IMPORTANT NOTICE

This ARCO Rights Notice (“Notice”) applies to all users, visitors, customers, prospective customers, property owners, buyers, sellers, landlords, tenants, investors, brokers, agents, employees, contractors, vendors, referral partners, subscribers, website visitors, mobile application users, and other parties interacting with LiBe Holdings, S.A.S., and any of its parents, subsidiaries, affiliates, successors, assigns, related entities, controlled entities, commonly controlled entities, licensed operators, authorized representatives, officers, directors, employees, contractors, agents, brokers, partners, and service providers (collectively, “LiBe,” “Company,” “we,” “our,” or “us”).

This Notice explains the rights available to Data Subjects under applicable privacy and data protection laws, including the Access, Rectification, Cancellation, and Opposition Rights (“ARCO Rights”) recognized under Mexican law, as well as similar privacy rights available in other jurisdictions throughout the Americas.

By accessing, browsing, registering for, purchasing, subscribing to, communicating with, or otherwise using any LiBe Service, you acknowledge that you have read and understood this Notice.

1. PURPOSE OF THIS NOTICE

LiBe is committed to respecting and protecting the privacy rights of individuals.

This Notice describes:

• Your privacy rights
• How to exercise those rights
• Verification procedures
• Response procedures
• Applicable limitations
• International privacy protections

Nothing in this Notice shall be interpreted as limiting rights granted by applicable law.

2. WHO MAY EXERCISE ARCO RIGHTS

ARCO Rights may generally be exercised by:

• The Data Subject
• A legal representative
• An authorized agent
• A parent or guardian, where legally applicable
• A person otherwise authorized by law

LiBe may request documentation to verify authority before processing requests.

3. RIGHT OF ACCESS

You may request information regarding:

• Whether LiBe processes your personal information
• Categories of information collected
• Sources of information
• Purposes of processing
• Categories of recipients
• International transfers
• Retention practices
• Information is maintained about you

Subject to applicable legal limitations, LiBe may provide access to personal information maintained in its systems.

4. RIGHT OF RECTIFICATION

You may request correction, updating, or rectification of personal information that is:

• Inaccurate
• Incomplete
• Outdated
• Misleading
• Incorrectly recorded

LiBe may request supporting documentation before implementing corrections.

5. RIGHT OF CANCELLATION

Subject to applicable law, you may request deletion, blocking, anonymization, suppression, or cancellation of personal information.

Certain information may be retained where necessary to:

• Comply with legal obligations
• Complete transactions
• Resolve disputes
• Enforce agreements
• Protect legal rights
• Prevent fraud
• Meet regulatory requirements
• Maintain business records

Where deletion is not legally permissible, LiBe may limit processing to the extent required by law.

6. RIGHT OF OPPOSITION

You may object to certain processing activities where permitted by applicable law.

Such objections may relate to:

• Marketing activities
• Profiling activities
• Automated decision-making
• Certain business operations
• Other processing activities permitted by law

LiBe may continue processing where legally justified or required.

7. ADDITIONAL PRIVACY RIGHTS

Depending upon applicable law, you may also possess:

• Right to Know
• Right to Data Portability
• Right to Restrict Processing
• Right to Withdraw Consent
• Right to Non-Discrimination
• Right to Appeal Certain Decisions
• Right to Obtain Copies of Data
• Right to Lodge Complaints with Regulatory Authorities

Availability of rights varies by jurisdiction.

8. REQUEST SUBMISSION PROCEDURE

Requests should include:

• Full legal name
• Contact information
• Description of the request
• Identification documentation
• Supporting documentation, if applicable

Requests may be submitted electronically.

LiBe reserves the right to request additional information reasonably necessary to verify identity.

9. IDENTITY VERIFICATION

To protect privacy and security, LiBe may require:

• Government-issued identification
• Proof of authority
• Additional verification procedures
• Authentication measures

LiBe may deny requests where identity cannot reasonably be verified.

10. RESPONSE TIMEFRAMES

LiBe shall respond within the timeframes required by applicable law.

Response periods may vary depending upon:

• Jurisdiction
• Nature of the request
• Complexity of the request
• Applicable legal requirements

Where permitted by law, extensions may be utilized when reasonably necessary.

11. REQUEST DENIALS

LiBe may deny requests where permitted by law, including circumstances involving:

• Legal obligations
• Fraud prevention
• Security concerns
• Ongoing investigations
• Contractual obligations
• Regulatory compliance
• Inability to verify identity

Where appropriate, LiBe may provide information regarding the basis for denial.

12. AUTHORIZED REPRESENTATIVES

Authorized representatives may exercise rights on behalf of Data Subjects where:

• Proper authorization exists
• Required documentation is provided
• Applicable legal requirements are satisfied

LiBe may verify the authenticity of submitted authorizations.

13. MARKETING OPT-OUTS

Individuals may request removal from:

• Marketing emails
• SMS campaigns
• WhatsApp campaigns
• Promotional communications
• Advertising audiences

Operational and transactional communications may continue where legally permitted.

14. AUTOMATED PROCESSING AND PROFILING

LiBe may utilize:

• Artificial Intelligence
• Automated scoring systems
• Lead qualification systems
• Recommendation systems
• Marketing automation

Where required by law, users may request information regarding certain automated processing activities.

15. INTERNATIONAL DATA TRANSFERS

Personal information may be transferred internationally.

By using LiBe Services, users acknowledge that information may be processed, stored, transferred, or accessed outside their country of residence.

LiBe may implement reasonable safeguards designed to protect transferred information.

16. REGULATORY COMPLAINTS

Where applicable, Data Subjects may file complaints with:

• Mexican privacy authorities
• Colombian privacy authorities
• Consumer protection agencies
• Data protection regulators
• Other competent authorities

LiBe encourages individuals to contact the Company first so concerns may be addressed efficiently.

17. NON-DISCRIMINATION

LiBe shall not unlawfully discriminate against individuals for exercising privacy rights.

However, certain services, features, benefits, or functionality may be unavailable where information necessary to provide such services is deleted or restricted.

18. SECURITY OF REQUESTS

LiBe reserves the right to reject requests that:

• Appear fraudulent
• Are abusive
• Are excessive
• Threaten system security
• Violate applicable laws

Appropriate safeguards may be implemented to protect personal information.

19. INTERNATIONAL APPLICABILITY

This Notice is intended to apply throughout:

• Mexico
• United States
• Puerto Rico
• Canada
• Colombia
• Brazil
• Argentina
• Chile
• Peru
• Uruguay
• Panama
• Central America
• South America
• Caribbean jurisdictions

LiBe recognizes that privacy rights vary among jurisdictions.

Where local law grants greater protections than those described herein, such protections shall prevail.

20. MANDATORY LAW SAVINGS CLAUSE

Nothing in this Notice shall limit rights granted by applicable privacy, consumer protection, telecommunications, cybersecurity, employment, or data protection laws.

Where local law grants rights, protections, disclosures, obligations, restrictions, remedies, or enforcement mechanisms that cannot legally be waived, those provisions shall prevail solely to the extent required by law.

All remaining provisions shall remain valid, enforceable, and binding to the fullest extent permitted by law.

21. GOVERNING LAW

Except where prohibited by mandatory law, this Notice shall be governed by the laws of the Republic of Colombia.

22. JURISDICTION

Except where prohibited by mandatory law, disputes relating to this Notice shall be subject exclusively to the courts located in:

Barranquilla, Atlántico, Colombia.

LiBe Holdings, S.A.S., and any of its affiliates

NIT: 902-043-981

Barranquilla, Atlántico, Colombia

Puerto Rico Real Estate Broker License: C-17849

All privacy requests, compliance inquiries, consumer complaints, regulatory communications, and legal notices should be submitted to: legal@letslibe.com

LAST UPDATED: September 7, 2026