Introduction

This Privacy Policy explains how Digitalfrontierar S.A.S. ("Digitalfrontierar", "we", "us") collects, uses and protects personal data of visitors and clients of digitalfrontierar.com. We follow the Argentine Personal Data Protection Act 25.326 and the guidelines published by the Agencia de Acceso a la Información Pública (AAIP) during 2025 regarding profiling, automated decisions and international data transfers.

Scope of this policy

This policy applies to any interaction with our public website, investor onboarding forms, contact channels and marketing communications. It does not cover third-party websites that we may link to from time to time; those services remain governed by their own privacy notices.

Data we collect

• Identification data (full name, national ID or passport number) required by AML/KYC regulations before you can participate in any project.
• Contact data (email, phone number, postal address) provided through forms, calls or our investor relations desk.
• Financial and investor profile data (declared risk tolerance, source of funds, banking details) used to comply with CNV rules on collective financing.
• Technical data (device type, browser, IP address, approximate location, pages visited) collected via cookies and consent-based analytics.

Purposes of processing

We process your data to: (i) provide and improve the platform; (ii) comply with CNV, UIF and AAIP obligations; (iii) evaluate investor suitability for specific projects; (iv) send transactional and informational messages; and (v) prevent fraud, abuse or misuse of the service. We do not sell your personal data to third parties.

Legal basis

Depending on the case, we rely on: your prior informed consent, the performance of a contract, our legitimate interest to keep the service secure, and legal obligations under Argentine capital-markets, tax and anti-money-laundering rules.

Sharing and international transfers

We share limited data with regulated third parties: escrow banks operating in Argentina, KYC providers, accountants, external auditors, cloud infrastructure providers and, where necessary, judicial or administrative authorities. When data is transferred outside Argentina, we rely on adequacy decisions or contractual safeguards approved by the AAIP.

Retention

Investor-onboarding data is kept for ten years after the end of the relationship, in line with UIF requirements. Marketing data is kept until you unsubscribe or three years after the last interaction, whichever occurs first.

Your rights

You may exercise your rights of access, rectification, update, deletion and opposition regarding your personal data by writing to privacy@digitalfrontierar.com. You also have the right to file a claim with the AAIP if you consider that your rights are not being respected.

Security

We apply organisational and technical measures aligned with the ISO/IEC 27001:2022 framework: encryption in transit and at rest, role-based access controls, continuous monitoring, quarterly penetration tests and mandatory training for our team.

Minors

Our service is not aimed at minors. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with data, please contact us so we can delete it.

Changes to this policy

We may update this Privacy Policy to reflect regulatory, operational or technical changes. Meaningful updates will be announced on this page and, where appropriate, communicated by email.

Contact

Data controller: Digitalfrontierar S.A.S., Av. Corrientes 4568, Piso 12, Ciudad Autónoma de Buenos Aires. Data protection contact: privacy@digitalfrontierar.com.