PRIVACY NOTICE – Eleva Capital Group

Version: 2025. V2
Cumbres Towers Realty, S. de R.L. de C.V., trading as “Eleva Capital Group,” with registered office at Boulevard Cumbres, Block 109, Lot 8, Subblock 310, Cancún, Quintana Roo, ZIP code 77560; is committed to protecting your personal data and assumes responsibility for its use, handling, and confidentiality in accordance with the provisions of the Federal Law on Protection of Personal Data Held by Private Parties. In order to inform you of the main characteristics of the processing to which your personal data will be subjected, we hereby issue this Privacy Notice. [cite: 90, 91, 139, 140].

1. Personal data we collect

To fulfill the purposes outlined in this Privacy Notice, we collect data through our offline channels, website, social media, third-party landing pages, WhatsApp, and broker registrations. These data mainly include:

Identification, contact, and location data: Name, phone number, email address, and address.
Financial and asset data: Approximate income and tax information for purchase or investment processes.
Commercial profiling: Interests in apartments, offices, or commercial spaces, and source of contact.
For Brokers: Sales track record and commission payment information.

2. Purposes of data processing

The collected data will be used for the following necessary purposes:

Verify, confirm, and validate your identity.
Evaluate your application for contracting and/or purchasing our products and services.
Commercial profiling: Analyze your interests to offer specific units (residential or commercial).
Create and update your file and databases for the operation of contracted products and services.
Contact you through different communication channels to manage the relationship derived from contracted services.
Carry out collection procedures.
Issue tax receipts.
Address and follow up on inquiries, clarifications, and complaints.
Develop and monitor risk profiles and models.
Manage sales, pre-sales, closing, and post-sale processes.
Formalize contracts and comply with legal obligations.

Secondary Purposes:

Send you advertising, promotional, and prospecting information according to your profile.
Offer products and services from companies and/or brands belonging to Eleva Capital Group.
Send invitations to programs, activities, campaigns, contests, tests, and events organized by Eleva Capital Group.
Conduct surveys or consultations regarding our products and services.
Refer third-party products and/or services with which Eleva Capital Group has agreements.
Analyze your commercial profile to understand preferences, consumption, financial capacity, and solvency.

If you do not wish your data to be used for these secondary purposes, you may request this by emailing: info@elevacap.com. If no refusal is received within 5 business days after your data is collected, consent will be assumed.

Eleva Capital Group may also process personal data of third parties (such as beneficiaries or representatives) when provided, to fulfill contractual obligations. In such cases, you confirm that you have informed such third parties and obtained their prior consent.

3. Transfer of personal data

Eleva Capital Group may transfer your personal data in the following cases:

Companies belonging to the Eleva Capital Group, if necessary to fulfill the purposes set forth in this Privacy Notice. Please note that these companies operate under privacy policies that comply with the applicable regulations.
Third parties with whom we have entered into contracts for the marketing of products and/or services, for the benefit and/or interest of our customers.
Third parties with whom we have a business and/or collaborative relationship for the indirect collection and validation of data for profiling.
Third parties with whom we have entered into contracts for the benefit and/or interest of customers, to fulfill the legal relationship established between the parties.
Competent authorities in cases provided for by law.

If necessary, Eleva Capital Group will request your consent to transfer your data and will provide you with this Privacy Notice so that your personal data may be processed in accordance with its terms and in compliance with the Federal Law on the Protection of Personal Data Held by Private Parties.

Means and procedure for exercising ARCO rights and/or revoking consent for the processing of personal data:

You or your legal representative may exercise any of the rights of access, rectification, cancellation, or objection, as well as revoke your consent for the processing of your personal data by sending an email to the following address: info@elevacap.com.

Your request must be made through the ARCO Rights Request Form (hereinafter, the “Request”). In order for Eleva Capital Group to process your Request, you must properly verify your identity; therefore, your Request must contain and be accompanied by the following:

I. The full name of the data subject and their address or any other means for receiving notifications;
II. Documents proving the identity of the data subject or, where applicable, the legal status and identity of their representative;
III. A clear and precise description of the personal data regarding which the data subject seeks to exercise any of the ARCO rights;
IV. A description of the ARCO right the data subject intends to exercise, or the specific request made by the data subject; and
V. Any other information or document that facilitates the identification of the personal data.

Options and methods for limiting the use or disclosure of personal data

You may limit the use or disclosure of your personal data by sending an email to the following address: info@elevacap.com. The requirements for verifying your identity, as well as the procedure for addressing your request, will be governed by the same criteria outlined in the previous section. If your request is deemed valid, Eleva Capital Group will add you to its opt-out list.

5. Use of Cookies, Web Beacons, and Other Technologies

Please be advised that Eleva Capital Group uses cookies and/or web beacons on its website and in its applications. These mechanisms automatically and simultaneously collect data to monitor your behavior as a user of our services.

These technologies allow us to collect information about your browser type, operating system, visits to other websites, or to identify you as a user in order to improve the efficiency of our technological tools, including your experience when browsing these sites or using our applications.

If you wish, you can disable or adjust the use of these technologies by following the procedures for the web browser you use to access our websites and/or the mobile device through which you access our services. For more details, please refer to our Cookie Policy published on our website.

6. Changes to the Privacy Notice

Eleva Capital Group reserves the right, at its sole discretion, to change, modify, add, or remove portions of this Privacy Notice at any time. In such cases, Eleva Capital Group will always keep its Comprehensive Privacy Notice available on the website https://elevacap.com. We recommend that you visit this page periodically to stay informed of any changes to this notice.

Registration on our website and/or applications implies customers’ full and unreserved consent to the use of their personal data in accordance with this Privacy Notice.

By providing any type of information, including your personal data, you expressly: (i) Accept the terms contained in this Privacy Notice; (ii) Agree and grant your consent for the information you provide to be stored, used, and generally processed for the purposes set forth in this Privacy Notice, including for commercial and promotional purposes; (c) You grant Eleva Capital Group your authorization to obtain, compile, store, share, communicate, transmit, and use such information in any manner or form, in accordance with the terms set forth herein and applicable laws.

8. Contact

Data Protection Officer: info@elevacap.com | Phone: +52 (998) 116 0262 [cite: 135, 184].

Last updated: May 2026

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