Intellectual Property Policy
Version 1.0 · Last updated
English translation for convenience — the Spanish version is the governing text.
TITLE I. GENERAL PROVISIONS
Chapter 1. Purpose and Relationship to Other Documents
1.1 Purpose
This Intellectual Property Policy (hereinafter, the "Policy") is intended to develop, with the level of detail required by legal audit and Due Diligence processes, the comprehensive regime of ownership, licensing, assignment and protection of the intellectual and industrial property of Ancuria™ Inteligencia Inmobiliaria (hereinafter, "Ancuria", the "Platform" or the "Data Controller").
1.2 Relationship to other documents
This Policy develops and consolidates the provisions of Title V (Intellectual Property) of the Terms and Conditions of Service, and is interpreted jointly with the Responsible Artificial Intelligence Policy regarding ownership of Artificial Intelligence models and components. This Policy additionally incorporates subject matters not developed in those documents, particularly the regime of intellectual-property assignment by founders, personnel and collaborators, and the notice-and-takedown procedure for infringement.
1.3 Nature of the document
Unlike the Terms and Conditions of Service, whose Title V governs the relationship between the Data Controller and its Users, this Policy has a broader scope, extending to the Data Controller's relationship with its own personnel, collaborators, independent contractors, and third parties outside the Platform who might become involved in an intellectual-property dispute.
1.4 Consequences of non-compliance
Non-compliance with this Policy by Users shall be governed by the consequences provided in the Terms and Conditions of Service and in the Acceptable Use Policy; non-compliance by personnel, collaborators or contractors shall be governed by the corresponding contractual instruments and by applicable legislation.
Chapter 2. Definitions
2.1 "Intellectual Property of the Data Controller"
The set of copyrights, industrial secrets, trademarks, and other intellectual and industrial property rights of which the Data Controller is or may become the holder, including those described in Chapter 4.
2.2 "Derivative Work"
Any work that incorporates or is substantially based on a protected preexisting work, as defined in the Federal Copyright Law.
2.3 "Work Made for Hire"
Any intellectual creation developed by an individual in the performance of their employment relationship, professional-services relationship, or collaboration with the Data Controller, as regulated in Title V of this Policy.
2.4 "Open Source Component"
Any third-party software incorporated into the Platform whose license is publicly available under a recognized open licensing scheme (such as MIT, Apache 2.0, GNU GPL, among others).
2.5 "Infringement Notice"
A communication through which a third party informs the Data Controller that User Content, or another element present on the Platform, infringes their intellectual-property rights, pursuant to the procedure described in Title IV.
2.6 Reference to the definitions of the Terms and Conditions of Service
The terms "Platform", "User", "User Content", "Artificial Intelligence Agent" and other terms defined in Chapter 2 of the Terms and Conditions of Service have, for purposes of this Policy, the same meaning assigned there, unless expressly indicated otherwise.
TITLE II. OWNERSHIP OF ANCURIA'S INTELLECTUAL PROPERTY
Chapter 3. Consolidation of Ownership
3.1 Legal objective
To consolidate, in a single reference instrument, the entirety of the intellectual and industrial property assets held by the Data Controller, for clarity purposes toward auditors, investors and third parties.
3.2 Inventory of intellectual-property assets
The Data Controller holds the following intellectual and industrial property assets, without prejudice to such inventory expanding as the Platform evolves: (i) the source and object code of the Platform's software, protected as a literary work under the Federal Copyright Law; (ii) the databases and their structure, including the proprietary Market Indicators database; (iii) the Artificial Intelligence models, configurations, prompts and architectures developed by the Data Controller, protected as industrial secrets pursuant to section 3.4; (iv) the trademarks, trade names and other distinctive signs described in Chapter 5; (v) the graphical user interfaces and original design elements of the Platform; (vi) the technical and methodological documentation developed internally; and (vii) the domain name of the Platform's website.
3.3 Protection through copyright
The source code, documentation, original graphical interfaces, and other literary or artistic works generated by the Data Controller enjoy automatic protection under the Federal Copyright Law from the moment of their fixation in a tangible medium, such protection not requiring registration to exist, without prejudice to the evidentiary advantages that registration before the National Copyright Institute could offer.
3.4 Protection through industrial secrets
The system prompts, automation architectures, calculation methodologies of the Calculation Engine, and other technical information that the Data Controller keeps under reasonable conditions of confidentiality and that provides it a competitive advantage, constitute industrial secrets protected under the Industrial Property Law, provided the safeguard measures described in Chapter 14 of the Responsible Artificial Intelligence Policy and in the Information Security Policy are observed.
3.5 Consideration of patent registration
As the specific technical innovation of its future developments justifies it, the Data Controller will assess the convenience of applying for patent registration before the Mexican Institute of Industrial Property regarding inventions meeting the requirements of novelty, inventive step and industrial applicability; as of the date of this document no patent application is pending.
3.6 Consequences of non-compliance
Misappropriation of any of the assets indicated in this Chapter by a third party shall give rise to the civil and criminal actions provided in applicable legislation, pursuant to the protection procedure described in Title IV.
Chapter 4. Ownership of Artificial Intelligence Components
4.1 Reference to the Responsible Artificial Intelligence Policy
Ownership of the Platform's Artificial Intelligence models, Agents, prompts and automation architectures is governed, substantively, by Chapter 14 (Intellectual Property over Artificial Intelligence, Algorithms and Prompts) of the Terms and Conditions of Service and by Title I of the Responsible Artificial Intelligence Policy, provisions that this Policy acknowledges and incorporates by reference.
4.2 Distinction regarding third-party Artificial Intelligence Provider infrastructure
As already established, the Data Controller claims no ownership over the base models or the infrastructure of its third-party Artificial Intelligence Providers, its ownership being limited to the configurations, prompts, workflows, and specific developments the Data Controller incorporates upon that base infrastructure, pursuant to section 14.3 of the Terms and Conditions of Service.
4.3 Consequences of non-compliance
Referred to Chapter 14 of the Terms and Conditions of Service and Chapter 9 of the Responsible Artificial Intelligence Policy.
Chapter 5. Trademarks and Distinctive Signs
5.1 Inventory of distinctive signs
The Data Controller is, or intends to become, the holder of the following distinctive signs: the name "Ancuria™"; the logo associated with that name; and the institutional color combination (navy blue and coral) used consistently in the Platform's visual identity.
5.2 Status of the trademark registration proceeding
As of the date of this document, the "Ancuria™" trademark is in registration proceedings before the Mexican Institute of Industrial Property (IMPI), with an application filed in July 2026.
5.3 Effects of the pending trademark registration
Pursuant to Article 151 of the Industrial Property Law and related provisions, filing the registration application grants its holder a right of priority over later applications, without this being equivalent to the full protection granted by an issued registration; the Data Controller will follow up on that proceeding and will update this Policy once it concludes.
5.4 Consistent use of the trademark
The Data Controller seeks to use its distinctive signs consistently across all its materials and channels, as a recommended practice to strengthen the distinctiveness of the trademark and facilitate its defense against infringement.
5.5 Consequences of non-compliance
Unauthorized use of the Data Controller's distinctive signs by a third party shall be governed by Chapter 15 of the Terms and Conditions of Service and by the protection procedure described in Title IV of this Policy.
TITLE III. THIRD-PARTY INTELLECTUAL PROPERTY
Chapter 6. User Content
6.1 Reference to the Terms and Conditions of Service
The ownership and licensing regime of User Content is governed by Chapter 16 of the Terms and Conditions of Service, which this Policy acknowledges and incorporates by reference.
6.2 Additional best practices
Without prejudice to the foregoing, the Data Controller recommends that Real-Estate Agents verify, prior to publishing photographic or audiovisual material of a property, that they hold the corresponding authorization from the owner or the professional photographer who generated such material, in order to prevent third-party claims pursuant to section 16.3 of the Terms and Conditions of Service.
Chapter 7. Open Source Components
7.1 Legal objective
To establish the Data Controller's approach regarding the incorporation of Open Source Components into the Platform's development, a subject of particular relevance in legal-technical Due Diligence processes.
7.2 Use of Open Source Components
The Data Controller may incorporate into the Platform Open Source Components developed by third parties, subject to their respective public licenses, acknowledging that such incorporation does not transfer ownership of those components to the Data Controller, but only the right of use under the terms of the corresponding license.
7.3 License compatibility review
Before incorporating a new Open Source Component, the Data Controller seeks to review the terms of its license, in order to verify its compatibility with the Platform's commercial and proprietary business model, avoiding the incorporation of components subject to licenses that could require disclosure of Ancuria's proprietary source code (strong "copyleft" licenses, such as the GNU GPL, when their application is incompatible with that model).
7.4 Record of Open Source Components used
The Data Controller seeks to maintain a reasonable record of the Open Source Components incorporated into the Platform and their corresponding licenses, which may be made available to auditors or investors in Due Diligence processes, under the corresponding confidentiality agreements.
7.5 Compliance with attribution obligations
The Data Controller complies with the attribution, license-notice, or terms-publication obligations that the licenses of the Open Source Components used reasonably require.
7.6 Consequences of non-compliance
Non-compliance with the terms of an Open Source license could expose the Data Controller to claims by the holder of that component, or, in the case of copyleft licenses, to the risk of having to disclose proprietary source code; for that reason, observance of this Chapter is of particular relevance to protecting the Platform's technological value.
Chapter 8. Third-Party Licenses and Licensed Content
8.1 Licensed market-data sources
When the Data Controller incorporates third-party licensed real-estate market-data sources into the Platform for the generation of Market Indicators, such incorporation shall be subject to the terms of the corresponding license, which the Data Controller seeks to document and respect as to its scope of use and redistribution.
8.2 Third-party material in the Platform interface
When the Data Controller uses icons, typefaces, illustrations or other graphic material licensed from third parties for the Platform interface, such use is subject to the terms of the corresponding commercial or use license.
8.3 Consequences of non-compliance
Use of third-party material or data beyond the scope of the corresponding license could expose the Data Controller to claims by the holder of those rights.
TITLE IV. NOTICE AND TAKEDOWN PROCEDURE
Chapter 9. Notice of Infringements by Third Parties
9.1 Legal objective
To establish a clear and accessible procedure through which a third party who considers that their intellectual property has been infringed by User Content or another element present on the Platform can notify the Data Controller, in line with international best practices for technology platforms (analogous to the internationally recognized "notice and takedown" procedure) and with the intermediary-liability framework applicable under Mexican legislation.
9.2 Notification channel
Any third party who considers that their intellectual property has been infringed through the Platform may submit an Infringement Notice to the email address legal@ancuria.com, specifically designated for that purpose.
9.3 Content of the Infringement Notice
The Infringement Notice must include at least: (i) identification of the holder of the allegedly infringed rights, or of their authorized representative; (ii) specific identification of the allegedly infringed work or right; (iii) the specific location within the Platform of the allegedly infringing User Content (for example, by a link or listing identifier); (iv) a declaration, under penalty of perjury, that the information provided is accurate and that the notifier is authorized to act on behalf of the rights holder; and (v) the notifier's contact details.
9.4 Review of the Notice
The Data Controller will review every Infringement Notice received that meets the requirements indicated in the preceding section, without the Data Controller being obliged to make a definitive legal determination on the existence of the infringement; the existence of reasonable indications suffices to proceed under Chapter 10.
9.5 Consequences of non-compliance
Submitting an Infringement Notice with false information, for the purpose of unduly harming a User, may give rise to the notifier's liability under applicable legislation.
Chapter 10. Content Removal and Counter-Notification
10.1 Removal of allegedly infringing content
Upon receipt of an Infringement Notice meeting the requirements of section 9.3, the Data Controller may remove or disable access to the allegedly infringing User Content, pursuant to its general authority provided in section 27.5 of the Terms and Conditions of Service.
10.2 Notice to the affected User
The Data Controller will notify the User whose User Content has been removed under this Chapter, informing them of the reason for such removal and the essential content of the Infringement Notice received, unless applicable legislation or an order from a competent authority provides otherwise.
10.3 Counter-notification mechanism
The affected User may submit to the Data Controller a counter-notification, stating in good faith the reasons why they consider the removal improper, including, where applicable, documentation evidencing their right to use the removed content.
10.4 Resolution of disputes between User and notifier
The Data Controller does not act as arbitrator of the underlying intellectual-property dispute between the notifier and the affected User; it is for those parties to resolve that dispute by the means they deem appropriate; the Data Controller may restore the removed User Content if, after a reasonable period from the counter-notification, it receives no evidence that the notifier has initiated formal action to enforce their rights.
10.5 Recidivism and Account termination
In accordance with internationally recognized best practices for technology platforms, the Data Controller may terminate the Account of a User about whom it receives well-founded Infringement Notices repeatedly, pursuant to the graduated-consequences regime of the Acceptable Use Policy.
10.6 Consequences of non-compliance
Failure to reasonably attend to an Infringement Notice meeting the requirements of Chapter 9 may expose the Data Controller to liability under applicable intellectual-property legislation, in its capacity as an information-society services provider.
TITLE V. INTELLECTUAL PROPERTY OF PERSONNEL AND COLLABORATORS
Chapter 11. Assignment of Intellectual Property through Work Made for Hire
11.1 Legal objective
To establish, with the clarity required by investment and Due Diligence processes, the ownership regime over intellectual creations developed by the Data Controller's personnel, collaborators and independent contractors in the performance of their duties, a matter of utmost relevance to evidencing the clean title ("clean IP") to Ancuria's technological assets before investors.
11.2 General rule under copyright legislation
Pursuant to Article 83 of the Federal Copyright Law, unless otherwise agreed, the individual or legal entity that commissions the production of a work or produces it with the paid collaboration of other persons shall hold title to the economic rights over that work and the right to dispose of it; the Data Controller formalizes such ownership through the contractual instruments described in section 11.4, in order to eliminate any interpretive ambiguity before auditors and investors.
11.3 Scope of the assignment
Every work, software development, design, technical documentation, or other intellectual creation that the Data Controller's personnel, collaborators or independent contractors develop in the performance of their duties, or using the Data Controller's resources, time or information, is considered Work Made for Hire, whose ownership belongs entirely to the Data Controller from the very moment of its creation.
11.4 Formalization through contractual instruments
The Data Controller formalizes the assignment described in this Chapter through specific intellectual-property assignment clauses incorporated into professional-services agreements, employment contracts, or collaboration agreements it enters into with the individuals involved in the Platform's development, including its own founders regarding the technological contributions they make.
11.5 Situation of the founders
Ancuria's founders, in their capacity as original developers of the Platform, formally assign or will formally assign to James Marcus Patman, the individual holder of Ancuria, the entirety of the intellectual-property rights over the technological contributions made before and after Ancuria's formal start of operations, by means of the corresponding contractual instrument, whose existence and specific scope must be verified and, where applicable, formalized as part of the comprehensive legal review accompanying this Policy.
11.6 Independent contractors and external developers
Every contract the Data Controller enters into with an independent contractor, freelancer, or external developer participating in the Platform's development must include an express intellectual-property assignment clause in favor of the Data Controller, given the different legal presumption that, absent such express agreement, could apply to works commissioned to a third party not integrated into the Data Controller's internal structure.
11.7 Consequences of non-compliance
The absence of duly formalized assignment instruments regarding any person who has contributed to the Platform's technological development constitutes a significant legal risk to the ownership of Ancuria's intellectual property, and must be remedied as a priority, typically as one of the first conditions an investor or acquirer will require verifying in a Due Diligence process.
Chapter 12. Personnel's Preexisting Intellectual Property
12.1 Exclusion of preexisting works
The assignment described in Chapter 11 does not extend to intellectual-property works or developments that an individual created prior to their relationship with the Data Controller, and independently of that relationship, unless such preexisting works are incorporated into the Platform's development, in which case the Data Controller will seek to obtain an express license for their use, or the corresponding assignment, as applicable.
12.2 Declaration of non-incorporation of third-party intellectual property from previous employers
The Data Controller requires its personnel, collaborators and contractors to declare that they do not incorporate into the Platform's development confidential or third-party intellectual property (including from previous employers) for which they lack the corresponding authorization.
12.3 Consequences of non-compliance
Unauthorized incorporation of a third party's intellectual property by the Data Controller's personnel or collaborators could expose the latter to claims by that third party, with the person responsible for such unauthorized incorporation being the one who must answer to the Data Controller under the terms of the corresponding contractual instrument.
TITLE VI. FINAL PROVISIONS
Chapter 13. Validity, Modifications and Final Provisions
13.1 Entry into force
This Policy shall enter into force on the date stated on the cover page of this document.
13.2 Modifications
The Data Controller may modify this Policy at any time, particularly to reflect the evolution of its intellectual-property inventory, the status of its registration proceedings, or the incorporation of new Open Source Components or third-party licenses.
13.3 Severability
Should any provision of this Policy be declared null, illegal or unenforceable by a competent authority, such declaration shall not affect the validity and enforceability of the remaining provisions.
13.4 Governing language
In the event of translation into another language, the Spanish (Mexico) version shall prevail for interpretation purposes in case of discrepancy.
13.5 Recommendation of priority legal review
Since Title V of this Policy (Intellectual Property of Personnel and Collaborators) is of particular relevance to investment processes, it is recommended that the formalization of the assignment contractual instruments described there be treated as a priority in the comprehensive legal review of Ancuria's documentary framework.
Version Control Annex
| Version | Effective date | Description of the change |
|---|---|---|
| 1.0 | September 22, 2026 | Initial version of the document |