IMPORTANT NOTICE

This Personal Data Processing Policy (“Policy”) 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 Policy governs the collection, use, storage, processing, transmission, transfer, disclosure, retention, protection, deletion, and general handling of personal data obtained through any website, application, platform, marketplace, communication channel, property listing service, brokerage service, marketing service, advertising service, lead generation service, investment-related service, software product, subscription service, employment relationship, business relationship, or other offering operated by LiBe.

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

1. LEGAL FRAMEWORK

This Policy has been adopted in accordance with:

• Law 1581 of 2012 (Colombia)
• Decree 1377 of 2013 (Colombia)
• Decree 1074 of 2015 (Colombia)
• Law 1266 of 2008, where applicable
• Circulars and regulations issued by the Superintendence of Industry and Commerce (SIC)
• Brazil’s Lei Geral de Proteção de Dados (LGPD), where applicable
• Canada’s federal and provincial privacy laws, where applicable
• United States federal and state privacy laws, where applicable
• Mexico’s Federal Law on Protection of Personal Data Held by Private Parties, where applicable
• Applicable privacy, telecommunications, cybersecurity, consumer protection, employment, and data protection laws throughout the Americas

2. DATA CONTROLLER

The Data Controller responsible for personal data processing is:

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

NIT: 902-043-981

Barranquilla, Atlántico, Colombia

3. PERSONAL DATA WE COLLECT

LiBe may collect and process:

Identification Information

• Full name
• Government-issued identification numbers
• Passport information
• Driver’s license information
• Date of birth

Contact Information

• Email addresses
• Telephone numbers
• WhatsApp numbers
• Mailing addresses
• Property addresses

Real Estate Information

• Property ownership records
• Property interests
• Listing information
• Property inquiries
• Transaction information

Financial Information

• Payment information
• Billing information
• Financing information
• Investment-related information

Employment Information

• Professional background
• Employment history
• Business affiliations

Technical Information

• IP addresses
• Device identifiers
• Browser information
• Cookies
• Operating systems
• Website usage information

Marketing Information

• Communication preferences
• Marketing interests
• Lead source information
• Advertising interactions

4. PURPOSES OF PROCESSING

LiBe may process personal data for:

• Real estate services
• Brokerage services
• Property marketing
• Lead generation
• Customer relationship management
• Account administration
• Subscription management
• Identity verification
• Customer support
• Advertising services
• Marketing campaigns
• Email communications
• SMS communications
• WhatsApp communications
• Push notifications
• Social media communications
• Investment-related services
• Payment processing
• Fraud prevention
• Risk management
• Security monitoring
• Regulatory compliance
• Legal compliance
• Internal analytics
• Business operations
• Enforcement of contractual rights

5. AUTHORIZATION

LiBe may obtain authorization through:

• Written consent
• Electronic consent
• Website forms
• Account registration
• Service agreements
• Employment applications
• Communications
• Checkboxes
• Digital signatures
• Other legally recognized methods

Where required by law, consent shall be informed, prior, and express.

6. SENSITIVE PERSONAL DATA

LiBe generally does not require Sensitive Personal Data.

Where Sensitive Personal Data is processed:

• Collection shall be limited to legitimate purposes.
• Additional safeguards may be implemented.
• Explicit consent may be obtained where required.
• Data Subjects may decline to provide such information except where legally required.

Sensitive Personal Data may include:

• Health information
• Biometric information
• Religious beliefs
• Political opinions
• Sexual orientation
• Racial or ethnic origin

7. RIGHTS OF DATA SUBJECTS

Subject to applicable law, Data Subjects may:

• Access personal data
• Know how personal data is processed
• Update personal data
• Correct inaccurate information
• Request proof of authorization
• Revoke consent where applicable
• Request deletion where legally permissible
• Object to certain processing activities
• Submit complaints to competent authorities
• Exercise rights granted by applicable law

8. INTERNATIONAL DATA TRANSFERS

Personal data may be transferred, transmitted, processed, stored, or accessed in jurisdictions outside Colombia.

LiBe may use:

• Cloud service providers
• Technology providers
• CRM systems
• Marketing platforms
• Payment processors
• Business partners
• Affiliates

located in various jurisdictions.

Where applicable, reasonable contractual, technical, and organizational safeguards may be implemented.

9. DATA SHARING

LiBe may share information with:

• Affiliates
• Technology providers
• Service providers
• Payment processors
• Marketing providers
• Real estate professionals
• Legal advisors
• Auditors
• Government authorities
• Regulatory authorities
• Law enforcement agencies

where legally permitted or required.

10. SECURITY MEASURES

LiBe implements commercially reasonable administrative, technical, organizational, and physical safeguards designed to protect personal data against:

• Unauthorized access
• Unauthorized disclosure
• Loss
• Destruction
• Alteration
• Misuse

No security system can guarantee absolute protection.

11. DATA RETENTION

Personal data shall be retained only as long as necessary to:

• Fulfill legitimate business purposes
• Comply with legal obligations
• Resolve disputes
• Enforce agreements
• Maintain business records
• Protect legal rights

Retention periods may vary according to applicable laws.

12. MARKETING COMMUNICATIONS

LiBe may send:

• Emails
• SMS messages
• WhatsApp messages
• Telephone calls
• Push notifications
• Social media messages

regarding:

• Services
• Properties
• Promotions
• Investments
• Events
• Company updates

Users may opt out where required by applicable law.

13. COOKIES AND TRACKING TECHNOLOGIES

LiBe may use:

• Cookies
• Pixels
• Web beacons
• Analytics tools
• Similar technologies

for operational, analytical, security, personalization, and marketing purposes.

Users may manage preferences through browser settings, where available.

14. CHILDREN’S DATA

LiBe does not knowingly collect personal data from minors except where:

• Authorized by a parent or guardian;
• Permitted by law;
• Necessary for a lawful purpose.

The rights and interests of minors shall be protected in accordance with applicable law.

15. INTERNATIONAL APPLICABILITY AND MANDATORY LAW SAVINGS CLAUSE

This Policy is intended to apply throughout:

• United States
• Puerto Rico
• Canada
• Mexico
• Central America
• South America
• Caribbean jurisdictions

LiBe recognizes that privacy, consumer protection, telecommunications, cybersecurity, labor, and data protection laws vary among jurisdictions.

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

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

16. GOVERNING LAW

This Policy shall be governed by the laws of the Republic of Colombia.

17. JURISDICTION

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

Barranquilla, Atlántico, Colombia.

18. MODIFICATIONS

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

Updated versions shall become effective upon publication unless otherwise required by law.

Continued use of LiBe Services following publication of updates constitutes acknowledgment of the revised Policy.

LiBe Holdings, S.A.S.

NIT: 902-043-981

Barranquilla, Atlántico, Colombia

Puerto Rico Real Estate Broker License: C-17849

All privacy requests, compliance inquiries, consumer complaints, data subject requests, regulatory communications, and legal notices should be submitted to:

legal@letslibe.com

Last Updated: September 7, 2026