Privacy Policy

1. Who we are

REVABlox (referred to in this policy as “REVABlox,” “we,” “us,” or “our”) operates this website from Austin, Texas, United States. For the purposes of the European Union and United Kingdom General Data Protection Regulation (together, the “GDPR”), REVABlox is the controller of the personal information described below. If you have any question about this policy or about how your personal information is handled, you may contact us at hello@revablox.com.

2. Scope

This policy applies to personal information we collect through this website, including through the interest register form, through email correspondence with us, and automatically through your use of the site. It does not apply to any third-party website that we may link to, and it does not govern any future securities offering, which, if and when it occurs, will be accompanied by its own disclosures and privacy terms.

3. Information we collect

We collect only the limited categories of personal information described below.

Information you provide

• Email address. Provided when you join the interest register or contact us.
• Accredited-investor self-attestation. A yes or no indication of whether you are, or represent, an accredited investor. This is a self-declaration only and is not verification of status.
• Consent record. The fact that you agreed to this policy and to our Terms of Use when submitting the form.

Information collected automatically

• Internet protocol (IP) address. Collected by our hosting provider for security, abuse prevention, and to record consent.
• User agent. Basic technical information about your browser and device, such as the browser and operating system reported in your request.
• Consent timestamp. The date and time at which you submitted the interest register form.

We do not intentionally collect special categories of personal information such as health, biometric, or precise geolocation data, and we ask that you do not send such information to us.

4. How we use personal information

• To add you to our interest register and to contact you when investor verification and the first property become available.
• To respond to your inquiries and to communicate with you about the project.
• To maintain the security and integrity of the site, to prevent fraud and abuse, and to detect and stop automated submissions.
• To keep records of consent and to comply with our legal obligations.

We do not use your personal information for automated decision-making that produces legal or similarly significant effects, and we do not use it for advertising or profiling.

5. Legal bases for processing (GDPR)

Where the GDPR applies, we rely on the following legal bases to process your personal information:

• Consent. When you join the interest register, you consent to receive a notification from us and to the processing described in this policy. You may withdraw your consent at any time, as described in Section 9.
• Legitimate interests. We process limited technical information, such as IP address and user agent, to secure the site, prevent abuse, and maintain accurate records of consent. We balance these interests against your rights and freedoms.
• Legal obligation. We may process personal information where necessary to comply with a legal or regulatory obligation to which we are subject.

6. How we share information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We disclose personal information only to the service providers that operate this website on our behalf, and only as necessary for them to provide their services. These providers act as processors under our instructions:

• Supabase. Provides the database that stores interest register records.
• Resend. Provides transactional email delivery so that we can contact you.
• Vercel. Provides website hosting and related infrastructure and security logging.

We may also disclose personal information where required to do so by law, in response to a valid legal request, to enforce our Terms of Use, or to protect the rights, property, or safety of REVABlox, our users, or the public. If REVABlox is involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction, subject to the commitments made in this policy.

7. International transfers

REVABlox is based in the United States, and our service providers may process personal information in the United States and in other countries. Where we transfer personal information out of the European Economic Area, the United Kingdom, or Switzerland, we rely on an appropriate transfer mechanism, such as the European Commission Standard Contractual Clauses and the United Kingdom International Data Transfer Addendum, together with any supplementary measures that may be required. You may request more information about these safeguards by contacting us at hello@revablox.com.

8. Data retention

We retain interest register records for as long as your entry remains active, so that we can contact you when access opens, and thereafter for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. When you ask us to remove you, or when the information is no longer needed for the purposes described in this policy, we delete or de-identify it. Security and consent logs are retained for a limited period appropriate to their purpose and then deleted.

9. Your rights

Subject to applicable law, you have the following rights over your personal information:

• Access. To request confirmation of whether we process your personal information and to obtain a copy of it.
• Rectification. To have inaccurate personal information corrected and incomplete information completed.
• Erasure. To request deletion of your personal information in the circumstances allowed by law.
• Portability. To receive the personal information you provided to us in a structured, commonly used, machine-readable format, and to have it transmitted to another controller where technically feasible.
• Restriction. To request that we limit our processing of your personal information in certain circumstances.
• Objection. To object to our processing that is based on legitimate interests.
• Withdraw consent. To withdraw your consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, email us at hello@revablox.com. We will respond within the time required by applicable law. You also have the right to lodge a complaint with your local supervisory authority, although we ask that you contact us first so that we can try to resolve your concern.

10. California privacy rights

If you are a California resident, the California Consumer Privacy Act as amended by the California Privacy Rights Act (together, the “CCPA”) provides you with specific rights regarding your personal information. In the twelve months before the effective date of this policy, the categories of personal information we collect are identifiers (such as email address and IP address) and internet or other electronic network activity information (such as user agent). We collect this information for the business purposes described in Section 4, and we disclose it only to the service providers listed in Section 6.

Your California rights include:

• Right to know. To request the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of recipients.
• Right to delete. To request deletion of the personal information we have collected from you, subject to legal exceptions.
• Right to correct. To request correction of inaccurate personal information.
• Right to opt out of sale or sharing. To direct a business not to sell or share your personal information.
• Right to non-discrimination. To not receive discriminatory treatment for exercising any of these rights.

REVABlox does not sell your personal information, and REVABlox does not share your personal information for cross-context behavioral advertising. Because we do not sell or share personal information, there is no opt-out to submit for those activities. You may still exercise your other rights, and you can learn more in our Your Privacy Choices notice.

11. How to exercise your rights

To make any privacy request, email us at hello@revablox.com with enough detail for us to understand and respond to your request. We will take reasonable steps to verify your identity before acting, which may include confirming control of the email address associated with your interest register entry. An authorized agent may submit a request on your behalf where permitted by law, and we may ask the agent to provide proof of authorization.

12. Cookies

This website uses only strictly necessary cookies and does not use advertising or third-party tracking or analytics cookies. For details on the cookies that may be set and how to control them, please read our Cookie Policy.

13. Children

This website is not directed to individuals under the age of eighteen, and we do not knowingly collect personal information from anyone under eighteen. If you believe that a minor has provided us with personal information, please contact us so that we can delete it.

14. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the effective date shown at the top of this page, and, where required by law, we will provide additional notice. We encourage you to review this policy periodically.

15. Contact us

If you have questions, concerns, or requests regarding this policy or your personal information, contact us at hello@revablox.com or write to REVABlox, Austin, Texas, United States.