Terms & Conditions

In these Terms and Conditions ("Terms"), the following definitions apply:

**"Zaminor"** or **"we"** refers to Zaminor B.V. (i.o.), a private limited liability company (besloten vennootschap), registered in the Netherlands, with its registered office in the Netherlands.

**"Platform"** refers to the Zaminor website (zaminor.com), mobile applications (iOS and Android), and all related digital services, APIs, and interfaces.

**"User"** or **"you"** refers to any natural person who creates an account on the Platform and uses the Services.

**"Services"** refers to the real estate mediation services provided by Zaminor, including but not limited to: identity verification, financial profiling, mortgage pre-check calculations, property matching and browsing, broker coordination and mediation, transaction case management, and document exchange.

**"Broker"** refers to a licensed real estate professional or agency in Spain or Dubai that is contracted by or partnered with Zaminor to assist Users with property viewings, negotiations, and transactions in the relevant jurisdiction.

**"KYC"** refers to Know Your Customer identity verification processes conducted to verify your identity for safety and security purposes.

**"Mediation Agreement"** refers to the separate agreement executed between Zaminor and a User when the User commits to a specific property transaction, setting out the mediation fee, scope of services, and mutual obligations for that transaction.

**"Business Day"** refers to any day other than a Saturday, Sunday, or public holiday in the Netherlands.

By creating an account on the Platform, you confirm that you have read, understood, and agree to be bound by these Terms, our Privacy Policy, and our Cookie Policy. If you do not agree, you must not use the Platform.

These Terms constitute a legally binding agreement between you and Zaminor B.V. (i.o.) under Dutch law. They govern your access to and use of the Platform and Services. In the event of a conflict between these Terms and a Mediation Agreement, the Mediation Agreement shall prevail with respect to the specific transaction it covers.

Zaminor may offer Services through different tiers (free and paid). The specific features and limitations of each tier are described on our pricing page and may change from time to time with prior notice.

Zaminor operates as a real estate mediation platform connecting Dutch and EU/EEA residents with properties in Spain and Dubai. Our Services include:

- **Identity verification:** Verifying your identity for the safety and security of all parties involved, including document verification and liveness checks. - **Financial assessment:** Analyzing your financial profile and performing indicative mortgage pre-check calculations based on market-specific lending rules (Spanish non-resident rules, Dubai non-resident rules). - **Property matching:** Curating property listings from our data providers (including Casafari) and broker network that match your criteria and indicative financial capacity. - **Broker mediation:** Connecting you with licensed local real estate brokers in Spain and/or Dubai for property viewings, negotiations, and transaction support. - **Transaction support:** Facilitating communication, document exchange, appointment scheduling, and coordination between all parties in a property transaction. - **Market information:** Providing market reports, regional guides, and cost estimates for informational purposes.

**Important disclaimers regarding the nature of our Services:** - Zaminor provides information and mediation services. Zaminor does not provide financial advice, investment advice, or mortgage advice. We do not directly buy, sell, lease, or develop real estate properties. - Zaminor is not a bank, mortgage lender, mortgage broker, or licensed financial advisor (beleggingsonderneming). Mortgage pre-check results are indicative calculations based on publicly available market rules and do not constitute financial advice, a mortgage offer, or a guarantee of financing. - Zaminor is not a law firm and does not provide legal advice. Any information regarding legal processes, taxes, or regulations in Spain or Dubai is for general informational purposes only. - Property listings displayed on the Platform are sourced from third-party providers and brokers. While we strive for accuracy, Zaminor does not guarantee the completeness, accuracy, availability, or timeliness of listing information, including prices, availability, and property specifications.

To use our Services, you must create an account. By registering, you represent and warrant that:

- You are at least 18 years of age and have full legal capacity to enter into binding agreements. - You are a resident of the Netherlands or another EU/EEA member state. - You are registering for personal use in connection with a genuine interest in acquiring real estate property. - All information you provide during registration and subsequent use of the Platform is accurate, complete, current, and not misleading. - You will promptly update your account information if any details change. - You will maintain the confidentiality of your account credentials (including passkey, OTP, and any other authentication factors) and are solely responsible for all activities under your account. - You will notify us immediately at hello@zaminor.com of any unauthorized access to or use of your account.

You may only maintain one account per person. Duplicate accounts may be merged or terminated at our discretion. Zaminor reserves the right to refuse registration, suspend, or terminate accounts that violate these Terms, provide false or misleading information, or fail identity verification.

To ensure the safety and security of all parties on the platform, Zaminor verifies the identity of all Users before providing certain Services. By using the Platform, you acknowledge and agree to the following obligations:

**Your obligations:** - Complete the identity verification process truthfully and in full, including providing: a valid, unexpired government-issued identification document (passport, national ID card, or residence permit); proof of current residential address (utility bill, bank statement, or official correspondence, not older than 3 months); source of funds documentation demonstrating the lawful origin of funds intended for property acquisition. - Submit to liveness verification checks (selfie-based identity confirmation). - Provide additional documentation if requested, which may be required based on various risk factors. - Notify us promptly (within 30 days) of any material changes to your personal information or financial situation. - Cooperate with periodic re-verification requests (at minimum every 12 months for ongoing business relationships).

**Consequences of non-compliance:** - Failure or refusal to complete identity verification will prevent you from accessing property matching, mortgage pre-check, broker mediation, and transaction support services. Your account will be limited to browsing only. - Providing false, misleading, or fraudulent information in connection with identity verification constitutes a material breach of these Terms and may result in immediate account termination, reporting to the relevant authorities, and potential criminal liability under Dutch law. - Zaminor may refuse to execute a transaction, suspend services, or terminate the business relationship if we are unable to complete satisfactory identity verification.

As a User of the Platform, you agree to:

- Use the Platform only for lawful purposes directly related to genuine real estate exploration and acquisition. - Provide accurate and truthful information in all communications, forms, documents, and declarations. - Not misrepresent your identity, financial situation, source of funds, or any other material fact. - Not use the Platform for money laundering, terrorist financing, tax evasion, fraud, or any other illegal activity. - Not attempt to circumvent security measures, access other users' data, reverse engineer the Platform, or interfere with Platform operations. - Not use automated tools, scrapers, bots, or crawlers to access the Platform without prior written authorization. - Not reproduce, distribute, modify, create derivative works from, or commercially exploit any Platform content without prior written consent. - Respect the intellectual property rights of Zaminor, its partners, brokers, and other Users. - Maintain a professional and respectful tone in all communications through the Platform. - Comply with all applicable laws and regulations in the Netherlands, Spain, Dubai/UAE, and any other relevant jurisdiction.

Zaminor reserves the right to immediately suspend or terminate your access, without prior notice or refund, if you breach any of these obligations or if we reasonably believe you are engaged in prohibited activities.

**7.1 Free tier.** Creating an account, browsing property listings, using the basic mortgage calculator, and accessing market information are available free of charge. The free tier may have limitations on the number of saved properties, searches, or feature access.

**7.2 Paid tiers.** Zaminor may offer premium subscription tiers with enhanced features, including but not limited to: priority broker matching, detailed financial analysis, expanded property alerts, and dedicated support. Subscription terms, pricing, and features for paid tiers are published on our pricing page and may be updated from time to time with at least 30 days' prior notice to existing subscribers.

**7.3 Subscription management.** Paid subscriptions are billed on a recurring basis (monthly or annually, as selected). Payment is processed through Stripe using iDEAL, credit card, or other supported methods. You may cancel your subscription at any time; cancellation takes effect at the end of the current billing period. No pro-rata refunds are provided for partial billing periods. All prices are in EUR and exclusive of VAT, unless otherwise stated.

**7.4 Mediation fees.** In addition to any subscription fees, Zaminor charges a mediation fee upon successful completion of a property transaction. The fee structure is: - Spain: 1.5% of the purchase price (minimum EUR 5,000) - Dubai: 2.0% of the purchase price (minimum AED 25,000) Mediation fees are payable upon signing of the purchase agreement (Spain: contrato de arras or escritura; Dubai: MOU or SPA) or equivalent binding document. Specific fee details, payment terms, and scope will be set out in the Mediation Agreement executed before you commit to a transaction.

**7.5 Third-party costs.** Costs such as notary fees, transfer taxes (ITP in Spain, DLD fees in Dubai), legal fees, mortgage arrangement fees, property valuation fees, and local broker commissions in the destination country are not included in Zaminor's mediation fee and are the User's responsibility. We will provide transparent, itemized cost estimates before you proceed with any transaction, but these estimates are indicative and may vary.

**7.6 Taxes.** All prices are exclusive of VAT where applicable. Dutch VAT at the applicable rate will be charged on mediation fees and subscription fees where required by law.

The Platform integrates with and references third-party services. You acknowledge and agree to the following:

**8.1 Property listings (Casafari and broker network).** Property listings displayed on the Platform are sourced from Casafari's aggregated real estate database and our network of brokers. Zaminor does not own, verify, or guarantee the accuracy of property information including but not limited to: listing price, availability, property dimensions, legal status, permits, or condition. You must conduct your own due diligence and rely on professional inspections and legal verification before committing to any property purchase.

**8.2 Broker services.** Brokers connected through the Platform are independent licensed professionals in their respective jurisdictions. Zaminor selects broker partners based on licensing, reputation, and professional standards, but does not employ, supervise, or control brokers' advice, actions, or omissions. Any engagement with a broker is subject to the broker's own terms of service and the local laws of the relevant jurisdiction (Spain or Dubai/UAE). Zaminor is not liable for broker performance, advice, or misconduct.

**8.3 Open banking (PSD2).** If you choose to connect your bank account via our PSD2 integration (Enable Banking), you authorize the secure, read-only retrieval of your bank account data (balances and transaction history) for the purpose of financial assessment. This data is processed in accordance with PSD2 requirements and our Privacy Policy. You may revoke access at any time through your bank's online banking interface or by contacting us.

**8.4 Payment processing (Stripe).** Payment processing is provided by Stripe Payments Europe, Ltd. By making payments through the Platform, you also agree to Stripe's Terms of Service and Privacy Policy.

All content on the Platform -- including but not limited to text, graphics, logos, trademarks, icons, images, software, source code, algorithms, database structures, design elements, and the overall look and feel of the Platform -- is the property of Zaminor B.V. (i.o.) or its licensors and is protected by Dutch and international copyright, trademark, patent, trade secret, and other intellectual property laws.

You are granted a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Platform for personal, non-commercial purposes in connection with our Services. This license does not permit you to: copy, modify, or distribute Platform content; remove or alter any proprietary notices; use the Platform for competitive analysis or to develop a competing product; or frame or mirror any portion of the Platform.

The Zaminor name, logo ("ZAMI" + "NOR"), and all related product and service names, slogans, and visual identities are registered or unregistered trademarks of Zaminor B.V. (i.o.) Use of these marks without express written permission is strictly prohibited.

**User-generated content.** By submitting content to the Platform (messages, documents, feedback), you grant Zaminor a non-exclusive, worldwide, royalty-free license to use, store, and process that content solely for the purpose of providing the Services. You retain ownership of your content and may request its deletion in accordance with our Privacy Policy.

To the maximum extent permitted by Dutch law (including Book 6, Articles 74-110 of the Dutch Civil Code):

**10.1 Indicative information.** Property listings, mortgage pre-check results, cost estimates, market data, and any other information provided on the Platform are for informational purposes only. While we strive for accuracy, Zaminor does not guarantee the completeness, accuracy, or timeliness of this information. You should not make financial or legal decisions based solely on information obtained from the Platform without seeking independent professional advice.

**10.2 No financial or legal advice.** Zaminor is not a licensed financial advisor (beleggingsonderneming), bank, mortgage lender, or law firm. Nothing on the Platform constitutes financial advice, legal advice, tax advice, a mortgage offer, or a guarantee of financing. Mortgage pre-check calculations are indicative estimates based on publicly available rules and do not account for individual credit assessments by lending institutions.

**10.3 Third-party actions.** Zaminor is not liable for the acts, omissions, advice, negligence, or misconduct of third-party brokers, notaries, legal advisors, mortgage providers, banks, government authorities, or any other party involved in a property transaction, except to the extent caused by Zaminor's own gross negligence or willful misconduct.

**10.4 Maximum liability.** Zaminor's total aggregate liability for all claims arising from or in connection with these Terms, the Services, or any Mediation Agreement shall not exceed the greater of: (a) the total fees (subscription + mediation) paid by you to Zaminor in the 12 months preceding the event giving rise to the claim; or (b) EUR 5,000.

**10.5 Excluded damages.** Zaminor shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to: loss of profits, loss of data, loss of business opportunities, loss of expected savings, reputational damage, or property value fluctuations, regardless of whether such damages were foreseeable or whether Zaminor was advised of their possibility.

**10.6 Mandatory liability.** Nothing in these Terms excludes or limits liability that cannot be excluded or limited under Dutch law, including: liability for death or personal injury caused by negligence; liability for fraud or fraudulent misrepresentation; liability under the Dutch Product Liability Act (productaansprakelijkheid); or any other liability that cannot be lawfully excluded.

You agree to indemnify, defend, and hold harmless Zaminor B.V. (i.o.), its directors, officers, employees, contractors, and agents from and against any claims, losses, damages, liabilities, costs, and expenses (including reasonable legal fees) arising from or in connection with:

- Your breach of these Terms or any applicable law or regulation. - Your provision of false, misleading, or fraudulent information, including in connection with KYC verification. - Your use of the Platform for any unlawful purpose. - Your violation of the rights of any third party. - Any tax, penalty, or regulatory fine imposed as a result of your actions or omissions in connection with a property transaction facilitated through the Platform.

This indemnification obligation survives the termination of your account and these Terms.

We process personal data in accordance with our Privacy Policy and applicable data protection laws, including the GDPR and the Dutch UAVG. By using our Services, you acknowledge that you have read and understood our Privacy Policy.

For identity verification purposes, personal data (including identity documents, source of funds records, and transaction data) will be retained for a minimum of 5 years after the end of the business relationship, as required by Dutch law. Transaction and fiscal records are retained for 7 years under the AWR Article 52. These retention obligations survive account termination and cannot be overridden by a deletion request.

You acknowledge that Zaminor may be required to process and retain your personal data beyond your account lifetime to comply with its statutory obligations, and that such processing does not constitute a breach of these Terms or the Privacy Policy.

**13.1 Termination by User.** You may terminate your account at any time by: (a) using the account deletion function in your account settings; or (b) sending a request to hello@zaminor.com. We will process termination requests within 5 Business Days. Termination does not affect: any obligations arising from active property transactions or Mediation Agreements; any outstanding payment obligations; or legal data retention requirements under Dutch law.

**13.2 Termination by Zaminor.** We may suspend or terminate your account, with or without prior notice, if: - You materially breach these Terms or any applicable law. - You fail identity verification. - You provide false, misleading, or fraudulent information. - We are required to do so by a regulatory authority, court order, or statutory obligation. - You have been inactive for more than 24 consecutive months (we will send a 30-day warning email before termination for inactivity). - We cease to offer the Services (with at least 90 days' prior notice).

**13.3 Effects of termination.** Upon termination: your right to access the Platform and Services ceases immediately; any active property transactions will be handled in accordance with the applicable Mediation Agreement; data will be retained as required by law and our Privacy Policy (Section 10 of the Privacy Policy); data not subject to statutory retention will be deleted or anonymized within 60 days of termination; you may request a copy of your portable data (Article 20 GDPR) before or within 30 days of termination.

**13.4 Survival.** The following provisions survive termination: Sections 5 (Identity verification obligations), 9 (Intellectual property), 10 (Limitation of liability), 11 (Indemnification), 12 (Data protection), 14 (Dispute resolution), and 15 (Governing law), as well as any accrued payment obligations.

**14.1 Informal resolution.** We encourage you to contact us first at hello@zaminor.com or hello@zaminor.com to resolve any dispute informally. We will make reasonable efforts to resolve your concern within 15 Business Days.

**14.2 Mediation.** If informal resolution fails within 30 days, either party may propose mediation through the Nederlands Arbitrage Instituut (NAI) or another mutually agreed mediation body. Mediation costs are shared equally unless otherwise agreed. Mediation does not prevent either party from seeking urgent interim relief from a competent court.

**14.3 Jurisdiction.** Any disputes that cannot be resolved through mediation shall be submitted to the exclusive jurisdiction of the competent courts of The Hague, the Netherlands, subject to your mandatory consumer protection rights under EU law.

**14.4 Consumer rights and ODR.** If you are a consumer resident of the EU/EEA, you may also use the European Commission's Online Dispute Resolution (ODR) platform at ec.europa.eu/odr. Additionally, nothing in these Terms affects your mandatory statutory consumer rights under Dutch law (Book 7, Title 1 of the Dutch Civil Code), EU consumer protection law, or any other non-waivable consumer protections.

**14.5 Limitation period.** Any claim arising from or in connection with these Terms must be brought within 2 years from the date on which the claimant became or ought reasonably to have become aware of the grounds for the claim, subject to the absolute limitation periods under Dutch law.

Zaminor shall not be liable for any failure or delay in performing our obligations under these Terms where such failure or delay results from circumstances beyond our reasonable control ("Force Majeure Event"), including but not limited to: natural disasters, pandemics, war, terrorism, government actions or sanctions, internet or telecommunications infrastructure failures, cyberattacks, power outages, failures of third-party service providers, or changes in applicable law or regulation that make performance unlawful or commercially impracticable.

In the event of a Force Majeure Event, we will: (a) notify affected Users as soon as reasonably practicable; (b) use reasonable efforts to mitigate the impact and resume normal operations; and (c) if the Force Majeure Event continues for more than 90 days, either party may terminate the affected Services without liability.

These Terms are governed by and shall be construed in accordance with the laws of the Netherlands, without regard to its conflict of law provisions.

The applicability of the United Nations Convention on Contracts for the International Sale of Goods (CISG) is expressly excluded.

Where you are a consumer, you also benefit from the mandatory provisions of the consumer protection laws of your country of habitual residence to the extent those provisions offer greater protection than Dutch law (in accordance with Article 6(2) of the Rome I Regulation).

If any provision of these Terms is held to be invalid, illegal, or unenforceable by a competent court, that provision shall be modified to the minimum extent necessary to make it valid and enforceable, or if modification is not possible, it shall be severed from these Terms. The remaining provisions shall continue in full force and effect.

No failure or delay by Zaminor in exercising any right, power, or privilege under these Terms shall operate as a waiver thereof, nor shall any single or partial exercise preclude any other or further exercise of that right or of any other right.

These Terms, together with the Privacy Policy, Cookie Policy, and any applicable Mediation Agreement, constitute the entire agreement between you and Zaminor B.V. (i.o.) with respect to the subject matter hereof. They supersede all prior or contemporaneous oral or written communications, proposals, and representations with respect to the Platform and Services.

No amendment to these Terms shall be effective unless made in accordance with Section 19 (Amendments).

Zaminor reserves the right to modify these Terms at any time. Material changes will be communicated via email to your registered email address and via in-platform notification at least 30 days before they take effect. The notification will clearly describe the nature and impact of the changes.

If you do not agree with the changes, you may terminate your account before the effective date in accordance with Section 13. Continued use of the Platform after the effective date constitutes acceptance of the modified Terms.

For questions about these Terms and Conditions:

**Zaminor B.V. (i.o.)** Registered in the Netherlands

**Legal inquiries:** hello@zaminor.com **General support:** hello@zaminor.com