Privacy Policy

1. Introduction & Controller

This Privacy Policy (the «Policy») describes how eendLabs, LLC, a limited liability company organized under the laws of the State of Delaware, United States of America, operator of the Velnu platform («Velnu», «we» or «our»), collects, uses, shares and protects the personal data processed through the Service. Velnu is a property management platform that assists property managers, owners and tenants in managing real-estate portfolios.

The data controller for the data described in this Policy iseendLabs, LLC. For any inquiry, request or complaint relating to your personal data, you may contact us at [email protected]. We encourage you to read this Policy in full; by using the Service, you acknowledge that you have been informed of the practices described herein.

2. Our Roles (controller / processor)

Depending on the type of data and the purpose of the processing, Velnu may act under two distinct roles. Understanding this distinction is important in order to understand which obligations apply to us and against whom you may exercise your rights.

Velnu as controller. With respect to account and usage data—that is, the data you provide to us when you register and the data we generate about your interaction with the platform— Velnu acts as the data controller and determines the purposes and means of the processing in accordance with this Policy.
Velnu as processor. With respect to tenant data that the property manager or owner uploads on their behalf —such as leases, identification documents, payment records and tenant documents— Velnu acts as a data processor. In this role, we process such data following the instructions of the property manager or owner, who is the controller of that data. Tenant requests regarding this data should be directed, in the first instance, to the relevant property manager or owner; however, we may assist in handling them.

3. Information We Collect

We collect the following categories of information:

Identifying personal data: name, email address and phone number of property managers, owners and tenants.
Payment data: information necessary to process rent and other payments, collected and processed through external payment processors. Velnu does not store full payment card details.
Tenant records and documents: lease agreements, receipts, account statements, identification documents, guarantor documents and other records uploaded by the property manager or owner.
Communications: the content and metadata of communications sent or received through the platform, including messages via email andWhatsApp.
Usage and technical data: information about how you interact with the Service, such as features used, access dates and times, IP address, device type, browser, identifiers and activity logs.

4. How We Use Information

We use the information collected for the following purposes:

To provide, operate, maintain and improve the Service and its features.
To create and manage accounts, authenticate users and ensure access security.
To process and reconcile payments, and generate invoices, receipts, account statements and late-fee charges.
To facilitate communications between the parties and send operational notifications (for example, payment reminders) via email and WhatsApp.
To offer the conversational assistant and automated agent features powered by artificial intelligence, in accordance with Section 7.
To comply with legal, accounting and tax obligations, and to respond to requests from competent authorities.
To prevent fraud, abuse and unauthorized use, and to protect the integrity of the platform.
To analyze use of the Service for statistical and product-improvement purposes.

5. Legal Bases

The processing of your personal data is based on the legal bases that apply according to the relevant jurisdiction.

Dominican Republic — Law No. 172-13. For data of users and tenants located in the Dominican Republic, the processing relies onLaw No. 172-13 on the Comprehensive Protection of Personal Data, on the basis of one or more of the following grounds:

Consent of the data subject.
Performance of a contract to which the data subject is a party or to manage the management relationship.
Compliance with a legal obligation to which we are subject.
Legitimate interest in operating, securing and improving the Service, where the rights of the data subject do not prevail.

United States. For data subject to United States law, the processing is based on the performance of the contract with you and/or on yourconsent, as applicable.

We do not sell your personal data. We share information only with the service providers (subprocessors) that are necessary to operate the Service, which process the data on our behalf and under confidentiality and security obligations. Our subprocessors are:

Anthropic — artificial intelligence processing (Claude model).
Cardnet, Stripe and Azul — payment processing.
Resend — email delivery.
Meta / WhatsApp — messaging and communications.
Railway — infrastructure hosting and data storage.

Each of these subprocessors processes data in accordance with its own policies and the agreements entered into with Velnu. In addition to the above, we may disclose information when required by law, a court order or a request from a competent authority, or when necessary to protect our rights, prevent fraud or ensure the safety of individuals and of the platform.

7. AI Processing

The Service includes a conversational assistant and automated agents powered by artificial intelligence. To generate responses, perform management tasks and produce analyses, these features send data —including the content of your messages and the account and tenant information relevant to the request— to Anthropic (Claude), which processes it as a subprocessor on Velnu's behalf.

In accordance with the processor's commercial terms, the user and account data sent to Anthropic in connection with the Service is not used to train third-party artificial intelligence models. Such data is processed solely for the purpose of providing you with the requested functionality.

The artificial intelligence features are assistance tools. The results they generate may contain inaccuracies, so we recommend that you verify relevant information before making financial, legal or business decisions.

8. Data Retention

We retain personal data for as long as necessary to fulfill the purposes described in this Policy, while your account remains active and, thereafter, for the period required to meet legal, accounting and tax obligations, resolve disputes and enforce our agreements.

When we act as a processor of tenant data, retention periods are determined by the responsible property manager or owner. Once data is no longer necessary for the applicable purposes, we delete or anonymize it, unless the law requires its retention.

9. Data Security

We apply reasonable technical and organizational measures to protect personal data against unauthorized access, loss, alteration or improper disclosure. These include encryption in transit, access controls, authentication, activity logs and the selection of providers that maintain industry-recognized security standards.

Nevertheless, no system is completely infallible. You are also responsible for safeguarding your access credentials and for notifying us immediately, at the email indicated in the Contact section, of any unauthorized use or security incident of which you become aware.

10. International Data Transfers

Velnu operates from the United States and relies on infrastructure and service providers located primarily in the United States. As a result, the data of users and tenants located in theDominican Republic may be transferred to and processed in the United States and in other jurisdictions where our subprocessors operate.

When we carry out international transfers of data, we adopt the safeguards required by applicable law, including Law No. 172-13 of the Dominican Republic, and we seek to ensure that recipients maintain an adequate level of protection through contractual confidentiality and security obligations.

11. Your Rights

You have rights over your personal data that vary according to the applicable jurisdiction.

Dominican Republic (Law No. 172-13). You have the right to:

Access to your personal data that we process.
Rectification of inaccurate or incomplete data.
Cancellation (deletion) of data where appropriate.
Opposition to the processing of your data on legitimate grounds.

United States. Under applicable state law, you may have the right to:

Access to the personal information we hold about you.
Deletion of your personal information.
Opt-out of the sale or sharing of your personal information.

To exercise any of these rights, write to us at[email protected]. We will handle your request within the timeframes established by applicable law and may ask you for reasonable information to verify your identity. If the data in question is tenant data processed on behalf of a property manager or owner, we may refer or coordinate your request with the relevant controller.

12. Children's Privacy

The Service is intended for adults and is not directed at minors. We do not intentionally collect personal data from minors. If we become aware that we have collected data from a minor without the corresponding authorization, we will take reasonable steps to delete it. If you believe that a minor has provided us with personal data, contact us at [email protected].

13. Cookies & Similar Technologies

We use cookies and similar technologies (such as session identifiers and local storage) that are necessary to authenticate users, keep the session signed in, remember your preferences and ensure the security and proper functioning of the Service.

We may also use measurement technologies to understand, on an aggregate basis, how the platform is used and to improve it. You can configure your browser to reject or delete cookies; however, disabling necessary cookies may prevent the use of certain features of the Service.

14. Changes to this Policy

We may update this Policy from time to time to reflect changes in the Service, in applicable law or in our processing practices. When the changes are material, we will notify you by a reasonable means, such as a notice on the platform or by email, before they take effect. The «Last updated» date indicated on this page reflects the current version. Continued use of the Service after the changes take effect constitutes your acknowledgment of the amended Policy.

15. Contact

If you have questions, comments or complaints about this Policy or about the processing of your personal data, you may write to us at [email protected]. The data controller is eendLabs, LLC, a company organized under the laws of the State of Delaware, United States of America, operator of Velnu.