Privacy and Data Processing Policy

Last update: April 2026

At Patrimofy Real Estate S.A.S. (hereinafter "the Company", "we" or "our"), we highly value your trust and respect your privacy. This Privacy Policy describes our practices regarding how we collect, use, protect and share the personal information you provide us through our website, contact forms, CRM platforms and other customer service channels, in strict compliance with Law 1581 of 2012 (Personal Data Protection Law or Habeas Data) of the Republic of Colombia and its regulatory decrees.

1. Data Controller

Patrimofy Real Estate S.A.S. acts as the data controller for your personal data. For any questions, requests, or to exercise your rights, you can contact us via email at: info@patrimofy.com.

2. Information We Collect

We may collect and process the following personal data when you interact with our platforms or advisors:

• Contact and profiling data: Full name, phone number (WhatsApp), email address, city of residence, and country.
• Financial and investment data: Interest in specific projects (such as Luwana Alma Beach), estimated investment budgets, and other information voluntarily provided in forms to profile your real estate interest.
• Navigation and behavioral data: IP address, browser type, pages visited, time spent, and interactions with our ads (via Meta Pixels, Google Analytics, and our CRM).

3. Purposes of Data Processing

Your personal data will be used solely and exclusively for the following purposes:

• Provide detailed commercial information about our real estate projects, launches, and investment opportunities.
• Manage your requests, scheduling of in-person or virtual appointments with our advisors, and track your purchase interest.
• Manage the reservation process, linking to trust funds, and administrative procedures related to the acquisition of properties.
• Send advertising material, newsletters, and exclusive offers via email, SMS, or WhatsApp.
• Perform statistical and market analysis to improve the usability of our web platforms and optimize our advertising campaigns.

4. Data Sharing and Transfer

Patrimofy Real Estate S.A.S. does not sell, rent, or trade your personal data. However, to fulfill our services, we may securely share your information with:

• Partner Developers and Trust Companies: (e.g., Grupo ICG, Alianza Fiduciaria) strictly for the legal onboarding and purchasing processes of the property you choose to acquire.
• Technology Providers: We use CRM platforms (e.g., LedBy.Digital) and cloud servers that act as data processors under strict confidentiality agreements and international security standards.

5. Use of Cookies and Tracking Technologies

Our website uses cookies, tracking pixels (such as Meta Pixel or TikTok Pixel), and similar technologies to analyze site traffic, personalize content, and deliver relevant ads. You can configure your browser to reject all cookies, although this may limit some functionalities of the site.

6. Data Subject Rights (Habeas Data)

In accordance with Colombian law, you have the right to:

• Know, update, and rectify your personal data at any time.
• Request proof of the authorization granted for data processing.
• Be informed about the use given to your data.
• Revoke the authorization or request the deletion of your data from our commercial databases, provided there is no legal or contractual duty preventing such deletion (for example, if you are an active client of a project).

7. Security Measures

We implement reasonable and updated physical, administrative, and technical security protocols (including SSL encryption) to protect your personal data against unauthorized access, loss, alteration, or improper disclosure.

8. Changes to this Policy

We reserve the right to modify this Privacy Policy at any time. Any significant changes will be published on this same page with an updated revision date. We recommend periodically reviewing this section.