Everlay Group | Investment Holding

Privacy Notice

EVERLAY GROUP, LLC (hereinafter, “Everlay”) is committed to the protection of personal data and the privacy of the Users, partners, suppliers, potential customers and other third parties with whom it maintains a legal or commercial relationship, in compliance with the Federal Law on the Protection of Personal Data Held by Private Parties, published in the Official Gazette of the Federation on March 20, 2025 (the “Law”), and the other provisions that may be applicable. For this reason, it makes available to you this Privacy Notice (the “Privacy Notice”).

Capitalized terms not defined in this Privacy Notice shall have the meaning ascribed to them in the Terms and Conditions of the website https://everlay.com (the “Website”).

Controller and Domicile

Everlay Group, LLC, with a domicile at 7480 SW 40th St, Suite 810, Miami, Florida 33155, United States of America, is responsible for the processing of your personal data. For any matter related to your personal data or to this Privacy Notice, you may contact us at the email address legal@zorya.com

Personal Data We Collect

The User may browse the Website without providing personal data. However, when the User decides to contact us voluntarily through the contact form, by email or by any other means that the Website makes available, we may collect the following identification and contact personal data:

Full name;
Name of the company or organization, where applicable;
Email address and/or telephone number;
Country and, where applicable, city; and
The content of the inquiry, comment or request that the User decides to communicate to us.

Likewise, as a result of browsing the Website, we may automatically collect technical and browsing information of the device from which it is accessed, as described in the “Cookies and Similar Technologies” section of this Privacy Notice.

The Website is not designed to collect sensitive personal data. The User must refrain from providing sensitive personal data through the Website or by any other means.

Purposes of the Processing

Primary purposes. Your personal data will be processed for the following purposes, necessary to handle your request and for the legal relationship with Everlay, the processing of which does not require your additional consent:

To handle and respond to your inquiries, comments and contact requests;
To maintain communication with the User regarding such requests;
To operate, administer and safeguard the security of the Website;
To comply with the applicable legislation and to respond to the requests of competent authorities; and
To exercise or defend the rights and interests of Everlay.

Secondary purposes. Additionally, and provided that the User does not express their objection, we may process your data to generate statistics and internal analysis aimed at improving the Website, as well as to send you institutional information and news about Everlay.

If the User does not wish for their personal data to be processed for the secondary purposes, they may express their objection by sending their request to the email address legal@zorya.com The objection to the secondary purposes shall not be grounds to deny the handling of your request nor shall it affect the legal relationship with Everlay.

Cookies and Similar Technologies

The Website uses cookies and similar storage technologies (collectively, the “Cookies”). Cookies are small text files that are stored in the browser of the User's device and that allow such device to be recognized and information to be collected when the Website is accessed.

Through Cookies we may collect information such as the type of browser and operating system, the IP address, the pages consulted, the duration of the session and the User's configuration preferences. Such information is used to: (i) enable the operation and security of the session; (ii) remember the User's preferences; (iii) measure the performance of the Website; and (iv) generate usage statistics.

According to their purpose, the Cookies we use may be classified into:

Technical or necessary Cookies: essential for the operation and security of the Website;
Preference or functional Cookies: allow the User's options and preferences to be remembered;
Performance or analytics Cookies: allow the use of the Website to be measured and improved; and
Third-party Cookies: installed by analytics providers or social networks, which are governed by the privacy policies of such third parties.

The User may configure their browser so that Cookies are not stored, so that it requests authorization on each occasion, or to delete previously stored Cookies; each browser offers different options for this. Please note that disabling certain Cookies may limit or prevent the proper functioning of some sections or functionalities of the Website. By continuing to browse the Website without disabling the Cookies, the User consents to their use on the terms indicated herein.

Social Networks

The Website may include links to social networks or third-party platforms (such as Facebook, Instagram, X or LinkedIn, among others). Everlay does not control such platforms nor does it establish their privacy settings, and therefore we recommend that the User review the respective privacy notices before providing their data. Everlay shall not be responsible for the processing that such platforms carry out of the data that the User voluntarily provides on them.

Transfers of Personal Data

Everlay may transfer your personal data, without requiring your consent in accordance with the cases provided for in the Law, to:

Holding, subsidiary or affiliated companies of the same corporate group of Everlay that operate under the same internal processes and policies, for administrative and support purposes;
Competent administrative or judicial authorities, where the transfer is legally required or necessary for the recognition, exercise or defense of a right; and
Advisors or suppliers that provide services to Everlay and that process the data on its behalf and in accordance with its instructions, in which case such communications constitute remissions and do not require your consent.

Since Everlay is an entity incorporated in the United States of America, the processing of your personal data may involve its transfer to, or access from, jurisdictions other than the United Mexican States. In such cases, Everlay adopts adequate safeguards so that your data maintains a level of protection equivalent to that provided for in the Law.

ARCO Rights, Revocation and Limitation of Use

The User, as data subject, has the right to access, rectify, cancel or object to the processing of their personal data (the “ARCO Rights”), as well as to revoke the consent granted and to limit the use or disclosure of their data. To exercise any of these rights, they must send their request to the email address legal@zorya.com, enclosing the information and documentation evidencing their identity or representation, as well as a clear description of the data and of the right they wish to exercise. Everlay will handle your request within the periods and on the terms provided for in the Law.

The revocation of consent or the limitation of the use of your data may result in Everlay not being able to handle your request or to maintain communication with the User.

Retention Period

Everlay will retain your personal data only for the time necessary to fulfill the purposes indicated in this Privacy Notice and during the retention periods that are enforceable in accordance with the applicable legislation. Once such purposes have been fulfilled, your data will be blocked for the determination of possible liabilities and, subsequently, deleted in accordance with the security measures implemented by Everlay.

Changes to the Privacy Notice

This Privacy Notice may be modified or updated at any time. The modifications will be made available to the User through the publication of the updated version on the Website www.everlay.com, indicating at all times its date of last update.

Consent

By visiting, accessing or using the Website, or by providing your personal data to Everlay by any means, the User grants their consent for the processing of their personal data in accordance with this Privacy Notice. Should they not express their objection, it shall be understood that they grant their tacit consent on the terms indicated herein.

Last Updated

October 2026.

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