DSA Compliance Policy

You are reading the English-language version of this document. This translation is provided for informational purposes only. The legally binding version, which takes precedence in the event of any dispute, is the original Portuguese version.

Digital Services Act (DSA) Compliance Policy

This Digital Services Act Compliance Policy (“DSA Policy”) sets out the obligations, procedures, and internal controls of THEPREPLAN, LDA (Tax ID/NIF 519232828, registered office at Praça Alexandre Herculano, 22, 4 B, Sé e São Pedro, Faro), as the entity responsible for the thepreplan.com platform, under Regulation (EU) 2022/2065 on a Single Market For Digital Services (“Digital Services Act” or “DSA”), applicable in Portugal since 17 February 2024.

thepreplan.com operates as:

• An intermediary hosting service, allowing real estate developers to store content (text, images, documents) on servers under thepreplan.com’s control; and

• An online platform, insofar as it disseminates to the public information about pre-construction real estate projects, at the request of developers, through its online interface.

This Policy applies to all operations, staff, and service providers of thepreplan.com involved in the design, development, operation, and support of the platform, as well as in content moderation and relationships with users, developers, and authorities.

Whenever thepreplan.com ceases to meet the thresholds for a micro or small enterprise within the meaning of the DSA, this Policy will be updated to reflect any additional obligations.

In accordance with Article 11 of the DSA, thepreplan.com designates single points of contact for:

• Regulatory and law-enforcement authorities, including ANACOM (the Digital Services Coordinator in Portugal), other competent national authorities, and competent judicial authorities of the EU;

• Platform users (Developers and Visitors).

The details of these points of contact include, at a minimum:

• Name/Position: Rabi Yassin — CFO

• Email: support@thepreplan.com

• Languages: Portuguese and English

This information is published in an easily accessible location on the website (for example: /legal/dsa-contact) and in the Terms and Conditions, and is kept permanently up to date.

All DSA-related communications received at these addresses are logged internally for compliance purposes.

Should thepreplan.com not be established within the European Union, a legal representative in the Union will be designated under Article 13 of the DSA, whose details will likewise be made public and communicated to the competent authorities.

As thepreplan.com is established in Portugal, this point does not currently apply, but the legal position will be reassessed whenever the business model or corporate structure changes.

In accordance with Article 14 of the DSA, thepreplan.com’s Terms and Conditions of Use clearly and accessibly describe:

Restrictions on use of the platform, including:

• Types of content prohibited because they are illegal under European Union or Portuguese law (for example: fraud, money laundering, terrorist financing, discrimination, incitement to violence, copyright infringement);

• Types of content prohibited for breaching thepreplan.com’s internal policies (for example: content that is misleading as to the characteristics of a development, false information about licenses or permits, manipulated reviews, spam).

Content moderation policies, including:

• Criteria and processes for removal, restriction, de-indexing, demotion, or other impact on content visibility;

• Criteria and processes for suspending or terminating Developer accounts; indication of when automated moderation or algorithmic assistance is used, and the associated error rate and human oversight.

Available complaint and appeal mechanisms, both internal (complaint-handling system — see section 11) and external (out-of-court dispute resolution bodies and ANACOM).

Use of recommender systems, including:

• The main parameters used to rank or recommend content;

• The options available to users to modify such parameters.

The impact of these policies on users’ fundamental rights, including freedom of expression, data protection, and non-discrimination, and how these rights are taken into account in content moderation.

The Terms and Conditions are made available in Portuguese and English, in an accessible format and, wherever practicable, in line with accessibility standards for people with disabilities.

Any material change to these matters is communicated to Developers with at least 15 days’ prior notice, except where necessary to comply with a legal order or to mitigate a serious and unforeseen risk, in which case the change may be immediate, with notification given as soon as possible.

thepreplan.com will comply, without undue delay, with any order to remove, disable, or restrict access to illegal content, issued by the competent judicial or administrative authorities of a Member State or of the European Union, and with any order to provide specific information about one or more recipients of the service (including Developers), issued by such authorities.

The point of contact for authorities must:

• Verify the authenticity and competence of the issuing authority and the territorial scope of the order;

• Confirm receipt of the order to the issuing authority within a reasonable time;

• Coordinate the technical execution of the order internally;

• Ensure that the order, its execution, and any associated communications are logged.

Where an order relates to content from a Developer, thepreplan.com will, unless legally prohibited from doing so, notify the Developer with:

• a copy or summary of the order;

• an indication of the legal basis;

• the nature of the measure taken and its effects (removal, blocking of access, de-indexing, etc.);

• information about the appeal mechanisms available.

In accordance with Article 16 of the DSA, thepreplan.com provides a clear and accessible mechanism for any individual or legal entity to notify potentially illegal content hosted on the platform.

Reports may be submitted through an online form accessible from project pages (for example, a “Report illegal content” button) or to the dedicated email address support@thepreplan.com.

The mechanism is easy to use, free of charge, and does not require account creation.

A valid notification must contain, at a minimum:

• A sufficiently substantiated explanation of the reasons why the content is considered illegal, referring, wherever possible, to the applicable legal provisions;

• A clear indication of the electronic location (URL) or other precise reference allowing the content in question to be located;

• The name and email address of the notifying party (except in specific situations of serious crime where the law permits or recommends anonymity);

• Confirmation that the notifying party believes, in good faith, that the information provided is accurate and complete.

Whenever a notification contains the minimum elements listed above, thepreplan.com considers itself to have obtained actual knowledge of the notified content and acts promptly and diligently.

Upon receiving a valid notification, thepreplan.com will:

• Acknowledge receipt within 2 business days;

• Assess the completeness, validity, and plausibility of the notification within 5 business days;

• Make a decision — to remove, restrict, or retain the content — within 10 business days for standard notifications, or within 24 hours for notifications concerning illegal content that endangers the life or safety of persons;

• Notify the Developer of any measure taken, including specific reference to the legal provision and/or clause of the Terms and Conditions on which the decision is based, the nature of the measure adopted, whether it results from an order of a public authority (with identification of that authority, unless legally prohibited), and the appeal mechanisms available;

• Notify the reporting party of the decision and of their right to lodge a complaint through the internal complaint-handling system and/or with the competent authorities;

• Log the notification and the measure taken in internal compliance records.

Whenever a notification reveals information giving rise to a reasonable suspicion of a serious criminal offense involving a threat to life or safety, thepreplan.com will promptly inform:

• The competent Portuguese law-enforcement authorities (the Public Prosecutor’s Office or the Judicial Police); and

• ANACOM, as the Digital Services Coordinator in Portugal.

Where ANACOM or another Digital Services Coordinator designates entities as trusted flaggers with competence over content relevant to thepreplan.com’s activity, thepreplan.com will:

• Maintain and update internally a list of recognized trusted flaggers;

• Give priority treatment to notifications from these flaggers, through a dedicated channel, ensuring swift and preferential review;

• Keep prominent records of decisions relating to trusted flagger notifications.

In accordance with Article 30 of the DSA, before activating any Developer listing on the platform, thepreplan.com will collect, verify, and retain the following information, where applicable:

• The full legal name of the company and any trading names;

• Commercial registration number and Tax ID (NIF);

• Registered office and, where different, a postal contact address;

• Contact email address and telephone number;

• Identification of the responsible legal representative (name, position, professional contact details);

• Reference to any relevant sectoral registrations or authorizations (for example, IMPIC registration, construction license issued by the competent authority, where applicable);

• Bank account details used for service billing purposes (where relevant);

• A declaration on the Developer’s honor that it is not subject to an EU-wide prohibition on offering the services in question, and that it will provide only truthful, complete, and up-to-date information.

thepreplan.com will make reasonable efforts to verify this information, using, in particular, public registers and, where applicable, supporting documentation provided by the Developer.

A summary of the Developer’s identity — including, at a minimum, its legal name, country of establishment, and, where possible, a reference to its commercial or sectoral registration — will be displayed on all project listing pages visible to Visitors.

Where a Developer provides identity information that is false, incomplete, outdated, or misleading:

• thepreplan.com may immediately suspend the account and all associated listings;

• The matter may be reported to ANACOM and, where relevant, to sectoral regulatory or law-enforcement authorities.

Whenever thepreplan.com uses algorithms to rank, order, or recommend project listings to Visitors (for example, in search results or featured listings), the platform must:

• Clearly inform users that recommender systems are being used, and in which parts of the interface (for example, “Projects recommended for you”);

• Explain, in plain language, the main parameters used to determine ranking or recommendations (for example, subscription tier, listing completeness, recency, geographic relevance, popularity);

• Offer users, wherever technically feasible, at least one option to view listings that is not based on profiling, such as chronological order or ordering by geographic distance from the project location, without behavioral profiling;

• Never use special category personal data, as defined in Article 9 of the GDPR, as a ranking or targeting parameter.

The current default ranking logic will be described transparently in the interface and in this Policy, and updated whenever material changes occur.

Should thepreplan.com be classified as a “very large online platform,” additional obligations regarding recommender systems will apply, requiring revision of this section.

In accordance with Article 26 of the DSA, all advertising displayed on the platform must be clearly identified as such and must disclose, in real time, to each user:

That the content constitutes advertising or a sponsored placement (including clear visual labeling, such as “Ad” or “Sponsored”);

The identity of the Developer or advertiser on whose behalf the advertisement is displayed;

The identity of the entity that paid for the advertisement, if different from the above;

The main parameters used to determine why this particular advertisement was shown to that specific user and, where relevant, how to change such parameters.

Additionally:

• thepreplan.com does not use targeting based on special categories of personal data;

• Advertising is not specifically directed at minors, in accordance with the safeguards for the protection of minors provided for in the DSA.

A feature will be provided allowing Developers to indicate whether the content they upload constitutes commercial communication, ensuring that this indication is reflected in the interface shown to Visitors.

In accordance with Article 23 of the DSA, thepreplan.com will suspend — for a reasonable period, following prior warning — Developers who frequently provide manifestly illegal content, or who submit manifestly unfounded or abusive notifications or complaints.

The suspension procedure includes, in particular:

First occurrence of manifestly illegal content or a manifestly unfounded notification/complaint: issuance of a written warning clearly identifying the conduct; removal of the content (where applicable).

Second occurrence within the following 12 months: 30-day suspension of listing publication rights.

Third occurrence within the following 12 months: permanent suspension of the account; possible referral to ANACOM and other competent authorities.

Suspensions are communicated to the Developer with an indication of the grounds (including legal and contractual references) and of the right of appeal through the internal complaint-handling system and/or through the courts.

In accordance with Article 20 of the DSA, thepreplan.com provides an accessible, free internal complaint-handling system for:

Developers contesting a content moderation decision (removal, restriction, demotion, de-indexing, suspension, or termination of an account);

Visitors contesting a decision not to act on their notification of illegal content.

Complaints must be submitted to support@thepreplan.com, within 30 days of the communication of the decision.

thepreplan.com will:

• Acknowledge receipt of the complaint within 3 business days;

• Review the decision with due care, where possible by staff other than those who made the original decision;

• Issue a reasoned response within 15 business days, or, in particularly complex cases, within a reasonable time, duly explained to the complainant;

• Reverse, uphold, or amend the original decision and communicate the response with legal and factual grounds.

Complainants who remain dissatisfied may refer the matter to a certified out-of-court dispute settlement body or to ANACOM, without prejudice to the right to bring proceedings before the courts.

thepreplan.com undertakes to:

• Not use deceptive or manipulative interface designs (“dark patterns”) that could distort or undermine users’ freedom of choice, including with regard to consents, subscriptions, and cancellations;

• Ensure that options to accept or decline certain features (such as the use of certain recommendation parameters) are presented clearly, symmetrically, and intelligibly;

• Ensure that cancelling or terminating an account is as simple as creating one, without unnecessary steps or artificial obstacles;

• Ensure, wherever reasonably practicable, that the interface is accessible to people with disabilities, in line with relevant European Union and national legislation.

In accordance with Article 15 of the DSA and, as an online platform, with the specific rules of Article 24, thepreplan.com will publish a Transparency Report, at least once a year, covering, at a minimum:

• The number of notifications of illegal content received, broken down by type of alleged illegality and country of origin, and the measures taken (removal, restriction, no action);

• The number of Developer account suspensions and terminations, with a summary of the respective grounds;

• The number of internal complaints received, the type of decision contested, and the outcomes obtained (decisions upheld, amended, or reversed);

• A description of the use of automated content moderation tools, including the data analyzed, objectives, safeguards, and any known error rates;

• Any orders received from Portuguese or European Union authorities to act against illegal content or to provide information about users, with aggregate statistics (number, type of authority, types of content).

The Transparency Report will be published at www.thepreplan.com/transparency and submitted to ANACOM whenever required by applicable law.

In accordance with Article 24 of the DSA, thepreplan.com:

• Regularly calculates the average monthly number of active recipients of the service in the European Union, based on the preceding six months, in accordance with the methodology established by the European Commission;

• Keeps records of the data and criteria used in this calculation, so as to be able to demonstrate the methodology to ANACOM and the Commission, if requested;

• Will publish, if and to the extent this becomes mandatory, the aggregate average monthly number of active recipients, as well as any communication to authorities regarding the exceeding of relevant thresholds.

thepreplan.com maintains internal records documenting:

• all notifications of illegal content received;

• the content moderation measures taken;

• the internal complaints handled and their outcomes;

• interactions with authorities (including orders received and their execution);

• suspensions or terminations of Developer accounts under this Policy.

Records are kept for a minimum period of 6 months, or longer where required by law, and may be made available to ANACOM or other competent authorities upon request.

All staff and service providers involved in content moderation, review of reports and complaints, Developer onboarding and verification, the design of recommender and advertising systems, and customer support on DSA matters, receive appropriate training on DSA obligations before taking up these functions, as well as periodic refresher training or training whenever there is a material change to the legal framework or internal policies.

Training records (dates, content, trainees, trainers) are retained for audit purposes.

This DSA Policy will be reviewed at least annually and whenever there is a material change to the platform’s services, to applicable legislation, or to guidance from ANACOM or the European Commission relevant to thepreplan.com.

The legal and compliance team is responsible for maintaining and updating this Policy and coordinates with the Product, Technical, and Operations teams to ensure that changes are effectively reflected on the platform.

© 2026 THEPREPLAN, LDA — thepreplan.com