Privacy, Data Processing & Cookie Policy

Last update: September 2026

At Patrimofy Real Estate S.A.S. (hereinafter "Patrimofy", "the Company", "we" or "our"), we highly value your trust and are committed to protecting your privacy. This Privacy Policy governs the collection, processing, and protection of personal data across all our digital platforms, portals, and affiliated real estate projects, including but not limited to patrimofy.com, loomluxuryresidence.com (Loom Luxury Residence), Luwana Alma Beach, Vista Kanoa Condominio, and Anaiwa Eco Reserva.

This policy complies with Colombia's Law 1581 of 2012 (Personal Data Protection Law or Habeas Data), regulatory decrees, and international digital privacy benchmarks, including applicable provisions of the California Consumer Privacy Act (CCPA/CPRA) and United States Federal Trade Commission (FTC) guidelines for international investors.

1. Data Controller and Scope

Patrimofy Real Estate S.A.S. acts as the Data Controller.
Address: Cra. 17 #24 - 178 piso 2, oficina 204 Manga, Cartagena de Indias, Bolívar, Colombia.
Contact Email: info@patrimofy.com
Customer Support Phone: +57 333 239 4158

2. Information We Collect

Depending on your interactions across our websites, interactive lot maps, and advisory channels, we may collect:

• Personal Identifiers: First name, last name, phone number (WhatsApp enabled), email address, city, and country of residence.
• Real Estate & Investment Profiling: Specific interest in developments (such as Loom Luxury Residence or Vista Kanoa), preferred lot or villa units, estimated budget, investment horizon (family use, vacation rental, equity appreciation), and advisory requests.
• Navigation and Device Telemetry: IP address, device type, browser specifications, operating system, geolocation data, referral source, pages viewed, time on page, video viewing progress, and campaign tracking parameters (UTM parameters).

3. Purposes of Data Processing

We collect and process your personal information strictly for legitimate commercial and customer-service purposes:

• Provide personalized real estate advisory, price lists, architectural masterplans, and availability status.
• Coordinate virtual video calls, private showroom presentations, and on-site visits in Cartagena's North Zone.
• Process reservation agreements, direct developer financing arrangements, and fiduciary trust onboarding (e.g., Alianza Fiduciaria).
• Deliver tailored commercial communications, project updates, construction milestones, and promotional campaigns via WhatsApp, email, or telephone.
• Measure advertising effectiveness and optimize our web experience across digital platforms.

4. Advertising Technologies, Cookies & Conversion Tracking

Our websites employ first-party and third-party cookies, web beacons, and server-side tracking APIs to analyze traffic and deliver relevant advertising. Our primary partners include:

• Meta Platforms, Inc. (Facebook & Instagram Ads): We utilize the Meta Pixel and Meta Conversions API (CAPI) to measure ad engagement and deliver customized property advertisements.
• TikTok Pte. Ltd. (TikTok Ads): We utilize the TikTok Pixel and TikTok Events API to measure conversion events and campaign reach.
• Google LLC (Google Ads & Analytics): We utilize Google Analytics, Google Tag Manager, and Google Search Console to evaluate visitor flow and search discoverability.
• CRM & Automation (GoHighLevel / LedBy.Digital): Customer relationship management platforms acting as secure data processors under strict confidentiality protocols.
• Cloudflare, Inc.: High-speed content delivery network, SSL encryption, and high-resolution video streaming infrastructure.

You may manage or withdraw your consent for non-essential tracking cookies at any time using our on-site Cookie Banner by selecting "Necessary Only" or through your browser settings.

5. Notice to United States and California Residents (CCPA / CPRA)

If you reside in the United States, including California, Colorado, Connecticut, Utah, or Virginia, applicable state laws provide specific privacy rights regarding your personal information:

• Do Not Sell or Share My Personal Information: Patrimofy Real Estate S.A.S. does NOT sell, rent, or trade your personal information to third parties for monetary consideration. Any sharing of data with technology providers is conducted strictly to deliver our real estate advisory and promotional services.
• Right to Know / Access: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you over the past 12 months.
• Right to Delete: You have the right to request deletion of personal information collected from you, subject to legal and contractual exceptions.
• Right to Correct: You have the right to request correction of inaccurate personal data.
• Right to Non-Discrimination: We will never discriminate against you, deny services, or provide different pricing for exercising any of your statutory privacy rights.

To exercise your US privacy rights, submit a verified request by emailing info@patrimofy.com with the subject line "US Privacy Rights Request".

6. Colombian Habeas Data Rights (Law 1581 of 2012)

Under Colombian statutory regulations, as a data subject you have the right to:

• Know, update, and rectify your personal information recorded in our databases.
• Request proof of the authorization granted to Patrimofy for data processing.
• Be informed upon request about the use given to your personal information.
• Revoke authorization and/or request data suppression whenever constitutional and legal principles are not respected, or once commercial follow-up is concluded.
• Access your personal data free of charge at least once every calendar month.

7. Data Security and International Transfers

We employ enterprise-grade administrative, technical, and physical security measures, including 256-bit SSL/TLS encryption, restricted access controls, and hashed data transmission (SHA-256) when communicating with conversion APIs. In cases where data is transferred across international jurisdictions to cloud providers, such transfers adhere to international standard contractual clauses.

8. Updates to this Policy

Patrimofy reserves the right to amend this Privacy Policy to reflect technical enhancements, advertising partner updates, or statutory requirements. All revisions will be posted on this page with an updated revision date.