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communications and electronic messaging policy

IMPORTANT NOTICE

This Advertising & Lead Generation Disclaimer (“Disclaimer”) applies to all users, visitors, customers, advertisers, brokers, agents, developers, property owners, investors, lenders, vendors, service providers, 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 Disclaimer governs all advertising, marketing, promotional, lead generation, lead distribution, referral, prospecting, customer acquisition, listing promotion, and related activities conducted through any LiBe website, application, platform, marketplace, communication channel, social media account, advertising network, software platform, or service.

By accessing or using any Service, you acknowledge and agree to this Disclaimer.

 

1. PURPOSE

This Communications & Electronic Messaging Policy (“Policy”) governs all communications sent, received, processed, stored, managed, or facilitated by LiBe Holdings SAS (“LiBe,” “Company,” “we,” “our,” or “us”).

This Policy establishes the rules, rights, obligations, permissions, restrictions, and consent requirements applicable to all communications conducted through LiBe’s websites, applications, real estate platforms, customer support systems, marketing systems, messaging systems, and affiliated services.

This Policy is intended to operate in conjunction with:

    • Terms of Service
    • Privacy Policy
    • Personal Data Processing Policy
    • Cookie Policy
    • Fair Housing Statement
    • Applicable laws and regulations

 

2. COMMUNICATION CHANNELS COVERED

This Policy applies to all communications, including:

Mobile Communications

    • SMS
    • MMS
    • RCS Messaging
    • A2P Messaging
    • Text Messaging

Internet Messaging

    • WhatsApp
    • Telegram
    • Signal
    • Facebook Messenger
    • Instagram Direct Messages
    • LinkedIn Messages
    • X (Twitter) Messaging
    • Future messaging platforms

Email Communications

    • Marketing Emails
    • Transactional Emails
    • Service Notifications
    • Newsletters
    • Promotional Emails

Application Communications

    • Push Notifications
    • Mobile Notifications
    • Browser Notifications
    • In-App Messaging

Voice Communications

    • Live Calls
    • Recorded Calls
    • VoIP Calls
    • Automated Calls
    • Interactive Voice Response (IVR)

Customer Support

    • Chat
    • Live Support
    • AI Chat Systems
    • Customer Service Platforms

Future Technologies

This Policy automatically extends to any future communication technology adopted by LiBe.

 

3. COMMUNICATION CONSENT

LiBe may communicate with users only when:

    • Express consent exists;
    • Implied consent is legally recognized.
    • A contractual relationship exists.
    • The communication is transactional.
    • The communication is required by law.
    • The communication is necessary for the requested services.

Consent may be collected through:

    • Website forms
    • Mobile applications
    • Digital agreements
    • Property inquiry forms
    • Electronic signatures
    • Registration forms
    • SMS opt-ins
    • QR codes
    • Customer service interactions
    • Social media forms

 

4. CONSENT STANDARDS

LiBe follows the highest available consent standard applicable under:

    • TCPA (United States)
    • CAN-SPAM (United States)
    • FCC Regulations
    • CASL (Canada)
    • LGPD (Brazil)
    • Law 1581 (Colombia)
    • LFPDPPP (Mexico)
    • ARCO frameworks
    • Other applicable laws throughout the Americas

Consent must be:

    • Freely given
    • Specific
    • Informed
    • Unambiguous
    • Verifiable
    • Revocable

 

5. SMS TERMS & CONDITIONS

By providing a mobile number and opting in, users authorize LiBe to send SMS communications.

Messages may include:

    • Property alerts
    • Listing updates
    • Inquiry responses
    • Appointment reminders
    • Customer service communications
    • Marketing offers
    • Promotional campaigns

User Acknowledgements

Users acknowledge:

    • Message frequency varies.
    • Message and data rates may apply.
    • Wireless carrier charges may apply.
    • Consent is not a condition of purchase.
    • Carrier participation may vary.

Opt-Out

Users may opt out by:

STOP, UNSUBSCRIBE, CANCEL, QUIT or by contacting: legal@letslibe.com

 

6. A2P 10DLC COMPLIANCE

For United States recipients, LiBe complies with applicable carrier and messaging requirements.

LiBe:

    • Maintains consent records
    • Honors opt-out requests
    • Identifies message originators
    • Prohibits unlawful messaging
    • Monitors campaign compliance

LiBe reserves the right to suspend messaging privileges where misuse or fraud is detected.

 

7. WHATSAPP BUSINESS COMMUNICATIONS

Users who provide WhatsApp-enabled numbers consent to receive communications through WhatsApp.

Communications may include:

    • Property information
    • Listing updates
    • Appointment scheduling
    • Customer support
    • Marketing messages
    • Transaction notifications

Users may withdraw consent at any time.

LiBe complies with:

    • WhatsApp Business Policies
    • Meta Business Messaging Requirements

 

8. EMAIL MARKETING POLICY

LiBe may send emails regarding:

    • Properties
    • Market reports
    • Promotions
    • Newsletters
    • Investment opportunities
    • Company updates

Every marketing email shall include:

    • Sender identification
    • Company identification
    • Physical business location
    • Contact information
    • Functional unsubscribe mechanism

Unsubscribe requests will be honored promptly.

 

9. SOCIAL MEDIA MESSAGING POLICY

Users who initiate communication through social media may receive responses through:

    • Facebook
    • Instagram
    • LinkedIn
    • X (Twitter)
    • TikTok
    • YouTube
    • Future social media platforms

LiBe is not responsible for platform-specific privacy practices.

Users should review each platform’s policies separately.

 

10. PUSH NOTIFICATION POLICY

Users may receive:

    • Property alerts
    • Saved search updates
    • Service notifications
    • Security alerts
    • Promotional content

Users may disable notifications through:

    • Device settings
    • Browser settings
    • Application settings

 

11. AI-GENERATED COMMUNICATIONS

LiBe may utilize:

    • Artificial intelligence
    • Machine learning systems
    • Automated customer service tools
    • Predictive communication tools

Users acknowledge that communications may be generated in whole or in part by automated systems.

Human review may not occur for every communication.

 

12. CONSENT RECORD RETENTION

LiBe maintains records including:

    • Consent logs
    • Opt-in records
    • Opt-out records
    • Message history
    • Form versions
    • Timestamps
    • Device information
    • IP addresses

Records may be retained for:

    • Compliance
    • Litigation defense
    • Regulatory investigations
    • Fraud prevention
    • Business continuity

 

13. COMMUNICATION AUDIT PROCEDURES

LiBe may audit:

    • Consent records
    • Campaign activity
    • Complaint history
    • Message content
    • Delivery systems

Audits may be conducted internally or through third-party compliance providers.

 

14. COMMUNICATION FREQUENCY

Message frequency varies.

Factors include:

    • User preferences
    • Saved searches
    • Property alerts
    • Active transactions
    • Service updates

LiBe reserves the right to establish reasonable frequency limitations.

 

15. USER RIGHTS

Users may:

    • Access communication records
    • Withdraw consent
    • Correct contact information
    • Request deletion where legally permitted
    • Object to marketing communications
    • Exercise applicable ARCO rights

Requests: legal@letslibe.com

 

16. PROHIBITED COMMUNICATIONS

LiBe prohibits communications involving:

    • Harassment
    • Fraud
    • Spam
    • Misrepresentation
    • Discrimination
    • Hate speech
    • Illegal content

Violations may result in account suspension or legal action.

 

17. INTERNATIONAL COMMUNICATIONS

Users acknowledge communications may:

    • Cross international borders
    • Be processed in multiple jurisdictions
    • Utilize international service providers

Users remain responsible for:

    • Carrier fees
    • Roaming charges
    • Data charges

 

18. FAIR HOUSING COMPLIANCE

All communications involving real estate services shall comply with applicable fair housing and anti-discrimination laws.

LiBe prohibits discriminatory communications based upon protected characteristics recognized by applicable law.

 

19. NO GUARANTEE OF DELIVERY

LiBe does not guarantee:

    • Message delivery
    • Delivery timing
    • Platform availability
    • Network availability
    • Carrier acceptance

Delays and failures may occur due to circumstances beyond LiBe’s control.

 

20. LIMITATION OF LIABILITY

To the fullest extent permitted by law, LiBe shall not be liable for:

    • Delayed messages
    • Failed delivery
    • Platform outages
    • Carrier filtering
    • Spam filtering
    • Third-party service failures

 

21. REGULATORY COMPLIANCE FRAMEWORK

LiBe intends to operate its communications programs in compliance with:

United States

    • TCPA
    • CAN-SPAM
    • FCC Rules
    • State Privacy Laws

Canada

    • CASL
    • PIPEDA

Colombia

    • Law 1581 of 2012
    • Decree 1377 of 2013

Brazil

    • LGPD

Mexico

    • LFPDPPP
    • ARCO Rights

Argentina

    • Personal Data Protection Law

Chile

    • Data Protection Regulations

Peru

    • Personal Data Protection Law

Other Jurisdictions

Any additional laws applicable to the recipient’s location.

Where local law imposes stricter requirements, the stricter requirement shall govern.

 

22. COMPLAINTS

Users may submit complaints regarding communications to: legal@letslibe.com

LiBe will investigate complaints in accordance with applicable law.

 

23. CHANGES TO THIS POLICY

LiBe reserves the right to modify this Policy at any time.

Changes become effective upon publication.

Continued use of LiBe services constitutes acceptance of revised terms.

 

APPENDIX A

APPROVED CONSENT LANGUAGE LIBRARY

A.1 Universal Communications Consent

By checking this box and submitting my information, I expressly consent to receive communications from LiBe Holdings SAS and its affiliates regarding properties, services, account activity, customer support, appointments, promotions, updates, newsletters, and other business-related communications through email, SMS, WhatsApp, telephone calls, social media messaging, push notifications, and other communication channels.

I understand that consent is voluntary, not a condition of purchase, and may be withdrawn at any time.

A.2 Marketing Consent

I agree to receive marketing communications, property alerts, investment opportunities, promotional offers, newsletters, and market updates from LiBe Holdings SAS.

I understand that I may unsubscribe at any time.

A.3 International Consent

I acknowledge that communications may be processed, transmitted, or stored outside my country of residence and consent to such international processing.

 

APPENDIX B

SMS OPT-IN DISCLOSURES

Standard Website Form

By providing your mobile number and clicking “Submit,” you agree to receive recurring automated and non-automated text messages from LiBe Holdings SAS regarding property alerts, appointments, inquiries, updates, promotions, and customer support.

Message frequency varies.

Message and data rates may apply.

Consent is not a condition of purchase.

Reply STOP to unsubscribe.

Reply HELP for assistance.

Lead Generation Form

By submitting this form, you authorize LiBe Holdings SAS to contact you by SMS, phone call, WhatsApp, and email regarding your inquiry.

 

APPENDIX C

WHATSAPP CONSENT DISCLOSURE

Standard Consent

I consent to receive communications from LiBe Holdings SAS through WhatsApp regarding properties, appointments, support requests, account updates, marketing communications, and related services.

I understand that I may request removal from WhatsApp communications at any time.

Customer Support Consent

By initiating a WhatsApp conversation with LiBe Holdings SAS, you consent to receiving communications related to your inquiry.

 

APPENDIX D

EMAIL MARKETING DISCLOSURES

Subscription Form

By subscribing, you agree to receive emails from LiBe Holdings SAS containing:

    • Property alerts
    • Market reports
    • Promotional offers
    • Company news
    • Investment opportunities

You may unsubscribe at any time using the unsubscribe link included in every marketing email.

 

APPENDIX E

SOCIAL MEDIA COMMUNICATIONS DISCLOSURE

Users who contact LiBe Holdings SAS through social media platforms consent to receiving responses and related communications through those platforms.

Communications may include:

    • Property information
    • Customer support
    • Appointment scheduling
    • Marketing information

Social media platforms maintain separate privacy practices for which LiBe is not responsible.

 

APPENDIX F

PUSH NOTIFICATION CONSENT

By enabling notifications, you authorize LiBe Holdings SAS to send:

    • Saved search alerts
    • Property alerts
    • Security notifications
    • Service updates
    • Promotional notices

Users may disable notifications through application or device settings.

 

APPENDIX G

A2P 10DLC COMPLIANCE STATEMENT

LiBe Holdings SAS maintains the following compliance controls:

    • Consent documentation
    • Message auditing
    • Opt-out processing
    • Sender identification
    • Complaint management
    • Campaign registration was required

Prohibited messaging includes:

    • Fraudulent messaging
    • Phishing
    • Deceptive content
    • Illegal marketing
    • Unauthorized lead resale

 

APPENDIX H

RECORD RETENTION SCHEDULE

Record TypeMinimum Retention
Consent Records10 Years
SMS Logs7 Years
Email Logs7 Years
WhatsApp Logs7 Years
Opt-Out RequestsPermanent or 10 Years
Customer Complaints10 Years
Regulatory RequestsPermanent
Litigation HoldsUntil Released
Audit Reports10 Years

LiBe reserves the right to retain records longer where legally required.

 

APPENDIX I

CONSENT EVIDENCE MAINTENANCE

LiBe may maintain:

    • Consent timestamp
    • Source URL
    • Form version
    • User IP address
    • Device identifiers
    • Browser information
    • Session information
    • User account identifiers

These records may be used to demonstrate lawful consent.

 

APPENDIX J

COMMUNICATION AUDIT CHECKLIST

Prior to launching campaigns, LiBe should verify:

✓ Consent exists

✓ Proper disclosures displayed

✓ Opt-out functionality tested

✓ Contact information displayed

✓ Sender identification displayed

✓ Message content reviewed

✓ Fair housing review completed

✓ Privacy review completed

✓ Legal review completed

✓ Carrier compliance confirmed

 

APPENDIX K

COMPLAINT HANDLING PROCEDURE

Upon receipt of a complaint:

    1. Log complaint.
    1. Assign case number.
    1. Verify communication records.
    1. Suspend messaging where appropriate.
    1. Investigate the complaint.
    1. Respond to the complainant.
    1. Implement corrective measures if necessary.
    1. Archive complaint file.

Target response period:

Within thirty (30) calendar days.

 

APPENDIX L

FAIR HOUSING COMMUNICATION REVIEW

All real estate communications shall avoid references that could indicate unlawful preference, limitation, or discrimination.

Prohibited examples include references based on:

    • Race
    • Color
    • National origin
    • Religion
    • Sex
    • Familial status
    • Disability
    • Any additional protected characteristic recognized by law

 

APPENDIX M

AI COMMUNICATION DISCLOSURE

LiBe may utilize:

    • Artificial Intelligence
    • Machine Learning Systems
    • Chatbots
    • Automated Customer Service Systems

Users acknowledge that communications may be generated in whole or in part by automated systems.

LiBe reserves the right to monitor and review AI-generated communications.

 

APPENDIX N

INTERNATIONAL COMPLIANCE MATRIX

United States

Applicable Laws:

    • TCPA
    • CAN-SPAM
    • FCC Regulations
    • State Privacy Laws

Requirements:

    • Prior express consent
    • Opt-out mechanisms
    • Record retention

Canada

Applicable Laws:

    • CASL
    • PIPEDA

Requirements:

    • Express consent
    • Unsubscribe functionality
    • Consent records

Colombia

Applicable Laws:

    • Law 1581 of 2012
    • Decree 1377 of 2013

Requirements:

    • Authorization
    • Habeas Data Rights
    • Notice of Processing

Brazil

Applicable Laws:

    • LGPD

Requirements:

    • Legal basis
    • Data subject rights
    • Security controls

Mexico

Applicable Laws:

    • LFPDPPP

Requirements:

    • Notice of Privacy
    • ARCO Rights
    • Consent Management

Peru

Applicable Laws:

    • Personal Data Protection Law

Requirements:

    • Consent
    • Registration obligations are applicable

Argentina

Applicable Laws:

    • Personal Data Protection Law No. 25,326

Requirements:

    • Data processing notice
    • User rights

Chile

Applicable Laws:

    • Personal Data Protection Framework

Requirements:

    • Notice
    • Consent
    • User access rights

Remaining Countries of the Americas

Where a recipient is located:

    • Antigua & Barbuda
    • Bahamas
    • Barbados
    • Belize
    • Bolivia
    • Costa Rica
    • Cuba
    • Dominica
    • Dominican Republic
    • Ecuador
    • El Salvador
    • Grenada
    • Guatemala
    • Guyana
    • Haiti
    • Honduras
    • Jamaica
    • Nicaragua
    • Panama
    • Paraguay
    • Saint Kitts & Nevis
    • Saint Lucia
    • Saint Vincent & the Grenadines
    • Suriname
    • Trinidad & Tobago
    • Uruguay
    • Venezuela

LiBe shall apply the highest available compliance standard from this Policy and comply with any additional local requirements that may apply.

 

LiBe Holdings S.A.S.

NIT: 902-043-981

Barranquilla, Atlántico, Colombia

All communication compliance requests, opt-outs, complaints, privacy concerns, regulatory inquiries, legal notices, and consent requests should be directed to: legal@letslibe.com

Last Updated: September 7, 2026

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