Legal notice

In compliance with Article 10 of Law 34/2002, of 11 July, on Information Society Services and Electronic Commerce, the Owner provides the following identifying information:

Company name: SHELLMENT, SL (hereinafter, "Shellment").
Tax ID (NIF): B88807425
Address: Paseo de la Castellana, 194 – 28046, Madrid (Spain).
Email: ahorrar@shellment.com
Registry details: Registered in the Commercial Registry of Madrid, diary 2026, entry 13284, sheet M-888866, registration 1.

Terms of use

Using this Website grants you the status of User and implies full acceptance of all clauses and conditions of use included in this Legal Notice. If you do not agree with any of these clauses, please refrain from using the Website.

Accessing the Website does not, in any way, initiate a commercial relationship with the Owner.

Through the Website, the Owner provides you with access to and use of various content published by the Owner and/or its collaborators via the Internet.

You are obliged and committed NOT to use any of the Website's content for unlawful or illicit purposes, purposes prohibited by this Legal Notice or by applicable law, or in any way that damages, disables, overloads, deteriorates, or prevents the normal use of the content, computer systems, or files stored on any equipment owned by or contracted to the Owner, other users, or any Internet user.

Content

The Owner has obtained the information, multimedia content, and materials included on the Website from sources it considers reliable, but while it has taken all reasonable steps to ensure that the information is correct, the Owner does not guarantee that it is accurate, complete, or up to date. The Owner expressly disclaims any responsibility for errors or omissions in the information contained on the Website.

It is prohibited to transmit or send through the Website any illegal or illicit content, computer viruses, or messages that in any way affect or violate the rights of the Owner or third parties.

The content of the Website is for informational purposes only and should not under any circumstances be used or considered as an offer to sell, a request for an offer to buy, or a recommendation to carry out any other operation, unless expressly stated.

The Owner reserves the right to modify, suspend, cancel, or restrict the content of the Website, links, or information obtained through the Website, without prior notice.

The Owner is not responsible for damages that may arise from the use of the Website's information.

Security measures

Personal data you provide to the Owner may be stored in automated or non-automated databases exclusively owned by the Owner, which assumes all technical, organisational, and security measures that guarantee the confidentiality, integrity, and quality of the information contained therein, in accordance with applicable data protection regulations.

However, you should be aware that security measures for computer systems on the Internet are not entirely reliable, and therefore the Owner cannot guarantee the absence of viruses or other elements that could cause alterations in the User's computer systems (software and hardware) or their electronic documents and files, although the Owner takes all necessary steps and appropriate security measures to prevent the presence of such harmful elements.

Personal data

You can find all information regarding the processing of personal data collected by the Owner in the Privacy Policy section of this page.

Cookie policy

Shellment uses PostHog, a web analytics tool, to understand how the platform is used and improve the user experience. Analytics data is processed in two distinct modes depending on the User's consent:

• Without consent: Visits are recorded anonymously and without cookies (cookieless mode). No data is stored on the User's device and browsing is not linked to any identified or identifiable person.
• With consent to analytics cookies: Full cookie-based tracking is enabled (ph_*), which may include: pages visited, time spent, interface interactions, session recordings, and — for registered users — the association of events with an internal user identifier. Email addresses are never used as tracking identifiers.

Consent is managed through the cookie preferences panel available on all pages of the platform. You may withdraw your consent at any time from that panel; upon doing so, analytics cookies (ph_*) will be automatically deleted from your device.

You can review PostHog's privacy policy at posthog.com/privacy.

Links to other websites

The Owner may provide you with access to third-party websites through links, with the sole purpose of informing you of the existence of other sources of information on the Internet where you can expand on the data offered on the Website.

These links to other websites do not in any way constitute a suggestion or recommendation to visit the destination web pages, which are outside the Owner's control. The Owner is therefore not responsible for the content of linked websites or the results you obtain by following the links. Likewise, the Owner is not responsible for links located on the linked websites to which it provides access.

The establishment of a link does not in any way imply the existence of a relationship between the Owner and the owner of the website on which the link is established, nor the Owner's acceptance or approval of its content or services.

If you access an external website from a link on this Website, you should read the other website's own privacy policy, which may differ from this Website's policy.

Intellectual and industrial property

All rights reserved. All access to this Website is subject to the following conditions: reproduction, permanent storage, and dissemination of the content, or any other use for public or commercial purposes, is expressly prohibited without the prior express written consent of the Owner.

Limitation of liability

The information and services included on or available through the Website may include inaccuracies or typographical errors. The Owner periodically incorporates improvements and/or changes to the information and/or Services, which may be introduced at any time.

The Owner does not represent or warrant that services or content will be uninterrupted or error-free, that defects will be corrected, or that the service or the server making it available are free from viruses or other harmful components, notwithstanding the Owner's efforts to prevent such incidents.

The Owner disclaims any liability for interruptions or malfunctions of the Services or content offered on the Internet, regardless of their cause. The Owner is also not liable for network outages, business losses resulting from such outages, temporary power failures, or any other type of indirect damage caused to you by reasons beyond the Owner's control.

Before making decisions and/or taking actions based on information included on the Website, the Owner recommends that you verify and cross-reference the information received with other sources.

Jurisdiction

This Legal Notice is governed in its entirety by Spanish law.

Unless a mandatory rule requires otherwise, for all matters arising from the interpretation, application, and compliance with this Legal Notice, as well as any claims that may arise from its use, the parties agree to submit to the Courts and Tribunals of Madrid, expressly waiving any other jurisdiction that may apply to them.

Privacy Policy

Shellment informs you of its Privacy Policy regarding the processing and protection of personal data of users that may be collected during browsing through the Website: shellment.com.

In this regard, the Owner guarantees compliance with the applicable personal data protection regulations, as reflected in Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD), and with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons (GDPR).

Purpose of processing

You are informed that all data Shellment requests from you is necessary for the purposes described in this privacy policy, and failure to provide it would make it impossible to contact you or process your request. Shellment reserves the right not to respond to or process requests that do not include the requested data.

You guarantee the accuracy of the personal data you provide. Shellment may periodically ask you to review and update the personal data it holds about you.

On the Website you can find information that may be useful for learning about the services offered by Shellment. In this regard, Shellment will only request and process the data necessary to handle the query made, provide the contracted service, or initiate and maintain a commercial, contractual, and/or pre-contractual relationship with you.

The different purposes for which your personal data is processed, and the legal bases, are:

• Performance of a contract or pre-contractual measures: Managing access to the private investment platform, account registration, authentication, and provision of the contracted service.
• Pre-contractual measures: Managing your participation in any selection process to join the company, and properly handling your application.
• Legitimate interest of Shellment: Managing information requests, queries, or complaints you submit through the forms on the Website, so that we can resolve your request as effectively and appropriately as possible.
• Your explicit consent: Conducting behavioural analytics of platform usage via web analytics tools (PostHog), including session recordings, with the aim of improving the user experience and identifying usability issues. This processing is only activated if you accept analytics cookies through the preferences panel.

Mere browsing of the Website will generally not involve the processing of your personal data, beyond, in specific cases, your IP address and browsing data, for the purpose of managing and optimising the Website, on the basis of Shellment's legitimate interest in preserving the security and integrity of the Website.

As a Website User you declare that you have been informed of the conditions on the protection of personal data, and you accept and consent to their processing by the Owner in the manner and for the purposes indicated in this Privacy Policy. To contact the Owner, subscribe to a newsletter, or post comments on this Website, you must accept this Privacy Policy.

Transfer of data to third parties

Personal data you provide to Shellment may be disclosed to the following categories of recipients:

• Third parties to whom Shellment is obliged to transmit information, such as public authorities, in order to comply with their requirements and applicable regulations.
• Companies forming part of the Shellment Group, in order to properly manage your contractual or pre-contractual relationship, as a result of the centralisation of administrative and IT processes within the Group.
• PostHog, Inc. (web analytics provider), only if you have accepted analytics cookies. PostHog processes data on servers located in the European Union and is subject to the GDPR. For more information: posthog.com/privacy.
• Auditors, lawyers, accounting firms, and other external consultants and service providers.

Data security

Shellment has appropriate policies and technical and organisational measures in place to safeguard and protect your personal data against illegal or unauthorised access, accidental loss or destruction, damage, and illegal or unauthorised use and disclosure.

We will also take all reasonable precautions to ensure that our staff and employees who have access to your personal data have received appropriate training.

In any case, you are informed that any transmission of data over the Internet is not completely secure and is therefore carried out at your own risk. Although we will make every effort to protect your personal data, Shellment cannot guarantee the security of personal data transmitted through our Website.

Data retention

The retention period for your data will be determined by the duration of your relationship with Shellment and legally established periods. The criteria used to set retention periods have been determined in accordance with requirements established by applicable legislation, regulations, and regulatory guidelines, as well as Shellment's operational requirements related to the proper management of relationships with different categories of data subjects.

Once your relationship ends, your personal data will be deleted once all actions necessary to manage and conclude any remaining obligations between the parties have been completed, unless you have provided express consent to receive commercial communications, in which case your data will be retained until you object.

Regardless of processing your data for only as long as strictly necessary for the corresponding purpose, we will subsequently retain it duly stored and protected for as long as liabilities arising from the processing may arise, in compliance with regulations in force at each time. Once possible actions have expired, we will proceed to delete your personal data.

Data protection rights

You may contact Shellment at any time to exercise your rights of access, rectification, erasure, restriction, objection, as well as the right to data portability and not to be subject to automated decisions, by submitting a request to SHELLMENT, SL at Paseo de la Castellana, 194 – 28046 Madrid (Spain), or to the following email address: ahorrar@shellment.com

Finally, if you wish to obtain more information about your data protection rights or need to lodge a complaint, you may contact the Spanish Data Protection Agency (Agencia Española de Protección de Datos), located at Calle Jorge Juan, 6, 28001, Madrid.

Changes to the privacy policy

Shellment reserves the right to modify this Privacy Policy to adapt it to legislative or case law developments, as well as industry practices. In such cases, the changes introduced will be announced on this page with sufficient notice before they take effect.

Terms of service

These Terms of Service govern access to and use of the private real estate investment platform offered by Shellment through the Website shellment.com (hereinafter, the "Platform"). Access to the Platform requires prior registration and is subject to express acceptance of these terms.

Access and registration

Access to the Platform is restricted to registered users. To register you must provide truthful, complete, and up-to-date information. You are responsible for maintaining the confidentiality of your access credentials and for all activities carried out under your account.

Shellment reserves the right to suspend or cancel access for any user who breaches these Terms or makes fraudulent, abusive, or unlawful use of the Platform.

Nature of the service

The Platform provides information on investment opportunities in commercial real estate assets. The information published is for informational purposes only and does not constitute financial, tax, or legal advice, nor an offer or investment recommendation.

All investments carry risks, including the possible loss of the invested capital. Before making any investment decision, we recommend consulting an independent financial adviser and carefully reviewing the information documents available on the Platform.

User obligations

As a Platform user, you agree to:

• Use the Platform solely for its intended purposes and in a lawful manner.
• Not reproduce, distribute, or make commercial use of the content without written authorisation from Shellment.
• Not attempt to access restricted areas, systems, or data belonging to other users.
• Not introduce malicious code or take actions that could compromise the security or integrity of the Platform.
• Notify Shellment immediately of any unauthorised use of your account.

Intellectual property

All content on the Platform — including texts, images, logos, design, source code, and investment materials — is the property of Shellment or its licensors, and is protected by applicable intellectual and industrial property law. Reproduction or use without prior written authorisation is expressly prohibited.

Service modifications

Shellment reserves the right to modify, suspend, or discontinue the service, in whole or in part, at any time and without prior notice, as well as to update these Terms. Material changes will be communicated to registered users with reasonable notice. Continued use of the Platform after the changes take effect constitutes acceptance of the updated Terms.

Limitation of liability

Shellment shall not be liable for direct or indirect damages arising from the use of or inability to use the Platform, errors or omissions in the content, or investment decisions made on the basis of information published on the Platform.

Jurisdiction

These Terms are governed by Spanish law. For any dispute arising from their interpretation or performance, the parties expressly submit to the Courts and Tribunals of Madrid, waiving any other jurisdiction that may apply.

Contact

If you have any questions about this Legal Notice or wish to make any comments about the Website, you may send an email to: ahorrar@shellment.com

Thank you

If you have made it this far, thank you for taking the time to read everything. We work to normalise investment in commercial real estate in a fast-paced world where traditional financial products are failing.

We work to protect family wealth.