PRIVACY POLICY

Last updated: January 5th 2026

The website ("Site" or "Platform") for PB Labs Co., Ltd. ("Propbase", "We", "Our", "Us" or "Company") was created to provide an intermediary technology platform for certain other persons to independently review and invest in private placement real estate offerings (the "Services").

The privacy of our Site visitors ("you," "your," or "user") is important to us. In order to protect your personal information, we have implemented the following Privacy Policy with provisions that apply to the collection of data by Propbase, its subsidiaries, and its affiliates.

Our Privacy Policy discloses the type and nature of information we collect and how we use it, as well as the choices you can make about the way your information is collected and used. We also explain how any requests for personal or personally identifiable information will be used. By exploring and using Propbase's Site and/or Services, and by submitting information to Propbase, you signify acceptance of the terms of our Privacy Policy.

If you have questions or concerns regarding this statement, you should first contact us at : support@propbase.app

1. UPDATES AND CHANGES TO THE PRIVACY POLICY

In the event of a change in this policy, a revised Privacy Policy will be posted to our Website, and the "Updated" date will be changed. If the revised Privacy Policy contains a material change to how we collect or use personal information, notice of the change will be emailed to you or posted on the Website's home page.

Please revisit this page to familiarize yourself with changes to the Privacy Policy. You agree to accept posting of a revised Privacy Policy as described herein as actual notice to you of such revised Privacy Policy. Your continued use of the Services after such posting constitutes acceptance of the collection and use of your information as described in the then-current Privacy Policy.

2. INFORMATION WE COLLECT

We are required by law, regulation, or securities reasons to ask for certain personal and financial information in order to provide our Services to you. Propbase makes commercially reasonable efforts to maintain the confidentiality, integrity, and security of our client's personal information.

You may choose to provide additional information during subsequent visits to the Site, but keep in mind that some of this information will be required if you wish to partake in the Services.

Types of Information We Collect
  • Contact Information and Personal Details: Your name, residential, business and postal addresses, telephone number, email address, and family details such as the name of your spouse, partner, or children.
  • Profile Information: The username and password you establish with the Services.
  • Demographic Details: Date of birth, country of citizenship and/or country of residence, marital status.
  • Government-Issued Identification: Such as a national identification number (e.g., a Social Security Number, tax identification number, or passport number), state or local identification number (e.g., a Driver's License or other government-issued identification number), a copy of your government-issued identification card and related government-issued photographs.
  • Investment Experience and Preferences: Information about your investment objectives, investment experience, liquidity needs, and risk tolerance.
  • Financial Account and Payment Information: Your bank accounts you may use to source your investment funds, other related payment information, and digital asset wallet addresses.
  • Feedback and Correspondence: Information you provide when you request information from us, receive customer support, or otherwise correspond with us, including by interacting with our pages on social networking online sites or services.
  • Marketing Information: Your preferences for receiving marketing communications and details about how you engage with our marketing communications.
  • Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
  • Other Information You Choose to Provide.
Access Logs

When visiting our website, we also store every instance of access in a log file and therefore, the following Data are stored in this process:

  • Computer or mobile device information
  • Website from which our domain is accessed and website usage information
  • Operating system of your computer
  • Country from which our website is accessed
  • Name of your internet provider
  • Name and URL of the Data accessed
  • Date and time of access
  • IP address of the accessing computer

3. COMMITMENT TO USER PRIVACY

Keeping client information secure, and using it only as our Users want us to, are matters of principle for all of us at Propbase. With this in mind, here is our commitment to each and every User:

  • Except as you may otherwise expressly approve, we will limit the collection and use of client and user information to what we believe would be useful to service your accounts, administer our business, or to tell you about our Services.
  • We will restrict employee access to client and user information to those who need to know in order to provide Services to you.
  • We will educate our employees according to our internal policies to reinforce the importance of confidentiality and client and user privacy.
  • We will maintain commercially reasonable and customary security standards and procedures to protect information about you.
  • We will respond quickly to your request to correct inaccurate information.

Propbase will also gather the names and email addresses of users who contact us through the Site with questions about our company or lending platform. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested to do so, as in the case of job applicants who submit resumes.

Any data including, but not limited to, your name, address, telephone number, e-mail address, and biometric information submitted to Propbase during the identity verification process is handled securely by our third-party, specialist identity verification provider. Propbase retains an ID and status of the process for our information and does NOT store, or use, any of the personally identifiable information (PII) submitted as part of that process.

4. HOW AND WHY WE GATHER INFORMATION

When you register for an account for the Services or at any later time, we collect certain personal information from you to open an account, transact business, communicate with you, verify your identity and fulfill legal and regulatory requirements. We call this your "Profile." From time to time, we may request additional information (e.g., through surveys) to help us further assess your needs and preferences.

If you choose to provide such information, during registration or otherwise, you are giving Propbase the permission to use and store it consistent with this Privacy Policy. We may also obtain your personal information from your transactions with us or other Users through the Services, or from third parties such as credit reporting agencies. If we combine or associate information from other sources with personal information that you provide directly to us through or in connection with the Services, we will treat the combined information as personal information in accordance with this Privacy Policy.

5. COOKIES

When you visit the Website, whether or not you register for an account, we may send one or more cookies.

  • Cookies: Small text files containing a string of alphanumeric characters that may be placed on your web browser. Cookies make it easier for you to navigate our Website by, among other things, "remembering" your identity so that you do not have to input your password multiple times as you navigate between web pages on the Website and/or as you access the Services. This use of cookies for authentication (i.e., verifying that you are who you say you are) is an essential component of site security. You can set your web browser to inform you when cookies are set or to prevent cookies from being set.
  • Web Beacon: Typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site or in an email which allows the website to record the simple actions of the user opening the page that contains the beacon.
  • Server Logs: Can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.

Please note that if you decline to use cookies, you may experience reduced functionality or slower site response times. Declining to use our authentication-related cookies may prevent you from using the Website altogether.

We or our service providers may also collect web surfing data related to your use of the Services (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences). This may be accomplished by using cookies, web beacons, page tags, or similar tools. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system, and the dates and times that you visit the Website. Web surfing data and similar information may be used for administrative purposes; to assess the usage, value, and performance of our online products and services; and to improve your experience with the Services.

6. SHARING YOUR INFORMATION

We may allow you to share certain information with other Users of the Services. You can share your profile with all other Users, or only with such other Users as are designated by you. You are not required to share your profile or any other information with other Users. If you do share your profile, anyone you designate will be able to see what companies you are following and investing in.

If you indicate an interest in making an investment through the Services, such as indicating an interest to buy equity or make a loan in a particular private real estate company, we will notify the party or parties offering the investment (the "Issuer") of your interest and may notify other Users with whom you have chosen to share information. By indicating an interest in an investment and/or sharing your Profile with other Users, you consent to this disclosure of your information. We may also collect and store information, which could include Non-Personally Identifiable Information orPersonally Identifiable Information, locally on your computer or device using mechanisms such as browser web storage or application data caches.

7. SOCIAL MEDIA SERVICES

You can log in to the Website using social media services such as Google or Facebook. These services will authenticate your identity and provide you the option to share certain personal information with us, such as your name and email address, to pre-populate our sign-up form.

Our Website may also include social sharing features for common social networks. These features are interactive mini-programs and may collect your IP address and the page you are visiting on our site. They may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing them.

8. NOTIFICATIONS AND COMMUNICATIONS

Propbase will send you email notifications from time to time. Some notifications are required elements of your transactions on our platform, such as confirmations of particular actions you have taken. These mandatory notices are sent typically to notify you of a change in status. For example, you will receive a notice when you are confirmed as an investor.

We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that another person cannot make a change to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or Site policies. Generally, you may not opt out of such service-related emails.

When you register as an investor, you will receive emails that confirm specific actions you requested. These will include emails to which you must respond to complete your registration and notifications confirming your registration. Thereafter, you will receive emails when a new investment opportunity is available on our platform, as well as updates concerning the progress of the funding of such investment and/or other relevant information. If you make an investment through the Site, Propbase will also send you confirmations of the investment as well as occasional updates as to the status of that investment and the timing of distributions relating to that investment.

When you register as an investor and opt-in to Propbase's SMS Communications program, you are consenting to receive text messages sent by an automatic telephone dialing system and acknowledge that data usage charges may apply by your cell phone company. You may receive text messages regarding system notifications, investment opportunity updates, and special offers and promotions, and can manage your opt-in status in your user profile.

We may also send you responses to emails you send us, if appropriate. From time to time, we will also send user surveys, requests for user feedback regarding user experience and Site operations, or marketing offers from us or from us on behalf of our marketing partners. Completing these surveys, answering requests for feedback, or accepting any offer is strictly voluntary.

Propbase will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go to the website directly. You might also make it a habit to check the URL of a website to be sure that it begins with the correct domain. In the case of Propbase, you should always ensure the URL begins with https://propbase.app or https://www.propbase.app

9. OPT-OUT POLICY

We may at times send you email communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional emails from us, you may unsubscribe at any time. Please note that opt-out requests may take up to twenty-four (24) hours to process.

Please also note that at times we may need to send you email communications that are transactional in nature, such as service or termination announcements or payment confirmations. You will not be able to opt out of these communications.

10. SECURITY NOTIFICATIONS

If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Site in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

11. WHERE YOU CAN VIEW AND CORRECT YOUR INFORMATION

We urge you to review your information regularly to ensure that it is correct and complete. If you believe that any of your information is incorrect, or if you have any questions regarding this Privacy Policy, please contact us at : support@propbase.app

12. DATA RETENTION POLICY

We will retain your data for as long as your account is active, or as needed to provide you with the Services. This includes information required to fulfill legal and regulatory requirements. Here are some examples:

  • Account information will be retained as long as your account remains active.
  • Transaction information will be retained for a period of [X] years in accordance with financial regulations.
  • We may also retain anonymized data for research or statistical purposes.
  • If you deactivate your account, we will remove your personal information from our active databases. However, some residual information may remain in backups or archives for a limited period of time.

You can request to have your information deleted by contacting us at : support@propbase.app . Please note that there may be exceptions to your deletion request, such as where information is necessary to comply with legal or regulatory obligations.

13. DATA SECURITY

We take the security of your data very seriously and employ a number of measures to protect it, including:

  • Encryption of data at rest and in transit
  • Regular security audits and penetration testing
  • Access controls to restrict access to your data
  • Data breach response procedures

We are committed to protecting your information and will continue to invest in security measures to mitigate risks. However, no security system is perfect, and we cannot guarantee the security of your data.

14. THIRD-PARTY SHARING

We may share your data with third-party service providers who help us operate and improve the Services. These service providers may be located in different countries around the world.

We will only share your data with third-party service providers who have agreed to comply with strict data privacy and security requirements. We will also enter into contracts with these service providers that limit their use of your data for the purpose of providing services to Propbase.

We may also share your data with third parties in the following circumstances:

  • To comply with a legal or regulatory requirement
  • To prevent fraud or other illegal activities
  • In connection with a merger, acquisition, or other business transaction

We will always notify you if we intend to share your data with a third party for a purpose other than those listed above. You will have the opportunity to opt out of such sharing.

15. CUSTOMER ELIGIBILITY

Propbase is intended for users in certain approved jurisdictions. We do not actively solicit clients and our current user base is global, excluding the United States and other restricted regions. Our primary focus includes users in the European Union (EU), Southeast Asia, and the Middle East and North Africa (MENA) region.

Please note that using Propbase does not guarantee your eligibility to participate in any investment opportunities. Investment offerings may have their own specific eligibility requirements based on location, accreditation, or other factors.

16. INTERNATIONAL VISITORS

The Services may be accessed and/or used by Users located in approved jurisdictions in accordance with our Terms of Use and other policies and procedures posted on the Website. If you choose to use the Services from the European Union (EU) or other regions of the world with laws governing data collection and use that may differ from other laws, then please note that you are transferring your personal information outside of those regions to the jurisdictions of where Propbase resides and by providing your personal information on or through the Services you consent to that transfer.

17. GDPR COMPLIANCE

Propbase is committed to protecting the privacy of our users and complying with all applicable data protection laws, including the General Data Protection Regulation (GDPR).

Key Aspects of Our GDPR Compliance
  • Lawful Basis for Processing: We will only process your data based on a lawful basis as defined by the GDPR. This may include your consent, a contractual necessity, or a legitimate interest. We will always be transparent about the legal basis for processing your data.
  • Your Data Rights: You have a number of rights under the GDPR, including the right to access, rectify, erase, and restrict the processing of your data. You also have the right to data portability and to object to automated decision-making. You can find more information about your data rights on the website of the European Commission https://commission.europa.eu/law/law-topic/data-protection_en
  • Data Protection Officer: We have appointed a Data Protection Officer (DPO) who is responsible for overseeing our compliance with the GDPR. You can contact our DPO at [email protected] if you have any questions or concerns about your data privacy.

18. CHILDREN'S PRIVACY POLICY

The Propbase website is not intended for use by children, especially those under eighteen (18) years of age. No one under eighteen (18) years of age is allowed to use the website, provide any personal information, or receive our email distributions. We do not knowingly solicit or collect Personally Identifiable Information from children under eighteen years of age. If you believe that a minor has disclosed Personally Identifiable Information to Propbase, please report this to us at : support@propbase.app

19. CONTACT INFORMATION

Please contact Propbase with any questions or comments about this Privacy Policy, your personal information, or your choices with regards to our collection and use of your personal information, email at : support@propbase.app

If you believe that we have infringed your rights, we encourage you to contact us first so that we can try to resolve the issue informally.

For citizens of the European Union, please contact support@propbase.app for requests and inquiries regarding the data retained and managed by this portal and your rights to be forgotten related to the General Data Protection Regulation (GDPR).

20. FINAL PROVISIONS

This Privacy Policy is governed by the laws of the jurisdiction where Propbase is established. Any disputes arising out of or relating to this Privacy Policy shall be resolved in accordance with the dispute resolution provisions set forth in our Terms of Service.

By using the Propbase Site and Services, you agree to be bound by this Privacy Policy. If you do not agree with this Privacy Policy, please do not use our Site and Services.

For further assistance or to discuss our Privacy Policy, please reach out to us at :

PB Labs Co., Ltd. (Propbase) Email : support@propbase.app Website : Propbase