LAGANGA PRIVACY POLICY

Last updated: July 15, 2026

Effective date: July 15, 2026

1. Introduction

This Privacy Policy explains how Chu Capital, C.A. collects, uses, stores, discloses and protects personal information when an individual accesses or uses LaGanga.

LaGanga is a live-commerce platform that allows users to discover products, follow Sellers, participate in livestreams, place bids, make purchases, sell products, manage orders and communicate with other users.

The mobile application, website, livestreams, support systems, communications, events, promotions and related services are collectively referred to as “LaGanga,” the “Platform” or the “Services.”

LaGanga is operated by:

Chu Capital, C.A.

Parque Central, Edificio El Tejar, 15th floor, Office 15M

Caracas, Capital District

Bolivarian Republic of Venezuela

Tax ID (RIF): J-508324366

Email: hi@chuventures.com

In this Policy, “Chu Capital,” “LaGanga,” “we,” “us” and “our” refer to Chu Capital, C.A.

2. Scope of this Policy

This Policy applies to personal information we process when an individual:

Creates or uses an account.
Browses LaGanga.
Participates in a livestream.
Lists or sells products.
Places bids.
Makes purchases or payments.
Manages shipping, returns or claims.
Communicates with other users.
Contacts support.
Participates in promotions, surveys or events.
Interacts with our websites, social pages or communications.
Uses any other LaGanga feature.

This Policy does not directly govern the independent privacy practices of Sellers, carriers, payment processors or other third parties operating under their own policies.

3. Data controller

Chu Capital, C.A. is responsible for personal information collected and used to operate LaGanga, except where a third party acts as an independent controller for a particular service.

For example, a payment provider may process financial information under its own terms and privacy policy.

Sellers may also process Buyer information, such as a name, address and telephone number, when necessary to complete delivery. In those circumstances, the Seller must use the information only for the relevant Transaction and comply with applicable law.

4. Personal information we collect

The information we collect depends on how you use LaGanga and which features are available.

We may collect information supplied directly by you, information collected automatically and information received from third parties.

5. Account and profile information

When you create or use an account, we may collect:

First and last name.
Username.
Email address.
Telephone number.
Date of birth.
Country, city or residential area.
Mailing address.
Profile picture.
Biography.
Language preferences.
Categories and interests.
Login information.
Authentication information.
Internal account identifiers.
Account status.
Platform roles, such as Buyer or Seller.

We may also retain records showing acceptance of the Terms of Service and other policies, including the date, time, accepted version, application used and other reasonably necessary technical information.

6. Authentication and security information

To provide access and protect accounts, we may collect or generate:

Encrypted passwords or cryptographic representations.
One-time passcodes.
Session tokens.
Authentication tokens.
Login and logout information.
Failed access attempts.
Authorized devices.
IP addresses.
Security alerts.
Information relating to authentication through email, telephone, SMS or WhatsApp.

We will not request your full password through email, private messages or support calls.

7. Identity and verification information

To enable selling features, increase limits, process payments or prevent fraud, we may request:

National identity card.
Passport.
Tax identification number.
Date of birth.
Nationality.
Address.
Photographs of identification documents.
Verification photograph or video.
Information contained in government documents.
Business or corporate information.
Legal-representative details.
Proof of address.
Information required to verify the ownership or origin of products.
Results or status of third-party verifications.

Verification may be performed by Chu Capital or a specialized provider.

When facial recognition, biometric comparison or another sensitive technology is used, we will provide additional information or obtain consent where legally required.

8. Seller information

In addition to the information above, we may collect from Sellers:

Business name.
Tax identification number.
Business address.
Billing information.
Bank or settlement details.
Social-media information.
Product categories.
Sales history.
Delivery, cancellation and claim rates.
Inventory information.
Authenticity or origin documents.
Purchase invoices.
Customer-service records.
Information needed to assess compliance, safety and risk.

9. Payment and Transaction information

When you participate in a Transaction, we may collect:

Products viewed, saved, bid on, sold or purchased.
Bid history.
Bid amounts.
Purchase price.
Currency.
Payment method.
Payment status.
Billing information.
Fees.
Refunds.
Chargebacks.
Reversals.
Seller payouts.
Balances and pending amounts.
Transaction date and time.
Order number.
Buyer and Seller information.
Information needed to investigate disputes.

Payments may be processed by independent providers.

Depending on the method used, Chu Capital may not directly collect or store a full payment-card number. We may nevertheless receive associated information such as:

Cardholder name.
Payment-method type.
Last digits.
Issuing country.
Billing address.
Approval or decline status.
Transaction identifier.
Fraud or risk indicators.

10. Shipping and delivery information

To manage delivery, we may collect:

Recipient name.
Delivery address.
Location references.
Telephone number.
City, municipality, state or area.
Postal code, where applicable.
Carrier.
Tracking number.
Shipping status.
Dispatch and delivery dates.
Signature or receipt confirmation.
Delivery photographs.
Shipping communications.
Return information.
Selected pickup point.

Necessary information may be shared with the relevant Seller, Buyer, carrier or delivery provider.

When local delivery or pickup is used, we may use approximate location to display nearby options. We will not publicly display a complete residential address unless necessary, permitted by the applicable feature and properly disclosed to the user.

11. Location information

We may collect different levels of location information.

Approximate location

We may estimate a country, city or region using:

IP address.
Postal code.
Delivery address provided by the user.
Regional settings.

We may use this information to:

Display relevant content.
Estimate delivery options.
Prevent fraud.
Apply geographic restrictions.
Personalize the experience.

Precise device location

LaGanga does not currently request access to precise device location (GPS). Shipping addresses are entered manually by the user; we do not use the phone's GPS to locate the user.

If we later enable a feature that requires precise location, we will request the corresponding system permission and update this Policy before doing so.

12. Livestreams, image, audio and voice

When a user hosts or participates in a livestream, we may collect:

Video.
Audio.
Image.
Voice.
Username.
Comments.
Reactions.
Products displayed.
Bids and auction results.
Stream metadata.
Date, time and duration.
Technical connection information.
Clips created from the livestream.

We may record and retain livestreams for a reasonable period to:

Verify what was displayed or stated during a sale.
Resolve claims.
Investigate fraud.
Moderate content.
Enforce our policies.
Handle support requests.
Protect Buyers and Sellers.
Meet legal obligations.
Improve Service quality.

Public livestreams may be viewed by other users. Users should avoid revealing home addresses, identity documents, financial information or other sensitive data during a livestream.

13. Photographs, videos and published content

We may collect user-posted content, including:

Product photographs.
Videos.
Descriptions.
Comments.
Reviews.
Profiles.
Posts.
Evidence images.
Packaging photographs.
Shipping or receipt evidence.
Counterfeit reports.
Reported content.

We may also collect associated metadata, such as creation date, device, format, size and, where available and relevant, location information.

Content published in profiles, listings, public chats or livestreams may be visible to other users or the public depending on the applicable feature and settings.

14. Messages and communications between users

LaGanga may provide direct messages, livestream chats, comments and order communications.

We may collect and store:

Message content.
Sender and recipient.
Date and time.
Delivery or read status.
Attachments.
Related reports.
Technical metadata.

We may review or otherwise process messages when reasonably necessary to:

Handle a report.
Resolve a claim.
Detect fraud.
Prevent harassment or abuse.
Investigate prohibited products.
Meet a legal obligation.
Enforce our Terms and Community Guidelines.
Protect user safety.

We will not use the content of private conversations for targeted advertising.

15. Support and claim information

When you contact support or submit a claim, we may collect:

Name.
Contact information.
Order number.
Description of the issue.
Messages.
Photographs.
Videos.
Recordings.
Invoices.
Receipts.
Product information.
Payment or shipping information.
Claim outcome.
Satisfaction surveys.

Support calls or conversations may be recorded where disclosed and legally permitted.

16. Information collected automatically

When you use LaGanga, we may automatically collect:

Device information

IP address.
Device type.
Model.
Operating system.
App version.
Language.
Time zone.
Mobile carrier.
Connection type.
Device or app identifiers.
Advertising identifier, where permitted.
Device settings.
Push-notification tokens.
Crash logs.

Usage information

Screens visited.
Time spent.
Buttons or links selected.
Searches.
Products viewed.
Sellers followed.
Preferred categories.
Favorites.
Shopping carts.
Bids.
Purchases.
Livestreams viewed.
Interactions.
Referral information.
Action date and time.
Errors and performance.

Technical information

Server logs.
API requests.
Authentication events.
Latency.
Sessions.
Failures.
Security information.
Anomalous activity.
Data needed to prevent automation or abuse.

17. Information received from third parties

We may receive information from:

Payment processors.
Banks and financial providers.
Shipping companies.
Courier services.
Identity-verification providers.
App stores.
Authentication providers.
Analytics services.
Fraud-prevention services.
Social networks.
Business partners.
Public sources.
Other users.

For example, we may receive payment confirmation, shipment status, verification results or security information.

We do not control those third parties’ independent practices.

18. Device contacts

LaGanga may offer a feature allowing users to find or invite contacts.

We will not access a device address book without first requesting permission.

When a user enables the feature, we may temporarily process:

Names.
Telephone numbers.
Email addresses.
Matches with existing users.

Users must have reasonable authorization before sharing another person’s information.

Access can be withdrawn through device settings.

19. How we use personal information

We may use personal information for the following purposes.

Providing the Services

Creating and managing accounts.
Authenticating users.
Enabling purchases and sales.
Processing bids and auctions.
Managing payments.
Managing orders.
Coordinating delivery.
Facilitating returns.
Displaying listings and livestreams.
Enabling messages and comments.
Providing support.

Personalizing LaGanga

Recommending livestreams.
Showing relevant products.
Suggesting Sellers.
Organizing the feed.
Remembering preferences.
Adapting content based on general location.
Improving search results.

Safety and fraud prevention

Verifying identity.
Detecting false accounts.
Investigating suspicious activity.
Detecting auction manipulation.
Preventing fraudulent chargebacks.
Assessing payment risk.
Preventing unauthorized access.
Protecting Buyers and Sellers.
Detecting prohibited or counterfeit products.
Applying limits and controls.

Managing claims

Reviewing descriptions and livestreams.
Evaluating evidence.
Confirming shipments.
Resolving returns.
Processing refunds.
Holding payouts.
Investigating reports.
Communicating with relevant parties.

Communications

Sending receipts.
Providing order updates.
Sending security codes.
Sending bid or sale notifications.
Communicating policy changes.
Responding to requests.
Sending account alerts.
Sending authorized promotional communications.

Improving the Services

Measuring performance.
Correcting errors.
Testing features.
Performing analytics.
Researching usage patterns.
Developing tools.
Improving recommendations.
Assessing safety and quality.

Legal compliance

Meeting legal obligations.
Responding to valid orders.
Handling competent-authority requests.
Managing tax obligations.
Enforcing our contracts.
Protecting rights and property.
Retaining records.
Investigating unlawful activity.

20. Automation and profiling

We may use automated systems to:

Recommend products and livestreams.
Rank content.
Detect fraud.
Calculate risk.
Detect spam.
Identify anomalous activity.
Apply security controls.
Prioritize human review.

An automated decision may result in a temporary restriction, verification request or further review.

Where an automated decision has a material effect on a user, the user may request human review to the extent required by applicable law.

21. Cookies and similar technologies

Our websites and Services may use:

Cookies.
Local storage.
Pixels.
Web beacons.
SDKs.
App identifiers.
Measurement technologies.

These technologies may be used for:

Necessary functions

Maintaining sessions.
Remembering preferences.
Protecting accounts.
Detecting fraud.
Enabling essential features.

Performance and analytics

Measuring visits.
Assessing performance.
Detecting errors.
Understanding usage.
Improving the Platform.

Personalization

Remembering viewed products.
Adapting recommendations.
Displaying relevant categories.
Maintaining settings.

Advertising and measurement

When advertising is implemented, we may use permitted identifiers and technologies to:

Measure campaigns.
Attribute app installations.
Create audiences.
Limit frequency.
Display relevant advertisements.

Where required by law, we will obtain consent before using non-essential technologies.

22. Analytics

We may use product-analytics, performance, attribution and error-reporting providers.

Those providers may receive:

Account or device identifiers.
IP address.
Usage information.
In-app events.
System version.
Technical information.
Approximate location information.

Where possible, we will limit the data shared and use pseudonymous identifiers.

We will not provide full payment-card numbers, passwords or identity-document images to analytics providers for product-measurement purposes.

23. Advertising and marketing

We may use information to send:

Product updates.
Promotions.
Invitations.
Recommendations.
Campaigns.
Livestream information.
Communications concerning followed Sellers.

Users may opt out of promotional communications through:

An unsubscribe link.
Account settings.
Device settings.
A request sent to Chu Capital.

Users will continue to receive necessary communications concerning security, payments, orders, claims and legal changes.

We do not share SMS, WhatsApp or messaging consent with third parties for their independent marketing.

24. When we disclose information

We may disclose personal information to the categories described below.

Other users

We may disclose information needed to:

Display a profile.
Publish an item.
Complete a sale.
Ship a purchase.
Process a return.
Enable social interaction.
Resolve a claim.

For example, a Seller may receive a Buyer’s name, telephone number and address to complete delivery.

A Buyer may receive a Seller’s username, business information or return address where necessary.

Service providers

We may disclose information to providers of:

Infrastructure.
Cloud hosting.
Databases.
Video and streaming.
Content delivery.
Messaging.
Notifications.
Customer service.
Analytics.
Security.
Fraud prevention.
Identity verification.
Payment processing.
Shipping.
Email.
Storage.
Legal and accounting services.

These providers may use the information only to provide contracted services unless they act as independent controllers.

Payment processors and financial institutions

We may disclose Transaction, identity, billing and risk information to:

Authorize payments.
Process charges.
Complete settlements.
Process refunds.
Manage chargebacks.
Verify accounts.
Meet legal obligations.
Prevent fraud.

Carriers and delivery providers

We may disclose:

Name.
Address.
Telephone number.
Order information.
Delivery instructions.
Tracking information.

Business partners

We may disclose limited information to brands, event organizers or partners when a user requests a joint activity or enters a promotion.

Affiliates and corporate transactions

We may disclose information to companies under common control where necessary to operate the Services.

Information may also be transferred in connection with a:

Merger.
Acquisition.
Reorganization.
Financing.
Asset sale.
LaGanga transfer.
Insolvency proceeding.

Authorities and legal protection

We may preserve, access or disclose information where we reasonably believe in good faith that it is necessary to:

Meet a legal obligation.
Respond to a valid order.
Cooperate with a competent authority.
Prevent harm.
Investigate fraud.
Protect rights or safety.
Enforce agreements.
Collect amounts owed.
Defend a claim.

25. Public information

Certain information may be publicly visible:

Username.
Profile photograph.
Biography.
Followers and followed accounts.
Product listings.
Public livestreams.
Public comments.
Reviews.
Ratings.
Number of sales.
Clips.
Seller business information.

Users should avoid publishing sensitive information.

Removing content does not guarantee its immediate deletion from:

Copies created by third parties.
Search engines.
Screenshots.
Legal records.
Backups.
Transaction evidence.

26. Sale of personal information

Chu Capital does not sell personal information to third parties for money.

When we use advertising technologies that may legally constitute a “sale,” “sharing” or “targeted advertising” in a particular jurisdiction, we will provide the notices and opt-out mechanisms required there.

27. De-identified and aggregated information

We may transform information into aggregated, statistical or de-identified data that does not reasonably identify an individual.

We may use this data for:

Analytics.
Research.
Reporting.
Product development.
Market trends.
Security.
Business presentations.

We will not attempt to re-identify properly de-identified information except to test the effectiveness of safeguards or comply with law.

28. International transfers

Information may be stored or processed in Venezuela, the United States or other countries where Chu Capital or its providers operate.

Those countries may have privacy laws different from those of the user’s country.

When transferring information internationally, we will take reasonable measures and, where applicable, use:

Data-protection agreements.
Confidentiality obligations.
Access controls.
Encryption.
Provider assessments.
Applicable contractual clauses.
Other legally recognized mechanisms.

29. Data retention

We retain information for as long as necessary to:

Maintain the account.
Provide the Services.
Complete Transactions.
Resolve claims.
Prevent fraud.
Meet legal, tax and accounting obligations.
Defend rights.
Maintain security.
Enforce agreements.

Retention periods depend on:

The nature of the information.
Sensitivity.
Risk.
Purpose.
Account status.
Pending disputes.
Legal requirements.
Fraud-prevention needs.

We may retain certain records after an account is deleted, including:

Transaction history.
Invoices.
Tax records.
Chargebacks.
Claims.
Enforcement records.
Fraud evidence.
Legal acceptances.
Security logs.

When information is no longer required, we will delete, anonymize or isolate it until technical deletion is possible.

30. Security

We use reasonable administrative, technical and organizational safeguards.

These measures may include:

Encryption in transit.
Encryption of sensitive information at rest.
Access controls.
Activity logs.
Secret management.
Secure authentication.
Backups.
Monitoring.
Security testing.
Restricted internal access.
Provider assessments.
Incident-response procedures.

No system is completely secure. We cannot guarantee that unauthorized access, loss, alteration or disclosure will never occur.

Users should use a strong password, protect their phones and promptly report suspicious activity.

31. Security incidents

When we identify an incident involving personal information, we may:

Investigate its scope.
Contain the incident.
Restore systems.
Change credentials or tokens.
Notify affected users.
Notify authorities where appropriate.
Provide security recommendations.
Implement corrective measures.

Notices will be provided according to applicable law and the level of risk identified.

32. Privacy rights and choices

Depending on applicable law, users may request:

Confirmation that we process their information.
Access.
A copy of their information.
Correction.
Updating.
Deletion.
Blocking.
Anonymization.
Restriction of processing.
Objection to certain uses.
Withdrawal of consent.
Portability.
Information about recipients.
Review of certain automated decisions.
Marketing opt-out.
Account closure.

These rights may be subject to exceptions.

For example, we may retain information when required to:

Complete a Transaction.
Meet a legal obligation.
Resolve a dispute.
Prevent fraud.
Defend rights.
Maintain tax records.
Protect security.

33. Exercising your rights

Users may send a request to:

hi@chuventures.com

The request should include:

Name.
Email address or telephone number associated with the account.
The right being exercised.
Information sufficient to locate the account.
A clear description of the request.

We may request additional information to verify identity before disclosing, changing or deleting information.

We will not request information unnecessary for verification.

We will respond within a reasonable period and in accordance with applicable law.

When we cannot fulfill a request, we will explain the reason unless prohibited by law.

34. Account deletion

Users may request account deletion through:

The function available within LaGanga.
A support request.
An email to hi@chuventures.com.

Account deletion may involve:

Profile deactivation.
Deletion or anonymization of unnecessary information.
Retention of required records.
Retention of order, payment, fraud or claim information.
Loss of access to purchases, sales and messages.

We may be unable to immediately delete information connected with a pending Transaction, debt, investigation or active claim.

35. Communication preferences

Promotional emails

Users may unsubscribe using the link included in the message.

Push notifications

Users may disable them through device or app settings.

SMS and WhatsApp

Users may follow the provided opt-out instructions or contact support.

Necessary communications

Users cannot opt out of communications necessary for:

Security.
Account administration.
Payments.
Orders.
Claims.
Legal changes.
Suspensions.

36. Device permissions

LaGanga may request access to:

Camera.
Microphone.
Photographs.
Videos.
Notifications.
Contacts.

Each permission will be used for its related function.

For example:

Camera and microphone for livestreaming.
Camera and photographs to update the profile photo.
On-device contacts to invite friends (we do not upload your address book to our servers).
Notifications for bid and order alerts.

We do not request device location permission. Shipping addresses are typed in manually.

Users may manage permissions through device settings.

37. Children

LaGanga is not directed to persons under eighteen years of age.

We do not allow minors to create accounts, purchase, sell, place bids or host livestreams.

We do not knowingly collect personal information from minors.

When we have reason to believe an account belongs to a minor, we may:

Suspend it.
Request age verification.
Delete information.
Cancel Transactions where possible.
Take protective action.

A parent or legal guardian who believes that a minor supplied information may contact us at hi@chuventures.com.

38. Third-party links and services

LaGanga may include links or integrations with third parties.

Those parties’ practices are governed by their own policies.

Chu Capital does not control the independent practices of:

Social networks.
App stores.
Payment processors.
Carriers.
Map services.
External websites.
Authentication providers.

Users should review those policies before supplying information.

39. Changes to this Policy

We may update this Policy to reflect:

New features.
Technical changes.
New providers.
Legal changes.
Changes to our practices.

The updated date will appear at the beginning.

When a change is material, we may provide notice through:

An in-app notice.
Email.
Website publication.
A new consent request where necessary.

Changes become effective on the stated date.

40. Language

This Policy may be published in Spanish and English.

In the event of an inconsistency, ambiguity or conflict, the Spanish version will control unless applicable law requires otherwise.

41. Contact

For privacy questions, complaints or requests: