dominican Republic. We recommend sending requests by certified mail with return receipt.

4.3 Verification

To protect your information, we will take reasonable steps to verify your identity before responding to an access, rectification, update, or suppression request. The verification process depends on the sensitivity of the information requested and your relationship with us. For most account-based requests, we will verify by matching information you provide with information already in our records. For requests involving more sensitive information, we may request additional verification, such as a copy of your cédula or passport.

4.4 Authorized Representatives

You may use a representative authorized by power of attorney to submit a request on your behalf. We will require evidence of the representative's authority and may also require direct verification of your own identity.

4.5 Response Time and Cost

We will acknowledge receipt of your request and respond within a reasonable period appropriate to the request. Under Article 10 of Law 172-13, access requests are free of charge when made at intervals of at least six months, unless a legitimate interest justifies more frequent access.

4.6 Manifestly Unfounded or Excessive Requests

We may decline or charge a reasonable fee for requests that are manifestly unfounded, excessive, or repetitive (for example, frequent identical requests). We will explain the reason for any denial.

5. Sensitive Personal Data

Under Article 76 of Law 172-13, certain categories of personal data are specially protected, including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health, sex life, or biometric or genetic data. As a general rule, sensitive data may only be processed with the data subject's free, conscious, and express consent.

SEVND does not require you to provide sensitive personal data to use the Site. Where any sensitive data is processed in connection with the Site — for example, biometric data collected by an identity-verification provider in compliance with Law 4-23 on the Organic Law of Civil Status — we will inform you in writing or by electronic means about the purpose and retention period, and we will obtain your express consent before processing it.

6. International Data Transfers

Under Article 80 of Law 172-13, transfers of personal data outside the Dominican Republic generally require the data subject's consent, except where the transfer is necessary for the performance of a contract with the data subject, for the protection of vital interests, or for compliance with a legal obligation. SEVND uses service providers and infrastructure located in jurisdictions outside the Dominican Republic (including the United States, the European Union, and other countries). By using the Site and providing personal data through it, you consent to the international transfer of your personal data for the purposes described in Section 3.

SEVND uses appropriate contractual safeguards with its international service providers (including data-processing agreements with confidentiality and security commitments). Where transfers involve residents of the European Economic Area, the United Kingdom, or Switzerland, we also use the European Commission's Standard Contractual Clauses and equivalent mechanisms.

7. Marketing Communications

Under Article 27 of Law 172-13, marketing lists limited to name, identity document number, tax identification, and other biographical information may be processed without consent. SEVND will only contact you for direct-marketing purposes where permitted by law, and you may at any time:

use the unsubscribe link in any marketing email we send you;
reply STOP to any marketing SMS or WhatsApp message;
adjust your communication preferences in your account; or
email privacy@sevnd.com to opt out of all direct-marketing communications.

8. Security and Breach Notification

Consistent with the security and integrity principles of Article 6 of Law 172-13 and the obligations of INDOTEL Resolution No. 055-06 (where applicable), SEVND maintains physical, technical, and administrative safeguards aligned with the sensitivity of the data we process. If we become aware of a security incident affecting your personal data, we will notify you and any applicable authorities in accordance with applicable law.

9. Cookies and Similar Technologies

Information about how SEVND uses cookies, pixels, SDKs, and similar technologies is set out in Section 3 of the SEVND Privacy Policy. Where required, the Site will display a cookie banner that lets you accept, reject, or customize non-essential cookies.

10. Children

The Site is not directed to children under the age of 18 (or the legal age of majority in your jurisdiction). Under Article 488 of the Civil Code of the Dominican Republic, minors must be legally represented by their parents or legal guardians to give consent. We do not knowingly process personal data of minors without the consent required by law.

11. Changes to This DR Notice

SEVND may update this DR Notice from time to time to reflect changes in our practices, technologies, legal requirements, or for other reasons. When we make material changes, we will update the Effective Date above and provide notice through the Site or by other reasonable means.

12. Complaints and Contact

If you have any questions about this DR Notice or our handling of personal data, please contact us:

Email: privacy@sevnd.com
Web: https://www.sevnd.com/contact
Mail: SEVND, S.R.L., Attn: Privacy, Santo Domingo, Dominican Republic.

If you are not satisfied with our response, you may file a complaint with the National Institute for the Protection of Consumer Rights (Pro-Consumidor), which is responsible for protecting consumer data in commercial relationships:

Pro-Consumidor — Av. Charles Summer #33, Los Prados, Distrito Nacional, Santo Domingo, Dominican Republic Tel.: 809-472-2731 — Complaints: 809-567-8555 Web: https://proconsumidor.gob.do

You may also bring an action before the competent Dominican courts.

Questions? Contact: legal@sevnd.com