PRIVACY POLICY FOR THE “PODESUBIR INC. INC.” APPLICATION AND PLATFORM

Version Date:  December 14, 2025 

Purpose of this Privacy Policy 

This Privacy Policy explains in detail how Podesubir Inc. Inc., a corporation incorporated in the State of Florida, United States (“Podesubir Inc.,”, “Urcyrd”, “we,” “us,” or “our”), collects, uses, stores, discloses, and otherwise processes personal information in connection with its applications, platforms, websites, and related access-control services (collectively, the “Services”).

Podesubir Inc.’s Services are designed to facilitate controlled access to private or restricted locations, subject to authorization, approval, and security policies defined by customers such as residential communities, commercial properties, enterprises, or event operators. Because physical access involves safety, accountability, and compliance considerations, the Services necessarily rely on certain categories of personal information to function properly.

This Privacy Policy applies to all individuals whose personal information is processed through the Services, including visitors, registered users, invitees, employees or contractors of customers, administrators, and other individuals interacting with the Services (“Users” or “you”).

This Privacy Policy does not apply to third-party websites, applications, or services that may be linked through the Services. Users should review the privacy policies of those third parties separately.

NOTE: please do not submit any personal information (whether yours or that of other persons) to Podesubir Inc. Inc, Podesubir Inc., Urclyrd, or companies related, whether through this website or through other means If you are not in agreement with this privacy policy.

We recommend that you read this notice to ensure you are fully informed about the way we collect, use, store, or otherwise process your personal information as well as your privacy rights. Please refer to the table of contents below.

1. General Information.
2. User right
3. Collection of Information.
4. Personal Data Processing
5. Your choices.
6. Children’s Privacy.
7. Security in User Personal Data Processing 
8. Complaint to a Supervisory Authority 
9. Consent and legal basis.
10. Changes to This Policy 

1.- General Information 

This section contains information regarding the processing of user personal data, totally or partially, automated or not, performed by the application and which may or may not be stored. The objective is to provide guidance regarding the information collected, the reasons for collection, and how the user can update, manage, export, or delete this information.

This Privacy Policy defines how Podesubir Inc. Inc, Urclyrd. and its group of companies (“we,” “our,” “us,” or “with us”) collect and use information from users, individuals, captured via its platform and/or applications that access or use our websites, our mobile applications, our web client (internet site), and/or any of our other sites, products, or services that reference this Privacy Policy (the “Services”). By using our Services, you understand that we will collect and use your information as described in this Privacy Policy (collectively, “you,” “your,” or “yours”). 

This privacy policy may be updated due to a possible regulatory update, which is why the user is invited to periodically consult this section. 

This Privacy Policy does not apply to any third-party websites and applications you may use, including any that are linked in our third-party Services. You should review the terms and policies for third-party websites and applications before clicking on any links or providing any personal information. 

Podesubir Inc.’s main products and Services help and facilitate users to access private locations subject to control and prior approval for such access. As part of our Services, users request that we collect and record information that helps parties authorize, release, and facilitate access to restricted locations. This information includes people who are involved in authorizing access, controlling access, making access invitations, and/or administering policies and access controls to private and restricted locations that use Podesubir Inc.’s platform, applications, and solutions. 

2.-User Rights 

The application commits to the following principles: 

• Your personal data will be processed lawfully, fairly, and transparently (lawfulness, fairness, and transparency); 
• Your personal data will be collected only for specified, explicit, and legitimate purposes, and cannot be subsequently processed in a manner incompatible with these purposes (purpose limitation);  
• Your personal data will be collected adequately, relevantly, and limited to the needs of the objective for which they are processed (data minimization);                                                           
• Your personal data will be accurate and updated whenever necessary, so that inaccurate data is deleted or rectified when possible (accuracy);                                                                            
• Your personal data will be kept in a form that allows identification of data subjects only for the period necessary for the purposes for which they are processed (storage limitation);                    
• Your personal data will be processed securely, protected from unauthorized or unlawful processing and against accidental loss, destruction, or damage, adopting adequate technical or organizational measures (integrity and confidentiality).    

The application user has the following rights: 

• Right of confirmation and access: the user’s right to obtain confirmation from the application that personal data concerning them is or is not being processed and, if so, the right to access their personal data; 
• Right of rectification: the user’s right to obtain rectification of inaccurate personal data concerning them from the application without undue delay;
• Right to erasure of data (right to be forgotten): the user’s right to have their data deleted from the application;
• Right to restriction of data processing: the user’s right to limit the processing of their personal data, which can be obtained when contesting data accuracy, when processing is unlawful, when the application no longer needs the data for proposed purposes, and when having opposed data processing and in case of unnecessary data processing;
• Right of objection: the user’s right to object at any time, for reasons related to their particular situation, to the processing of personal data concerning them, and may also object to the use of their personal data for marketing profiling; 
• Right to data portability: the user’s right to receive personal data concerning them that they have provided to the application, in a structured, commonly used, and machine-readable format, and the right to transmit this data to another application; 
• Right not to be subject to automated decisions: the user’s right not to be subject to any decision based solely on automated processing, including profiling, that produces legal effects on them or similarly significantly affects them.

The user may exercise their rights through written communication with the reference “Data Privacy -www.Podesubir Inc.inc.com,” specifying: – Full name or corporate name, TIN number (or SSN) and email address of the user and, if applicable, their representative; 

– Right, they wish to exercise with the application; 

– Date of request and user signature;

 – Any document that can demonstrate or justify the exercise of their right. 

The request should be sent to email: privacy@urclyrd.com, or by mail to the following address: 17754 SW, 47^th Street, Miramar, FL, 33029

3. Collection of Information 

3.1. Type of Data Collected 

To provide and improve our Services, we collect information about visitors to our sites, users of our Services, the devices they use, and sometimes their locations.

We collect certain information directly from you, when you fill out forms with a name or email address. We collect other information, typically about devices, internet browsers, or locations, automatically (without you needing to include them in a form). We may also collect information about you from other sources, such as contact lists from people who use or may be interested in our Services.

 You can choose to visit our sites, install our applications, or provide us with information. However, if you don’t provide us with certain information, you may not be able to use our Services. For example, if you don’t adopt an electronic signature and password, you won’t be able to log into the applications. 

The personal data collected by the application is only that necessary for user identification and compliance with Service security procedures.  All data necessary for user registration will be collected, such as full name or corporate name, email, information and images of valid identification documents and user address, among others, necessary requirements to access certain services offered by the application. 

Eventually, other categories of data may be collected due to legitimate interest or other reasons permitted by law. 

The user commits to providing exclusively their personal data and not that of third parties. 

You provide us with information about yourself when you: 

• Register or log into your account;
• Create, accept, reject, or review access invitations; 
• Create or edit your user profile or users of a specific property, department, or facility; 
• Contact customer support; 
• Comment on our blogs or community forums;
• Provide your photograph or photographs of identification documents.
• Start, sign, or review an electronic document
• Participate in surveys, sponsored events, sweepstakes, or when you sign up for newsletters.

Examples of information you provide are: 

name, email address, mailing address, phone number, front photographs, document photographs, and/or electronic signature.

You also provide us with information about others when you use parts of our Services, for example when you: 

• Create or send meeting invitations; 
• Share information in a chat; 
• Add other people as representatives to send or change invitations; 
• Leave comments; 
• Refer friends; 
• Contact customer service or support by any means. 

Information We Collect Automatically. 

We automatically collect information from you and your devices when you use our Services, even when you visit our sites or applications without logging in. 

The information we collect automatically includes but is not limited to: 

• Device Data, Usage Information, and Invitations. We collect information about how you use our Services and the computers or other devices, such as cell phones or tablets, that you use to access our Services. Some examples include: 
• IP address; 
• Precise geolocation information that you allow our applications to access (typically from your mobile device); 
• Unique device identifiers and device attributes, such as operating system and browser type; 
• Usage data, such as: web log data, indicating entry and exit pages, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of these pages, time spent on specific pages, date and time you used our Services, frequency of your use of our Services, error logs, and other similar information; 
• Invitation data, such as: names and email addresses of invitation parties, subject, history of actions that individuals perform with invitations (for example, accept, reject, request, change, others) and information about these individuals or their devices, such as name, email address, IP address, and authentication methods. 

• Cookies and Related Technologies. We may use cookies, which are text files containing small amounts of information saved on your device (“Cookies”), or related technologies, such as web beacons, shared local objects, and tracking pixels to store and collect information. We also allow others to use Cookies in conjunction with the Services as described below. Cookies may store your preferences, your username, and help personalize advertising. 

• Analytics. We may use services like Google Analytics. These services use Cookies to collect usage data and help us understand how people use our Services, for example the pages they visit and for how long and the website or page they were on before entering the Podesubir Inc. Inc website. 

Information We Collect from Other Sources. 

We may collect information about you from other places, such as: 

• Third-Party Sources. Examples of third-party sources include merchants, partners, researchers, affiliates (such as companies linked to Podesubir Inc.), service providers, and others who are legally authorized to share your information with us. For example, if you register for our Services on another website, the website may provide us with your information. 
• Other Customers. Other customers or users may provide us with your information. For example, if a customer expects you to participate in a meeting and sends an Invitation using our Services, they will provide us with your name and email address. 
• Combining Information from Different Sources. We may combine the information we receive from other sources with the information we collect from you (or your device) and use them as described in this Privacy Policy. 

Information We Collect and Process on Behalf of Customers. 

When our customers use our Services, we process and store certain information on their behalf as a data processor. For example, when sending a meeting Invitation for your acceptance or rejection, we act as a data processor and process invitations on behalf of the customer. In these cases, the customer is a data controller and is responsible for most characteristics of information processing. 

3.2. Legal Basis for Processing Personal Data

By using the application services, the user is consenting to this term and its privacy policy. 

The user has the right to withdraw their consent at any time, without compromising the lawfulness of personal data processed before its withdrawal. Consent withdrawal may be made by email : privacy@urclyrd.com , or by mail sent to the following address: 17754 SW, 47^th Street, Miramar, Florida, 33029

The consent of relatively or absolutely incapable persons, especially children under 16 (sixteen) years of age, may only be given, respectively, if properly assisted or represented. 

We typically collect or use information from you, when we need the information to perform our functions related to our contract with our customers, with you our users, or when processing is done in our legitimate interest and does not override your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or retain personal information or need personal information to protect your vital interests or those of another person. 

For example, when we: 

• Use information to create and manage an account, we need the information to provide related Services; 
• Collect and record data associated with single access authorization use to controlled access premises using our application or platform, including QR codes, bar codes, identification signals, facial biometrics, Bluetooth or NFC, we do this to comply with contractual obligations and/or regulations; 
• Use name and email address for email communication purposes, including marketing, we do this with your consent (which you can withdraw at any time); 
• Collect usage data and analyze to improve our Services, we do this based on our legitimate interest in protecting and improving our Services. 

Your main choice of consent for this type of personal information is simply not providing it, such as by not creating a profile or not leaving a comment in a blog.

3.3. Purposes of Personal Data Processing 

Generally, we collect, use, store, and process your information to provide our Services, repair and improve them, develop new Services, and promote our businesses and their products and Services.

Processing of personal data without user consent will only be carried out due to legitimate interest or for cases provided by law, among others, the following: 

• to provide you with the Services and products you requested and perform related billing; 
• to offer special features, products, or events using email or phone, or send you information about the property where you are located, properties where you conduct or conducted visits, and/or your employer when it is a company user of our services; 
• to manage the Services platform, including support and security systems; 
• for compliance with legal or regulatory obligation by the controller; 
• to send you records of our relationship; 
• for conducting studies by research bodies, ensuring, whenever possible, anonymization of personal data; 
• to create and review data about our users and how they use our Services;
• to test changes in our Services and develop new features and products; 
• when necessary for contract execution or preliminary procedures related to a contract of which the user is a party, at the request of the data subject; 
• to correct problems, you may have with our Services, including responding to support questions or resolving disputes; 
• for regular exercise of rights in judicial, administrative, or arbitral proceedings, 
• for protection of life or physical integrity of the data subject or a third party; 
• for health protection, in procedures performed by health professionals or health entities; 
• when necessary to serve the legitimate interests of the controller or a third party, except when fundamental rights and freedoms of the data subject that require protection of personal data prevail; 
• for credit protection, including provisions of pertinent legislation; 
• to prevent, investigate, and respond to: fraud, unauthorized access or use of our Services, violation of terms and policies, or other malicious behaviors; 
• to comply with legal retention periods. 

Other Uses.  We may combine the information we collect (“aggregation”) or remove parts of the information (“de-identification”) to limit or prevent identification of any particular user or device to assist with research and advertising purposes. This Privacy Policy does not apply to our use of such aggregated or de-identified information. 

3.4. Information Sharing 

We do not rent, sell, or share your information with third parties, except as described in this Privacy Policy. 

We share information as follows: 

• Service Providers. We share your information with other companies we use to support our Services. These companies provide services such as intelligent search technology, intelligent analytics, authentication systems, invoice billing, fraud detection, and customer support. We have contracts with our service providers aimed at protecting and appropriate use of your personal information; 
• We may share your information with other companies under common ownership or control of Podesubir Inc.. These companies use your information as described in this Privacy Policy; 
• Advertising Partners. We may share your information with event sponsors, webinars, or sweepstakes for which you registered, or other parties with whom we may participate in joint marketing activities; 
• Government or Public Authorities. We may share your information to comply with applicable laws, or to respond to legal process (such as a court order). We may also share your information when there is a threat to anyone’s physical security, violations of this Privacy Policy or other contracts, or to protect the legal rights of third parties, including our employees, users, or the public; 
• Business Operations. We may share your information during a corporate operation, such as a merger or sale of our assets, or as part of an audit (due diligence) for such contemplated operations. If a corporate operation occurs, we will notify about any changes in control of your information, as well as options you may have; 
• We may share your information in other ways if you have asked us to do so or if you have given us your consent. For example, with your consent, we publish user testimonials that may identify you. 

Your information may also be shared as described below: 

• Other Users. When you authorize others to access, use, or edit content, send invitations, receive, accept, or reject, we share that content with them. 
• Public Information. 
• User-Created Content. When you comment on our blogs or community forums, this information may also be read, collected, and used by others; 
• Profile Information. When you create a profile on Podesubir Inc., other Podesubir Inc. users may view your profile information. 
• Your Employer or Organization. When you create an account or user function with an email account assigned to you as an employee, subcontractor, or member of an organization, such as yourname@youremployer.com or yourname@nonprofit.org, that organization (if it is a Podesubir Inc. customer or is an individual or legal entity (company) of Podesubir Inc.) may locate your account and perform certain actions that may affect it.

 3.5. Personal Data Retention Period 

User personal data will be kept for a period not exceeding that required to fulfill the objectives for which they are processed.

The data retention period is defined according to the following criteria: 

– Data will be stored for the time necessary to provide access services contracted by the condominium.

 -User personal data may only be kept after the end of processing in the following cases: 

• for compliance with legal or regulatory obligation by the controller; 
• for study by research body, ensuring, whenever possible, anonymization of personal data; 
• for transfer to third parties, provided that data processing requirements set forth in legislation are respected; 
• for exclusive use by the controller, with access by third parties prohibited, and provided that data is anonymized. 

3.6. Recipients and Transfer of Personal Data 

User personal data may be shared with the following persons or companies: 

AMAZON Web Services, Inc., with headquarters at: 410 Terry Avenue North, Seattle, WA, 98109 

The transfer may only be made to another country if the country or territory in question or the international organization in question ensures an adequate level of protection of user data. 

If there is no adequate level of protection, the application commits to ensuring protection of your data according to the strictest rules, through specific contractual clauses for certain transfers, standard contractual clauses, binding corporate rules, or seals, certificates, and codes of conduct regularly issued.

4. Personal Data Processing 

4.1. How We Protect Your Information 

To keep your information secure, we use physical, electronic, and administrative tools. We apply these tools based on the sensitivity of the information we collect, use, and store, and the current state of technology. Despite taking measures to prevent unauthorized access or use of personal information, the Internet and our Services are not 100% secure. For this reason, we cannot guarantee that the information we collect or store will always be protected from unauthorized access, or that it will be used only as described in this Privacy Policy. 

4.2. Data Controller 

The controller, responsible for processing user personal data, is the natural or legal person, public authority, agency, or other body that, individually or jointly with others, determines the purposes and means of personal data processing. 

In this application, the person responsible for processing collected personal data is Podesubir Inc. Inc., represented by Ubaldo Lopez, who can be contacted by email: contact@urclyrd.com.  or at the address: 

17754 SW, 47th Street, Miramar, Florida, 33029. 

4.3. Subcontracted Data Processor 

The subcontracted data processor is the natural or legal person, public authority, agency, or other body that processes personal data under the supervision of the person responsible for processing user data.

User personal data will be processed by the legal entity AMAZON Web Services, Inc., with headquarters at: 410 Terry Avenue North, Seattle, WA, 98109 

4.4. Data Protection Officer

The data protection officer is the professional responsible for informing, advising, and controlling the data controller and subcontracted data processor, as well as workers who process data, regarding the application’s obligations under the law and in cooperation with the competent supervisory authority. 

In this application, the data protection officer is Ubaldo Lopez and can be contacted by email: 

Ubaldo.lopez@urclyrd.com. 

privacy@urclyrd.com 

5. Your Choices

This section describes many measures you can take to change or limit the collection or use of your information. 

• If you complete a profile to use our services, you can access and review that information. If any information is inaccurate or incomplete, you can make changes in your account settings; 
• Advertising Messages. You can opt out of receiving marketing email messages. You can opt out of receiving these messages by clicking the “unsubscribe” link in the email message. We inform you that we may send a message to confirm that you have opted out of receiving more messages. If you are a registered user of our Services, or if you have participated in transactions with us, we may continue to send messages about transactions and relationships (for example, notifications) after you opt out of receiving marketing messages; 
• Cookies and Other Related Technologies. You can reject cookies in your internet browser settings. However, if you reject cookies, you may not be able to use some parts of our Services
• To change how Google Analytics collects and uses your information, you can install the Google Analytics Opt-Out Browser Add-On by clicking here (https://tools.google.com/dlpage/gaoptout); 
• We do not recognize or respond to Do Not Track signals from internet browsers; 
• Device and Usage Information. If you don’t want us to see your device location, you can turn off location sharing on your device, change your device’s privacy settings, or refuse to share location in your internet browser. This may prevent proper functioning of our application and platform; 
• Closing Your Account. If you wish to close your account, please log into your account and cancel or send an email to contact@urclyrd.com; 
• Complaints. We are committed to resolving all valid complaints about your privacy and our collection or use of your personal data. For questions or complaints about our data use practices or Privacy Policy, contact us through email contact@urclyrd.com 

6. Children’s Privacy 

Our Services were not developed and are not offered to persons under 16 years of age (“minors”). We do not intentionally collect or request information from minors. We do not intentionally allow minors to use our Services. If you are a minor, please do not use our Services or send your information. We delete information that we become aware has been collected from a minor without proven consent from a guardian. We ask that you contact minors@urclyrd.com.  if you believe we have information from or about a minor. 

7. Security in User Personal Data Processing 

The application commits to applying adequate technical and organizational measures to ensure an adequate level of security appropriate to the risk, taking into account the most advanced techniques, implementation costs, and the nature, scope, context, and purposes of processing, as well as risks of varying probability and severity to user rights and freedoms. 

For this purpose, the application uses SSL (Secure Socket Layer) certificate that ensures personal data is transmitted securely and confidentially, so that data transmission between the server and user, and in feedback, occurs in a completely encrypted manner. 

However, Podesubir Inc. Inc., disclaims responsibility for exclusive fault of third parties, such as in case of hacker or cracker attacks, or exclusive fault of the user, who, for example, transfers their data to a third party, except if piracy occurred due to application security failure. Podesubir Inc. Inc. also disclaims responsibilities resulting from systems with inadequate security or procedures of our client properties where we are interconnected if these clients require that information from their residents and visitors registered with us be replicated in these systems. The application also commits to communicate to the user in adequate time if any type of violation of their personal data security occurs that may cause high risk to their personal rights and freedoms.

Personal data breach is a security breach that accidentally or unlawfully causes destruction, loss, alteration, unauthorized disclosure, or access to personal data transmitted, stored, or subject to any other type of processing. 

Finally, the application commits to treating user personal data confidentially, within legal limits. 

8. Complaint to a Supervisory Authority 

Without prejudice to any other administrative or judicial appeal, all data subjects have the right to file a complaint with a supervisory authority. The complaint may be made to the authority of the application’s headquarters, the user’s habitual residence country, their workplace, or the place where the alleged infringement was practiced. 

9. Consent and legal basis 

In some cases, Podesubir Inc. Inc may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If Podesubir Inc. Inc asks you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if Podesubir Inc. Inc collects and uses your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

When you use the Urclyrd or Podesubir Inc. website or otherwise, and provide personal information to Podesubir Inc. Inc., you acknowledge and agree that we may collect, use, disclose, and process that information in accordance with this Privacy Statement.

If you provide Podesubir Inc. Inc. with personal information relating to another individual, you confirm that you are authorized to do so and that you have obtained that individual’s consent for their personal information to be collected, used, disclosed, and processed in accordance with this Privacy Statement.

The legal basis on which Podesubir Inc. Inc. collects and processes personal information depends on the nature of the information involved and the specific circumstances under which it is collected. In most cases, we collect personal information only when you have given your consent, when the information is necessary to perform a contract with you, or when the processing is based on our legitimate business interests and does not override your fundamental rights and freedoms.

Notwithstanding the forgoing, please note that Podesubir Inc. Inc may also collect, use, disclose, or process your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

10. Changes to This Policy 

We may change this Privacy Policy to reflect changes in law, our businesses, our Services, our data collection and use practices, or technological advances. Our use of information we collect is subject to the Privacy Policy in effect at the time such information is used. Depending on the type of change, we may notify you about changes on this page or by email. Please review this Privacy Policy periodically and carefully analyze all changes made to this Privacy Policy. 

11. How to Contact Us

For questions or complaints regarding our use of your information or the Privacy Policy, please contact us at email privacy@urclyrd.com or at Podesubir Inc.’s address, attention to: 

Data Administrator 

17754 SW, 47th Street

Miramar, Florida, 33029