First issued: April 30, 2026 · Last updated: May 2026
This notice is issued by POLIBIT, S.A.P.I. de C.V. (“PoliBit”), with address at Calle San Juan Capistrano, number 107, Fraccionamiento Nuevo Bernardez, Guadalupe, Zacatecas, Mexico, ZIP Code 98610, electronic address: https://www.polibit.io/ (the “Site”), and contact email address: admin@polibit.io (the “Privacy Email”), for the purpose of making known to any person who accesses or uses the Site or the Platform (the “User”) the use of cookies and similar technologies that PoliBit employs in them.
For purposes of this document, “cookies” shall mean the short files, normally consisting of letters and numbers, that are placed on the computer, tablet, telephone or similar device used by the User to access the Site; and “similar technologies” shall mean pixel tags, web beacons, clear GIFs, JavaScript and local storage that may be related to the Site or the Platform.
Access to and/or use of the Site implies that the User has been informed of these terms. However, non-essential cookies shall only be activated upon the User’s prior express consent through the cookie preferences management mechanism available on the Site (the “Cookie Banner”). If at any time the User does not agree with these terms, the User may revoke consent or configure the browser to reject cookies.
In order to provide the User with the best possible functionality of the Site and the Platform, and to deliver personalized information in the context of the cross-border fund operations platform, PoliBit may use cookies to collect data that enable it to provide analytical information, manage authenticated sessions and optimize the experience of the registered User (Limited Partner, fund manager or developer).
PoliBit, as the operator of the Site and the Platform, may place cookies on the device through which the User accesses them. Such cookies are referred to as “first-party” cookies. Cookies placed by service providers integrated into the Site or the Platform — such as identity verification services (KYC/AML), electronic signature, payment gateways and analytics tools — are referred to as “third-party” cookies. PoliBit does not control the use of this technology by such third parties or the resulting information, and is not responsible for any action or policy of such third parties.
By means of cookies, it is possible to obtain aggregated information that DOES NOT INDIVIDUALLY IDENTIFY Users (such as the operating system, browser version and originating URL, including browsing patterns within the LP Portal and the Management Portal) in order to improve the user experience and understand the patterns of use of the Platform. This technology is used as a tool to compile aggregated statistics on the use of the Site and the Platform, for analytics, performance and optimization purposes.
PoliBit may also use similar technologies, such as web beacons (also known as “tracking pixels” or “clear GIFs”). These are graphic files of very small size that contain a unique identifier which makes it possible to recognize a visit to the Site or to notify PoliBit when the User opens an email sent by PoliBit, including notices of Capital Calls, distributions, or documents generated by the Platform. These technologies generally rely on cookies for their proper functioning, so disabling cookies directly affects their operation.
PoliBit distinguishes between essential cookies and non-essential cookies based on their necessity for the operation of the Site and the Platform:
The User may modify or revoke consent at any time through:
Revocation of consent shall not affect the lawfulness of any processing carried out prior to such revocation. PoliBit shall keep a record of the consent granted by the User in accordance with applicable requirements.
PoliBit may use one or more of the following types of cookies:
Required for the proper functioning of the Site and the Platform. They allow the User to authenticate and access the LP Portal, the KYC/AML module, the Capital Calls and distributions panel, and the other restricted areas of the Platform. Disabling these cookies will prevent authentication in the Portal and will render the essential functionalities of PoliBit’s SaaS service unavailable.
Designed to analyze the User’s activity on the Site, the Platform and the digital channels where PoliBit publishes content (blog, resources, glossary), in order to optimize the browsing experience and measure the performance of the platform. They make it possible to count visitors, analyze usage flows within the Platform (onboarding, fund dashboard, reporting), and measure the performance of institutional marketing initiatives.
Used to recognize the User when accessing or returning to the Site and the Platform, personalizing content according to the User’s profile (LP, fund manager or developer). They allow the Portal to remember preferences configured by the User, including registered name, display currency (MXN, USD, BRL, EUR), language and jurisdiction.
Used to present institutional PoliBit content relevant to the visitor based on online activity and apparent interest in cross-border investment fund operation services (private equity, real estate or private debt funds in Latin America and the United States). They enable PoliBit to run B2B marketing campaigns targeted at fund managers, developers and family offices interested in the Platform, through proprietary or third-party digital channels.
Cookies may be classified according to their persistence on the User’s device as follows:
| Type | Description | Duration | Example duration |
|---|---|---|---|
| Session | Activated upon accessing the Site and automatically deleted when the browser is closed. | Temporary | Until the session is closed |
| Persistent — Preferences | Store User preferences (currency, language, jurisdiction, dashboard views). | Persistent | Up to 12 months |
| Persistent — Analytics | Retain information on the frequency and patterns of use of the Platform (Capital Calls, Distributions, KYC/AML). | Persistent | Up to 24 months |
| Persistent — Marketing | Measure the effectiveness of institutional marketing and lead-generation efforts. | Persistent | Up to 12 months |
The use of cookies enables PoliBit to collect certain User data for the following purposes:
The User’s registration of personal information on the Site and the Platform allows PoliBit — by associating such information with other information collected through integrated service providers (identity verification, payment gateways, regulatory compliance services) — to use such information for operational analytics and institutional marketing purposes, always on a statistical and non-individualized basis.
PoliBit integrates third-party services into its Site and Platform that may place their own cookies on the User’s device. The functional categories of such providers, together with the purpose of their cookies, are described below. The updated list of specific providers is available to Users upon request addressed to admin@polibit.io. This list may be updated periodically as the technological integration of the Platform evolves:
| Provider | Purpose | Additional information |
|---|---|---|
| Web analytics provider | Web analytics: traffic measurement, user behavior and Site performance. | Available upon request |
| Electronic signature provider (USA) | Electronic signature of Platform documents (subscriptions, capital calls). Jurisdiction: United States. | Available upon request |
| KYC/AML provider (EU) | Identity verification and compliance: screening against international sanctions lists (OFAC, UN, EU), Politically Exposed Persons (PEPs) and adverse media. Jurisdiction: European Union (GDPR). | Available upon request |
| Cross-border payments provider (USA) | Cross-border payment processing and settlements in stablecoin. Jurisdiction: United States. | Available upon request |
| Card processing provider (Global) | Credit and debit card payment processing. Jurisdiction: United States / Global. | Available upon request |
| Institutional communications provider (EU) | Institutional communications and email marketing. Jurisdiction: European Union (GDPR). | Available upon request |
PoliBit does not control the cookies placed by these third parties, nor is it responsible for their privacy practices. The User is advised to review the privacy policies of each provider directly for further detail.
The User has the following mechanisms available to manage cookie preferences:
The Cookie Banner available on the Site allows the User to select the categories of cookies to activate (essential, analytics, functionality and/or advertising). This configuration may be modified at any time by accessing the cookie preferences panel within the Site.
The User may also manage or disable cookies directly from the browser configuration. The configuration paths for the most common browsers are indicated below:
For more detailed instructions on managing cookies across different browsers and devices, the User may consult resources such as: www.allaboutcookies.org.
PoliBit states that the User’s blocking of all cookies may result in the inability to authenticate in the LP Portal, access the Management Panel or use the KYC/AML, Capital Calls and Distributions modules, fully or partially affecting access to and use of the service. Additionally, even if the User disables third-party cookies at the browser level, PoliBit cannot guarantee that such third parties will not operate with other tracking technologies under their own terms.
To the extent that the cookies used by PoliBit involve the processing of personal data — particularly when associated with the information of the User registered on the Platform — such processing shall be governed by the provisions of PoliBit’s Privacy Notice, available at https://www.polibit.io/privacy-policy, and by the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP) and its Regulations.
The User has the right to exercise the rights of Access, Rectification, Cancellation and Objection (“ARCO rights”) with respect to the personal data processed through cookies, by submitting a request addressed to the Privacy Email: admin@polibit.io, including the following information:
PoliBit shall respond to requests for the exercise of ARCO rights within a maximum period of twenty (20) business days from receipt, in accordance with the provisions of the LFPDPPP. For data subjects located in the European Union, in addition to the ARCO rights, the right to data portability provided for in Article 20 of the GDPR shall apply, under which the data subject may request to receive personal data in a structured, commonly used and machine-readable format, and transmit such data to another data controller.
The processing of personal data derived from the use of cookies is based on the following regulatory instruments applicable in Mexico and, where applicable, in the jurisdictions where PoliBit operates or provides services:
The User acknowledges that, by granting consent through the Cookie Banner and/or by accessing and using the Site, the User expresses full and unreserved acceptance of the version of these terms published at the time of accessing the Site, pursuant to articles 1803 and 1834 Bis of the Federal Civil Code, 80, 81, 89 and other related and applicable articles of the Commercial Code. It is the sole and exclusive responsibility of the User to read these terms and their modifications each time the User accesses the Site.
If at any time the User does not agree, in whole or in part, with these terms, the User must refrain from accessing and using the Site, or revoke consent through the mechanisms described in Section 7 of this document.
The User acknowledges and accepts that PoliBit has made available all the information necessary to understand the scope and characteristics of the Site and the Platform. Likewise, the User states that, prior to accessing the Site and the Platform, the User analyzed their characteristics and agrees with them.
Any questions or comments regarding the use of cookies by PoliBit may be addressed to the Privacy Email: admin@polibit.io. When submitting a request, the User must include contact information, the name of the PoliBit website and a detailed description of the request or concern related to cookies.
This Cookies Policy is published in Spanish and English versions. The Spanish version is the binding version. The English version constitutes a courtesy translation for international Users and Managers. In the event of any discrepancy between the two versions, the Spanish version shall prevail.