Privacy Policy

SEVND, S.R.L. — Effective Date: June 25, 2026

SEVND, S.R.L., a Dominican Republic limited-liability company with offices in Santo Domingo, Dominican Republic ("SEVND", "we", "our", or "us"), respects your privacy. This Privacy Policy (this "Policy") describes the information we collect from and about you, how we use and share it, and the choices and rights you have. SEVND is the data controller ("responsable del tratamiento") for personal data processed under this Policy, within the meaning of Dominican Republic Law 172-13 on the Protection of Personal Data.

This Policy applies to information collected through https://www.sevnd.com and the SEVND Marketplace (together, the "Site"); through email, text, WhatsApp, and other electronic communications between you and us; and when you interact with SEVND advertising or features on third-party services that link to this Policy.

Several things this Policy does not cover:

Information collected offline or through other channels not connected to the Site.
Your interactions with third-party websites, apps, or services that we link to. Third-party services have their own privacy policies, which apply when you use them.
Information processed by service providers we use for specific functions — for example, identity-verification providers we engage to confirm user identities. When you complete identity verification, your interaction with that provider is governed by the provider's own privacy policy.

Please read this Policy carefully. By using the Site, you agree to this Policy. If you do not agree, please do not use the Site. Dominican Republic residents should also review the SEVND Dominican Republic Privacy Notice, which supplements this Policy and provides additional disclosures under Law 172-13.

1. Children Under 18

The Site is not directed to children under 18 years of age (or the age of majority in your country of residence, if greater), and we do not knowingly collect personal information from anyone under that age. If you are under 18, please do not use the Site or provide any information through it. If we learn that we have collected personal information from a minor without the consent required by law, we will delete that information promptly. 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.

2. Information We Collect

2.1 Categories of Information

We collect the following categories of information from and about users of the Site:

identifiers and contact information, such as name, postal address, email address, telephone number (including WhatsApp number), Dominican identity-card number (cédula) or passport number where required for verification, and online identifiers;
account information, such as username, password (stored in hashed form), authentication tokens, and account preferences;
for sellers, business information about the business or digital asset you list, including financial metrics, traffic and customer data, intellectual-property descriptions, and operational details;
for buyers, acquisition criteria, investor profile, funding capacity indicators, budget range, and other information you submit to qualify for the Marketplace;
transaction information, such as records of payments, fees, and Closing Fees collected, processed, or due;
communications and correspondence with us, including support tickets, deal-room messages, contact-form submissions, and feedback;
search queries and activity within the Site;
User Contributions you post or transmit through public or shared areas of the Site;
preferred contact times and channels (morning, afternoon, evening, flexible, WhatsApp, email-only); and
device, connection, and usage information, such as IP address, browser type and version, operating system, referring URLs, pages visited, and timestamps.

Dominican Republic residents can find a Law 172-13-aligned breakdown of categories, purposes, recipients, and rights in the SEVND Dominican Republic Privacy Notice.

2.2 Sources

We collect this information from three main sources:

Directly from you, when you register, complete forms, submit a listing, contact us, respond to a survey, search the Site, or otherwise voluntarily provide information.

Automatically, as you interact with the Site — including through cookies, pixels, SDKs, log files, and similar technologies (see Section 3).

From third parties, such as service providers (including identity-verification, payment-processing, and analytics providers), marketing partners, public databases (including the Dominican Registro Mercantil and the DGII RNC database for entity verification), and integrations you authorize.

2.3 Voluntary Third-Party Data Connections

If you choose to enrich your listing with verified data, you may connect a third-party account or provide API keys, view IDs, or OAuth tokens for tools such as Stripe, Google Analytics, ChartMogul, Baremetrics, ProfitWell, QuickBooks, or similar services. By doing so, you grant SEVND read-only access to specific data in those third-party accounts so that the resulting metrics can be displayed on your listing and used in the diligence process. You remain bound by the third party's terms and privacy policy when you make these connections. You can revoke access to any connected third-party account at any time through that third party's settings or by contacting us.

2.4 Sensitive Personal Data

Under Article 76 of Law 172-13, certain categories of personal data — including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health, sex life, or biometric or genetic data — are considered specially protected ("sensitive") personal data. SEVND does not require you to provide sensitive personal data to use the Site. Where any sensitive data is processed (for example, biometric data collected by an identity-verification provider, in compliance with Law 4-23), we will obtain your express, free, conscious, and informed consent as required by law before processing it.

3. Cookies and Similar Technologies

3.1 What We Use

We and our service providers use cookies, pixels, SDKs, web beacons, local storage, and similar technologies on the Site for the following purposes:

Strictly necessary — authentication, session management, security, fraud prevention, load balancing, and core functionality. These cannot be disabled without breaking the Site.

Functional — preferences such as language, time zone, and recent searches.

Analytics — understanding how the Site is used, measuring traffic and engagement, and improving features. Analytics providers may include Google Analytics and similar tools.

Marketing and measurement — measuring the effectiveness of our marketing and CRM workflows. Marketing-tool providers may include HubSpot and similar tools.

3.2 Your Choices

Most browsers let you refuse or delete cookies through your browser settings. You can also use browser extensions and operating-system features that limit tracking. If you disable cookies, some parts of the Site may not work as intended. Where required by applicable law, we display a cookie banner on the Site that lets you accept, reject, or customize non-essential cookies.

3.3 Third-Party Cookies

Some content on the Site is served by, or includes connections to, third parties (for example, embedded analytics scripts, marketing pixels, and CRM tools). These third parties may set their own cookies and collect information about your interactions with the Site. We do not control these third parties' cookies or how they use the information they collect. Their practices are governed by their own privacy policies.

4. How We Use Your Information

We use the information we collect for the following purposes:

providing, operating, securing, and improving the Site, the SEVND Marketplace, and our services;
creating and maintaining your account, authenticating you, and recovering or resetting access;
displaying authorized listing information to qualified prospective buyers, and surfacing buyer profiles to listed sellers, consistent with your account settings;
processing transactions and calculating, invoicing, and collecting fees (including the Closing Fee), in accordance with applicable tax laws including Law 32-23 on Electronic Invoicing;
performing identity verification, fraud prevention, anti-money-laundering checks, and sanctions screening, including through third-party providers;
communicating with you about your account, your transactions, 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, including sending listing alerts, newsletters, and event invitations you have asked to receive;
personalizing the Site and recommending listings, content, and resources that may interest you;
performing analytics, research, and quality assurance to understand how the Site is used and to improve it;
detecting, investigating, and preventing security incidents, fraud, abuse, and illegal activity, including acts prohibited by Dominican Republic Law 53-07 on High-Technology Crimes;
complying with legal obligations under Dominican Republic law (including the Civil Code, Law 172-13, Law 358-05, and applicable tax and AML obligations) and lawful requests from public authorities; and
any other purpose disclosed when you provide the information, or to which you consent.

We do not use your personal information to train or develop third-party generative-AI or machine-learning models. We may use de-identified or aggregated data, and limited operational logs, to improve our own service quality and reliability.

5. Sale and Sharing of Personal Information

SEVND does not sell your personal information. Depending on how analytics, marketing-measurement, and CRM tools are configured, our use of certain third-party technologies could involve the disclosure of online identifiers to those providers, which under some foreign laws may be considered "sharing" of personal information. Where you live in a jurisdiction that gives you the right to opt out of such sharing, you may do so by emailing privacy@sevnd.com or by using the cookie controls described in Section 3.2.

6. When We Disclose Information

We may disclose information about you to:

our affiliates and subsidiaries, where necessary to provide and support our services;
service providers and data processors ("encargados del tratamiento") that host, secure, and support the Site and our business — for example, cloud hosting, email delivery, WhatsApp messaging, payment processing, identity verification, customer support, analytics, and CRM — each bound by contractual obligations to keep information confidential and use it only for the purposes for which we provide it;
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 Marketplace users, but only as needed to facilitate a transaction, communication, or feature you initiated, and consistent with the Platform Terms;
an actual or potential acquirer, investor, lender, or successor in connection with a financing, merger, acquisition, reorganization, or sale of substantially all of our assets, subject to customary confidentiality protections;
Dominican Republic and foreign courts, regulators, law-enforcement authorities, and other public authorities (including Pro-Consumidor and the Dirección General de Impuestos Internos, where applicable), where required by law, legal process, or to protect our rights, our users, or the public; and
any other third party with your consent or at your direction.

We may disclose aggregated or de-identified information that cannot reasonably be used to identify you, for any lawful purpose.

7. International Data Transfers

SEVND is established in the Dominican Republic, but our service providers and infrastructure may be located in other jurisdictions, including the United States, the European Union, and other countries. Information we collect may therefore be processed outside the Dominican Republic. 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. By using the Site and providing information through it, you consent to the international transfer of your personal data as described in this Policy.

Where transfers involve personal data of residents of the European Economic Area, the United Kingdom, or Switzerland, we use appropriate safeguards — for example, the European Commission's Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum, and the Swiss equivalent — together with supplementary measures where appropriate.

8. Legal Bases (EEA, UK, and Switzerland Residents)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under the GDPR (or its UK or Swiss equivalent) to process your personal information:

Legal Basis	When We Rely On It
Performance of a contract	To provide the services you have requested, including managing your account, processing transactions, and communicating with you about your use of the Site and Marketplace.
Legitimate interests	To operate, secure, and improve our services; understand how the Site is used; perform marketing measurement; detect and prevent fraud and abuse; and protect our rights, users, and business — in each case where our interests are not overridden by your interests or fundamental rights.
Consent	Where required by law — for example, for non-essential cookies, certain marketing communications, and processing of special categories of data. You may withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.
Legal obligation	Where processing is necessary to comply with a legal obligation we are subject to, including tax, anti-money-laundering, sanctions-screening, and recordkeeping obligations.
Vital or public interest	In the limited circumstances where processing is necessary to protect a person's vital interests or for reasons of substantial public interest as recognized by applicable law.

9. Your Rights and Choices

9.1 Universal Choices

You always have the following choices:

review and update most personal information through your account profile on the Site;
unsubscribe from marketing emails by using the unsubscribe link in any marketing message we send you, or by adjusting your communication preferences in your account;
control non-essential cookies through our cookie banner, your browser settings, and your operating-system controls; and
close your account at any time by emailing privacy@sevnd.com.

9.2 Dominican Republic Residents

If you are a resident of the Dominican Republic, you have rights under Article 44(2) of the Constitution and Law 172-13 to confirm the existence of processing, access, rectify, update, and suppress your personal data, and to oppose its processing, among other rights. The SEVND Dominican Republic Privacy Notice describes those rights in detail and explains how to exercise them.

9.3 EEA, UK, and Swiss Rights

If you are located in the EEA, the UK, or Switzerland, you have rights under applicable data-protection laws, subject to certain conditions and exceptions, including:

Right	Description
Right of Access	To be informed of, and request access to, the personal information we process about you.
Right to Rectification	To request correction of personal information that is inaccurate or incomplete.
Right to Erasure	To request deletion of certain personal information, subject to legal exceptions.
Right to Restriction	To request that we temporarily or permanently restrict processing of all or part of your personal information.
Right to Object	To object to processing based on our legitimate interests, and to object at any time to processing for direct-marketing purposes.
Right to Data Portability	To receive a copy of personal information you provided to us in a structured, commonly used, machine-readable format.
Right to Withdraw Consent	Where processing is based on your consent, to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
Right Regarding Automated Decisions	Not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects. SEVND does not engage in such automated decision-making.
Right to Lodge a Complaint	To lodge a complaint with the data-protection supervisory authority in your country of residence, place of work, or place of the alleged infringement.

To exercise any of these rights, email privacy@sevnd.com. We will respond within the period required by applicable law. We will verify your identity before responding to a request, using information we already hold or by asking for additional information where needed.

10. Data Retention

SEVND retains your personal information for as long as reasonably necessary to provide our services, maintain business records, comply with legal and tax obligations under Dominican Republic law (including obligations under the Tax Code and Law 32-23 on Electronic Invoicing), 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 information, the purpose of processing, applicable legal requirements (including statutes of limitation and recordkeeping rules), and our legitimate business needs.

If you close or ask us to close your account, we will delete, de-identify, or anonymize your personal information unless we are required or permitted to retain it. Common reasons we may need to retain information include:

an unresolved issue, such as an outstanding payment, claim, or dispute;
tax, audit, accounting, anti-money-laundering, sanctions-screening, or other legal recordkeeping obligations;
fraud detection, abuse prevention, and platform-security investigations;
exercise or defense of legal claims; and
back-up, disaster-recovery, and business-continuity systems, until those backups are recycled in the ordinary course.

11. Security

Consistent with the security principles in Article 6 of Law 172-13, SEVND maintains administrative, technical, and physical safeguards designed to protect your personal information against accidental loss and against unauthorized access, use, alteration, or disclosure. These include encryption in transit and at rest where appropriate, access controls, authentication requirements, network and application security monitoring, and regular reviews of our practices.

Security is a shared responsibility. Where we have given you (or where you have chosen) a password to access certain parts of the Site, you are responsible for keeping that password confidential. Do not share your password, and use particular care when accessing your account from a shared or public device.

Although we work hard to protect your information, no system is completely secure, and the transmission of information over the internet is never entirely risk-free. Any transmission of personal information to or from the Site is therefore at your own risk.

12. Changes to This Policy

SEVND may update this Policy from time to time. When we make material changes to how we treat personal information, we will post the updated Policy on this page, update the Effective Date, and — where required by law or otherwise appropriate — provide notice through the Site, by email, or by other reasonable means. You are responsible for keeping your contact information current and for periodically reviewing this Policy.

13. Contact Us

If you have questions, comments, or requests about this Policy or our privacy practices — including to exercise any privacy right — please contact our Privacy Team at:

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

Dominican Republic residents may also raise consumer-data complaints directly with the National Institute for the Protection of Consumer Rights (Pro-Consumidor) at https://proconsumidor.gob.do or via the contact information provided there. EEA, UK, and Swiss residents have the right to lodge a complaint with the data-protection authority in their country of residence.

Questions? Contact: legal@sevnd.com