1. PPortal respects the privacy of the user and is committed to protecting it. This Privacy Policy is presented to inform the user about the privacy procedures and practices we apply, and it explains the information and data we collect about the user, how we obtain such information and data, and the way we use, share, and otherwise process them while conducting our business and operating our platforms. 2. The words “we,” “our,” and “us” in this Privacy Policy refer to PPortal for Digital Marketing. The term “website” refers to the official website of PPortal (www.pportal.net), and the term “platforms” refers collectively to the website and our mobile applications. Every person who accesses and uses our core systems or the services we provide is referred to as “you,” “the user,” and “your.” 3. “Personal information and data” means any information and data that can be used to identify the user or any information and data that we can link to the user and is in our possession or under our control. 4. For the purpose of this Privacy Policy, PPortal acts as a “data controller,” meaning we are responsible for the personal information and data we collect about the user and how we process it. 5. We may update or revise this Privacy Policy at any time, and the latest version will always be available on this page.

The information and data we may collect from or about you include: 1. Your Personal Data: When you register on our platforms as a user or otherwise, and when you update your information, participate in promotional offers, campaigns, or contests, log into our mobile application using your personal information or social media account, send us emails, submit support requests, communicate with brokers through forms or phone numbers available on our platforms, provide feedback, or report a problem on our platforms, you provide us with information and data that we store and process. This may include your name, address, phone number, email address, nationality, residency status, IP address, date of birth, passport number or ID, spending limits, budget, survey participation, video and audio recordings, your interests (including your preferred property type), and any other information and data you choose to provide to us independently (for example, if you send us a message via social media such as WhatsApp or Instagram, or via email or phone call). The user hereby acknowledges that all information provided is accurate and up to date, and shall bear sole responsibility for updating such data in the event of any changes. The platform reserves the right, at its sole discretion, to suspend or terminate the account if any false or misleading information is found to have been submitted. 2. Purchase Information and Data: We may collect information related to any actual or potential purchase of our products, listed properties on our website, or our services (e.g., purchase records). 3. Website Information and Data: We may receive information and data from the user as a result of visits and use of the website. This information may include data such as the user’s IP address, date and time of access to the website, time spent on the website, browsing history (logged through text and graphic files that make up the page), and the internet address of the website from which the user was redirected to our website. 4. Subscription Data: Upon subscribing to the platform’s services, users—whether individuals or licensed real estate brokerage firms—shall be required to provide certain personal or institutional information necessary for account creation and service activation, including but not limited to full name, identification or commercial registration number, contact details, and valid licensing documentation in the case of brokerage firms. Such data shall be used for the following purposes: • Verifying the identity and legal eligibility of the subscriber; • Enabling the user to access and utilize the platform's services; • Communicating in relation to the subscription or the user’s account; • Complying with applicable legal and regulatory obligations under the laws of any country or jurisdiction where the Platform provides its services. 5. Financial, Payment, and Credit Data: Payment information is handled securely via trusted third-party payment gateways. PPortal does not store or process your card or bank data directly. 6. Review Data: When a customer rates a service provider or the provided service, the following data is collected: (the customer's rating of the service “e.g., number of stars”, the comment the customer adds about the service, the date of the review, the identity of the user who gave the review “without publishing their personal data publicly”). 7. Contact Data, Inquiries, Complaints, and Suggestions: When the user contacts the Website for any reason, the data related to this communication is collected, including: (the user's full name, the phone number or email address used for communication, details of the inquiry, complaint, or suggestion submitted, any documents or attachments sent by the user to support their request, the communication record between the user and the support team, any decisions or actions taken based on the complaint or inquiry). This data is used to analyze issues, improve the user experience, ensure service quality, and comply with relevant laws and regulations. 8. Property Listing Content and Real Estate Information: In the context of using the Platform’s services, real estate listings published by licensed real estate brokerage firms may contain data or information that could be considered personal data under the applicable data protection laws in of any country or jurisdiction where the Platform provides its services, this may include, without limitation, images, locations, property descriptions, contact information, or details related to property owners or their authorized representatives. Accordingly, the user—particularly the advertising brokerage firm—acknowledges and agrees to the following: • The advertising company shall be bound to obtain all necessary legal consents or authorizations prior to including any personal data within the property listing content. • The data included in the listings shall be used solely for legitimate real estate marketing purposes via the Platform and shall not be used for any other purpose unless expressly authorized in advance by the data subject or as required by law or competent authorities. • Such content shall be retained within the Platform’s infrastructure only for the period necessary to fulfill the purpose for which it was collected. Its processing and storage shall be subject to strict administrative and security safeguards by the applicable laws and regulations of any country or jurisdiction where the Platform provides its services. • Individuals retain their legal rights with respect to accessing, correcting, or requesting the deletion of their personal data. These rights may be exercised by contacting the account-owning real estate company or the Platform’s administration using the contact details provided in this Policy. 9. Other Information and Data Collected with Your Consent: The Platform may, with your explicit consent, collect, process, and use additional information and data that are not necessary for the provision of core services but may enhance your experience or enable additional features on the Platform, such as: • Your real estate preferences (e.g., preferred property type or price range); • Approximate geographic location to improve search accuracy or personalize advertisements; • Your responses to surveys or participation in reviews and polls; • Any other information you voluntarily provide through your communication with the Platform. Such information shall be processed only for the specific purpose for which it was collected and shall not be used for any other purpose without obtaining your renewed and prior consent. You shall have the right to withdraw your consent at any time, without affecting the lawfulness of any processing carried out prior to the withdrawal.

We may collect information and data about the user in the course of our interactions with them, and we will only use the user's personal information and data in accordance with applicable data protection laws. We may obtain this information and data from a variety of sources, including: 1. Directly from the user (e.g., when accessing or using the platforms or when submitting an inquiry about our platforms or services or when communicating via WhatsApp with us or with agents and brokers through our platforms to inquire about a property, or sending emails or contacting our customer service team, or providing us with their personal information in another way); or from real estate developers, brokers, advertising networks, analytics providers, and search information providers. 2. Information Collected Automatically: When using the Platform, we may automatically collect certain technical and logistical data, such as IP address, device and browser type, geolocation data, browsing and usage logs, and cookies. This data is used to improve service performance and ensure the security of the Platform. 3. Information from Authorized External Sources: We may obtain user data from reliable and authorized sources, such as competent governmental authorities, official databases, licensing verification platforms, or our service partners, for the purpose of verifying the user’s identity, the accuracy of the provided data, or compliance with applicable laws and regulations. 4. User-Generated Content: Any data published or uploaded through the user's account — including property listings, documents, media files, or any other content — shall be considered part of the information we collect and process pursuant to this Privacy Policy.

This Website uses cookies and similar technologies to enhance the user experience, facilitate use of the Platform, analyze service performance, and deliver personalized content. By using the Website, you consent to our use of cookies as described in this Policy, unless you disable them through your browser or device settings. 1. What Are Cookies: Cookies refer to small text files that are stored on the user’s device when visiting the Website. These files store certain session-related or device-specific information, as well as usage preferences. 2. Types of Cookies We Use: Strictly Necessary Cookies: These are essential to enable core functionalities of the Website such as secure login, navigation, and saving user preferences. The Website cannot function properly without them. • Performance and Analytics Cookies: These cookies collect statistical data on how the Website is used, including pages visited and time spent on the Platform, which help us improve our services and content. • Customization Cookies: These cookies remember your preferences such as language, region, and personalize your browsing experience accordingly. • Third-Party Cookies: Some cookies may be placed by third-party service providers offering analytics, advertising, or technical integrations on the Website. 3. Managing Cookies: You have the option to accept or reject some or all cookies. You may adjust your browser settings to block or delete cookies; however, doing so may negatively affect certain features or prevent access to parts of the Website. 4. Amendments to This Policy: We reserve the right to modify or update this Cookies Policy at any time. Any changes will be posted on this page with an updated "Last Reviewed" date. Your continued use of the Website following any changes constitutes your acceptance of the updated policy. 5. Contact: For any inquiries regarding this Cookies Policy, please contact us using the information provided in the “Contact Us” section of the Website.

We may use or process the user's personal information and data for the following purposes: 1. To provide any services requested by the user, particularly to maintain internal records, as well as to improve our products, services, and platforms. If the user contacts us via the website, social media, or email through the contact details listed on the website or our call centers, we may retain a record of such communication to improve our services and process any specific requests or complaints. 2. To contact the user (via communication platforms such as WhatsApp, SMS, phone, and email) if the user has requested or purchased or participated in any topic on the platform, particularly to respond to any inquiries, requests, or comments they may have and to facilitate communication between the user and our agents and brokers when inquiring about properties on our platform. 3. To assist any third parties in providing services to the user, for example: developers, agents, and brokers. This information may be collected when sending emails, surveys, or other communications, as well as from any other sources outlined in this Privacy Policy, and to contact the user for market research purposes. 4. To improve the services we provide to the user and to evaluate the performance and responsiveness of our staff and real estate brokers providing services to them (for example, when inquiring about properties via our platforms and communicating with agents through us), and to provide the user with information and data about new opportunities, promotions, alerts, special offers, and other information and data that we believe may be relevant to them. 5. To personalize or enhance the user experience on our platforms and services, particularly by displaying advertisements and direct communications based on their activity on our platforms; to improve our platforms by determining the technical design specifications of the website, assessing system performance and potential issues, tracking activity on the website and mobile applications, generating reports, evaluating trends, and monitoring how the platforms are used. 6. To measure or understand the effectiveness of the ads we provide to the user and others, to deliver relevant advertisements to them, and to provide suggestions and recommendations to them and other users of our website regarding goods and services that may interest them based on their activity on our website or third-party websites; and to comply with legal obligations.

We use the user's personal information and data based on the following legal grounds (as permitted by applicable data protection laws): The collection of information and data is necessary to perform the contract with the user or to take steps at their request before entering into a contract, or based on the user's consent to such information and data; to serve our legitimate interests — using the user’s personal data helps us operate and improve and reduce disruptions to the platforms and services we provide to them. Our legitimate interests also include sending information and data to the user about services we believe will be of interest to them, and compliance with legal and regulatory obligations.

We undertake not to disclose or transfer your personal data except for the purposes set out in this policy, or unless notified to you at the time of collection of your personal information: 1. To specific real estate brokers, brokerage companies, agents, developers, or other service providers we work with when the user requests this or as part of their use of the platforms. For example, if a user inquiries about a property, our platform transfers their personal information and data to the agents responsible for the sale or rental of that property; to business partners, suppliers, and subcontractors to fulfill any contract we enter into with them or with the user; and to competent authorities if we are legally required to comply with a data request. 2. To our third-party service providers. We work with and support service providers around the world. Personal information and data are only provided to these parties when necessary to fulfill the services they provide to us, such as software, system, and platform support, direct marketing, social media, communication services, cloud hosting, advertising, data analytics, order fulfillment, and delivery. Our third-party service providers are not permitted to share or use your personal data for any purpose other than providing services to us. 3. If we sell or buy any business or assets, we may disclose your personal information and data to the prospective buyer or seller of such business or assets, and their professional advisors. If any third party acquires our assets or the assets of any of our affiliates, the personal information and data we or our affiliates hold about our clients may be transferred as part of those assets. We may also disclose your data to obtain professional advice when necessary. 4. If we are required to disclose or share your personal information and data to comply with any legal obligation, or to enforce or apply our terms of use or other agreements, or to protect our rights, property, or safety, or those of our affiliates, clients, or others — including exchanging data with companies and organizations for fraud protection and credit risk reduction purposes. 5. We may be required, pursuant to applicable laws and regulations, to disclose certain user data to competent governmental authorities, including financial or tax authorities, in compliance with regulatory obligations related to anti-money laundering, tax compliance, or legal and supervisory investigations. 6. We may share certain data with third-party payment processing service providers we engage with, for the purpose of facilitating payment or withdrawal transactions through the Platform, to the extent necessary to execute the transaction and ensure compliance with applicable security and regulatory standards. Such data may include, but is not limited to, the user’s name, account information, transaction amounts, and technical details necessary for payment verification.

We may transfer Users’ information and data to entities or service providers located in countries different from the User’s country of residence, in order to provide and operate the Platform’s services efficiently. Please note that such countries may not provide the same level of data protection as the laws applicable in the User’s country. By using the Platform, you acknowledge and consent to the transfer and processing of your personal data in such countries, with appropriate security measures taken to protect your data in accordance with applicable legal and regulatory standards.

1. Maintaining the security of your personal data and preventing unauthorized access is a top priority. We commit to taking all reasonable steps to protect your personal data from unauthorized access, use, modification, disclosure, or destruction. 2. In addition, we limit access to your personal data to employees, agents, contractors, and third parties who need to know such information and are bound by confidentiality obligations. 3. If we provide you with a password or if you create one as part of accessing parts of our platforms, you are responsible for keeping it confidential and not sharing it with anyone. 4. Transmitting data over the Internet is not completely secure. Although we strive to protect your personal data, we cannot guarantee the security of your data transmitted to our platforms. Any transmission is at your own risk. Once we receive your data, we implement strict procedures and security features to prevent unauthorized access.

1. The duration for which we retain your personal data varies. We do not usually retain it unless necessary to respond to inquiries or complaints, improve our services, or comply with legal obligations. 2. To determine appropriate retention periods, we consider the volume, nature, and sensitivity of the personal data, the risk of harm from unauthorized use or disclosure, the purposes for which we process it, and whether these can be achieved by other means, as well as applicable legal requirements.

Regarding your personal data under our direct control, and subject to certain conditions and applicable data protection laws, you have the right to: 1. Access your data and request a copy of the personal data we process about you; correct or update your data if inaccurate or incomplete; delete your data if no longer necessary for the purpose for which it was collected; object to the use of your data or its processing for our legitimate interests or direct marketing. 2. Withdraw your consent at any time for a specific purpose for which you previously gave consent. Please note that in certain circumstances we may legally continue processing your data without your consent if we rely on another legal basis. 3. To exercise any of the above rights, please contact, subject to any legal obligations and/or requirements and/or exemptions. We will aim to respond as soon as possible unless we need more information. We may also ask you to verify your identity.

To unsubscribe from email marketing, you can use the unsubscribe link in the email message received from us or contact us directly. For other marketing preferences, you can contact us through any relevant communication link. Information on controlling cookies can be found in our Cookie Policy.

Our services may include links to third-party applications, services, tools, or websites that we do not control. These may include, for example, Facebook, LinkedIn, Twitter, or third-party applications like voice and reading software. The privacy practices of these third parties are governed by their own policies. We are not responsible for the security or privacy of any data collected by those third parties. You should review the applicable privacy policies of those services. This Privacy Policy does not cover the information you provide to third-party companies.

We may update this Privacy Policy from time to time as necessary. If any material changes occur, we will notify you as required by applicable law, including by email or platform notification. Any changes take effect immediately upon notification.

For any inquiries, requests, or comments regarding this Privacy Policy or to exercise any of your rights related to personal data, please contact us through the following means: - Email: info@pportal.net We will endeavor to respond to your inquiries and process your requests as promptly as possible, subject to any applicable legal or regulatory obligations. We may also request additional information or proof of identity to ensure the security and confidentiality of the data.