Privacy Policy

Effective Date: May 18, 2026

This Privacy Policy explains how Grupo Gap collects, uses, shares, and protects information when you use the GAP Investments website located at
https://gapinvestments.com/, contact us, submit inquiries, or otherwise communicate with us.

By using this website or communicating with Grupo Gap, you agree to the practices described in this Privacy Policy.

1. Who We Are

Grupo Gap operates GAP Investments and related business activities involving real estate-backed lending coordination, transaction structuring support, deal review coordination, and related consulting services in Costa Rica.

For privacy-related questions, you may contact us at:

Email: info@gap.cr

2. Information We May Collect

Depending on how you interact with us, we may collect information including:

• Full name
• Email address
• Phone number
• WhatsApp contact information
• Country of residence
• Company or business information
• Property information
• Loan request details
• Lender inquiry details
• Capital allocation discussions
• Project financing discussions
• Photos, documents, maps, title information, plans, or supporting materials you provide
• Browser information, device information, IP address, and website usage data
• Communication history with Grupo Gap

3. How Information Is Collected

We may collect information when you:

• Submit a website contact form
• Submit a lender inquiry
• Submit a borrower or project inquiry
• Email us
• Call us
• Contact us through WhatsApp
• Send documents or supporting information
• Interact with our website
• Use website analytics or tracking-enabled pages

4. How We Use Your Information

Grupo Gap may use collected information to:

• Respond to inquiries
• Review possible lending opportunities
• Coordinate lender and borrower discussions
• Assist with deal structuring discussions
• Coordinate due diligence review
• Coordinate documentation review
• Coordinate the closing process
• Communicate regarding potential transactions
• Improve website performance and user experience
• Protect against fraud, abuse, or misuse
• Meet legal or regulatory obligations where applicable

5. Information Sharing

Grupo Gap may share information where reasonably necessary for inquiry handling, transaction review, due diligence, coordination, or the closing process.

This may include sharing information with:

• Internal Grupo Gap team members
• Legal counsel
• Appraisers or valuation professionals
• Due diligence professionals
• Title or registration professionals
• Closing coordinators
• Technology providers
• Website hosting providers
• Email service providers
• Analytics providers
• Private lenders reviewing a possible transaction
• Borrowers involved in a transaction review
• Other relevant counterparties where necessary

We do not sell your personal information to unrelated third parties for marketing purposes.

6. Website Analytics and Tracking

Our website may use cookies, analytics tools, and similar technologies to understand website usage and improve performance.

This may include services such as:

• Google Analytics
• Google reCAPTCHA
• Website performance or security tools

These providers may collect browser, usage, device, or technical data according to their own privacy practices.

7. Cookies

Cookies are small data files stored on your device that help websites function, improve user experience, and provide analytics information.

You may disable cookies in your browser settings, although some website features may not function properly.

8. Confidential Business Information

Grupo Gap understands that lender, borrower, property, and transaction discussions may involve confidential business information.

While we take reasonable steps to handle submitted information professionally and securely, no website transmission or electronic communication method can be guaranteed completely secure.

9. No Transaction Approval

Submitting information to Grupo Gap does not mean:

• Your inquiry has been accepted
• A transaction has been approved
• A lender has agreed to participate
• A borrower has been accepted
• A deal will proceed to closing

10. Data Retention

Grupo Gap may retain submitted information for as long as reasonably necessary for inquiry handling, relationship management, business records, legal compliance, dispute resolution, or legitimate business purposes.

11. Data Security

We take reasonable administrative, operational, and technical measures to protect information, but no method of storage, email transmission, messaging platform, or internet communication is completely secure.

12. International Users

If you are outside Costa Rica and choose to communicate with Grupo Gap, you understand that your information may be transferred to and processed in Costa Rica or other jurisdictions where our service providers operate.

13. Third-Party Websites

Our website may contain links to third-party websites. Grupo Gap is not responsible for the privacy practices, content, or policies of third-party sites.

14. Children

This website and Grupo Gap services are not intended for individuals under eighteen years of age. We do not knowingly collect personal information from minors.

15. Your Rights

Depending on applicable law, you may request access to, correction of, or deletion of certain personal information held by Grupo Gap, subject to legal and operational limitations.

Requests may be sent to:
info@gap.cr

16. Changes to This Privacy Policy

Grupo Gap may update this Privacy Policy from time to time. Updated versions will be posted on this page with a revised effective date.

17. Contact

If you have questions about this Privacy Policy, please contact:

Grupo Gap
Email: info@gap.cr
Website: https://gapinvestments.com/

Important: This Privacy Policy is provided for general business and website use and should be reviewed by qualified legal counsel to confirm compliance with applicable legal requirements.