Privacy Policy

1. Introduction and Scope

PE BIM LLC, a California limited liability company with Federal Employer Identification Number (EIN) 41-5256539, headquartered in Chula Vista, California, United States of America (“PE BIM,” “we,” “us,” or “our”), operates the online BIM marketplace platform “Proyecto Ejecutivo BIM,” accessible at www.proyectoejecutivo.comand its subdomains (the “Platform”).

This Privacy Policy explains how we collect, use, disclose, and safeguard personal information from users of the Platform (“you,” “your,” or “consumer”), including visitors, registered Creators, Specialists, and Clients. It describes your rights under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act (CPRA), the EU General Data Protection Regulation (GDPR) for users in the European Economic Area, and other applicable laws.

By accessing or using the Platform, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy.

2. Categories of Personal Information We Collect

In the preceding twelve (12) months, we have collected the following categories of personal information, as defined in California Civil Code §1798.140(v):

We do not usesensitive personal information to infer characteristics about consumers, and therefore no right to limit use and disclosure of sensitive personal information under CPRA §1798.121 arises beyond what is described in this Policy.

3. Sources of Personal Information

We collect personal information from the following sources:

1. Directly from you, when you register, upload content, make a purchase, contact support, or otherwise interact with the Platform.
2. Automatically, through cookies, pixels, server logs, and similar technologies when you access the Platform.
3. From third-party service providers, including Stripe (payment verification), Supabase (authentication), and Mailchimp (email engagement metrics).
4. From public records, when we verify professional credentials through the Mexican SEP National Registry of Professionals or, for Baja California pilot users, through the RETYS system.

4. Business and Commercial Purposes for Collection

We use personal information for the following purposes:

1. Account creation and management: verifying your identity, maintaining your account, and providing customer support.
2. Service delivery: enabling BIM model listings, automated Level of Development (LOD) review through the Anthropic Claude API, marketplace transactions, and secure 72-hour signed download links.
3. Payment processing: facilitating transactions through Stripe, Inc. and disbursing funds under escrow arrangements.
4. Fraud prevention: generating and retaining SHA-256 file fingerprints to detect duplicates, unauthorized reuse, and fraudulent uploads.
5. Legal compliance: meeting obligations under California, United States federal, Mexican, and other applicable laws, including tax reporting and responses to lawful governmental requests.
6. Marketing communications: sending newsletters, product updates, and promotional offers (you may opt out at any time).
7. Analytics and improvement: measuring usage, improving features, and developing new services.
8. Dispute resolution: addressing claims, complaints, and arbitration proceedings before JAMS in San Diego, California.

5. Disclosure of Personal Information to Third Parties

We share personal information with the following categories of service providers and third parties, each of whom is contractually obligated to maintain confidentiality and use the information only for the purposes we specify:

We may also disclose personal information to: (i) government authorities when required by law, subpoena, or court order; (ii) legal, accounting, and tax advisors under confidentiality obligations; and (iii) acquirers or investors in the event of a merger, acquisition, sale of assets, or corporate restructuring of PE BIM LLC.

6. Retention of Personal Information

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with our legal obligations, as follows:

• Account data: while the account is active and for five (5) years after account closure, for contractual, tax, and dispute-resolution purposes.
• Transactional records: a minimum of seven (7) years, to comply with California and Mexican tax requirements.
• Anti-fraud fingerprints (SHA-256):retained indefinitely for the protection of the original Creator's intellectual property, even after account closure.
• Marketing data: until you opt out or the contact becomes inactive for twenty-four (24) months.
• Technical and log data: up to twelve (12) months.

7. Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights regarding your personal information, subject to certain exceptions:

1. Right to Know what personal information we have collected, used, disclosed, and sold or shared about you.
2. Right to Delete personal information we have collected from you, subject to legal exceptions.
3. Right to Correct inaccurate personal information we maintain about you.
4. Right to Opt-Out of the sale or sharing of personal information (we do not sell or share, but this right is preserved by law).
5. Right to Limit Use and Disclosure of Sensitive Personal Information to purposes necessary for the services.
6. Right to Non-Discrimination for exercising any CCPA/CPRA right; we will not deny you services, charge different prices, or provide a different level of quality.
7. Right to Portability of your personal information in a readily usable format.

How to exercise your rights: submit a verifiable consumer request to privacy@proyectoejecutivo.com. We will respond within forty-five (45) daysand may extend by an additional forty-five (45) days with notice, consistent with 11 CCR §7021. We may require you to verify your identity before processing the request.

You may designate an authorized agentto submit requests on your behalf by providing written permission. We may require the consumer to verify their identity and confirm the agent's authority.

8. California Shine the Light Law

Under California Civil Code §1798.83, California residents may request a list of third parties to whom we have disclosed personal information for their direct marketing purposes during the preceding calendar year. To make such a request, please contact privacy@proyectoejecutivo.com. PE BIM does not currently disclose personal information to third parties for their own direct marketing purposes.

9. Your Rights Under the GDPR (EEA/UK/Switzerland)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the following rights under the GDPR:

1. Right of access(Art. 15) — to obtain confirmation and a copy of your data.
2. Right to rectification(Art. 16) — to correct inaccurate data.
3. Right to erasure(Art. 17) — “right to be forgotten” in certain circumstances.
4. Right to restriction of processing (Art. 18).
5. Right to data portability (Art. 20).
6. Right to object (Art. 21), including to direct marketing.
7. Right not to be subject to automated decision-making with legal effects (Art. 22); our LOD review is assistive and reviewable by human.
8. Right to withdraw consent at any time, without affecting the lawfulness of prior processing.
9. Right to lodge a complaint with a supervisory authority in your Member State.

Legal bases for processing (Art. 6 GDPR): (i) performance of a contract (account, marketplace transactions); (ii) compliance with legal obligations (tax, anti-fraud); (iii) legitimate interests (platform security, analytics); and (iv) consent (marketing communications, non-essential cookies).

International transfers. Because PE BIM LLC is headquartered in the United States, personal information of EEA/UK/Swiss users will be transferred outside the EEA. We implement appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission with our sub-processors where applicable.

10. Children's Privacy

The Platform is not directed to children under the age of 16, and we do not knowingly collect personal information from children under 16 without verifiable parental or guardian consent, in compliance with the Children's Online Privacy Protection Act (COPPA), CCPA §1798.120(c), and GDPR Art. 8. If we learn that we have collected personal information from a child under 16 without such consent, we will delete it promptly. Parents or guardians who believe their child has provided personal information without consent may contact privacy@proyectoejecutivo.com.

11. Security Measures

We implement technical and organizational measures appropriate to the risk, including encryption in transit (TLS 1.2+), encryption at rest via Supabase AWS infrastructure, row-level security (RLS) policies, SHA-256 fingerprinting, access controls, logging, and regular security reviews. However, no method of transmission or storage is perfectly secure; we cannot guarantee absolute security.

12. Cookies and Tracking Technologies

We use cookies, web beacons, local storage, and similar technologies for: (a) strictly necessary purposes (session, authentication, security); (b) functionality (language and user preferences); (c) analytics (PostHog or equivalent); and (d) marketing (campaign attribution). You may manage preferences through our cookie banner on first visit, or through your browser settings. We honor Global Privacy Control (GPC) signals under CCPA as an opt-out of sale/sharing.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the Platform. We will post the updated Privacy Policy at www.proyectoejecutivo.com/privacy-policy at least thirty (30) days before it becomes effective. Material changes will be notified by email to registered users.

14. Contact Information

To exercise your rights, ask questions, or file a complaint about this Privacy Policy, please contact us:

Residents of the EEA/UK/Switzerland may also lodge a complaint with their local data protection supervisory authority.