IMPORTANT NOTICE

This Privacy 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 Privacy Policy governs the collection, use, storage, processing, transmission, transfer, disclosure, retention, protection, deletion, and general handling of personal information 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 Privacy Policy.

1. OUR COMMITMENT TO PRIVACY

LiBe is committed to protecting the privacy, confidentiality, integrity, and security of personal information. We strive to process personal information in a transparent, lawful, fair, and responsible manner and to comply with applicable privacy, data protection, cybersecurity, consumer protection, telecommunications, and employment laws throughout the Americas.

2. APPLICABLE LAWS

This Policy is intended to comply with applicable laws, including, where applicable:

• Law 1581 of 2012 (Colombia)
• Decree 1377 of 2013 (Colombia)
• Decree 1074 of 2015 (Colombia)
• Brazil’s LGPD
• Canada’s PIPEDA and applicable provincial laws
• United States federal and state privacy laws
• Mexico’s Federal Law on Protection of Personal Data Held by Private Parties
• Argentina Personal Data Protection Law
• Uruguay Personal Data Protection Law
• Peru Personal Data Protection Law
• Chilean privacy regulations
• Caribbean privacy regulations
• Other applicable privacy and consumer protection laws throughout the Americas

3. INFORMATION WE COLLECT

LiBe may collect:

Identification Information

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

Contact Information

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

Real Estate Information

• Property ownership information
• Property inquiries
• Property preferences
• Property transaction information
• Listing information

Financial Information

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

Employment Information

• Employment history
• Professional qualifications
• Business affiliations

Technical Information

• IP addresses
• Device identifiers
• Browser information
• Cookies
• Website usage information
• Mobile application activity

Marketing Information

• Communication preferences
• Lead information
• Advertising interactions
• Customer interests

4. PURPOSES OF PROCESSING

Personal information may be used for:

• Real estate services
• Brokerage services
• Property marketing
• Lead generation
• Customer support
• Account administration
• Payment processing
• Fraud prevention
• Security monitoring
• Marketing campaigns
• Email communications
• SMS communications
• WhatsApp communications
• Push notifications
• Social media communications
• Investment-related services
• Analytics
• Legal compliance
• Regulatory compliance
• Business operations
• Contract administration

5. LEGAL BASIS FOR PROCESSING

Where applicable, LiBe may process information based upon:

• Consent
• Contractual necessity
• Legal obligations
• Legitimate business interests
• Fraud prevention
• Security requirements
• Regulatory compliance
• Establishment, exercise, or defense of legal claims
• Other lawful grounds recognized under applicable law

6. COMMUNICATIONS

LiBe may communicate with users through:

• Email
• SMS
• WhatsApp
• Telephone
• Push notifications
• Social media messaging
• In-app messaging
• Future communication technologies

Communications may include:

• Property updates
• Listing alerts
• Account notifications
• Customer support responses
• Marketing communications
• Promotional offers
• Security alerts
• Transaction updates

Users may opt out of marketing communications where required by law.

7. COOKIES AND TRACKING TECHNOLOGIES

LiBe may use:

• Cookies
• Pixels
• Web beacons
• Tags
• Analytics tools
• Advertising technologies

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

8. INFORMATION SHARING

LiBe may share information with:

• Affiliates
• Brokers
• Agents
• Service providers
• Technology providers
• Marketing providers
• Payment processors
• Legal advisors
• Auditors
• Government authorities
• Regulatory agencies
• Law enforcement authorities

where legally permitted or required.

9. INTERNATIONAL DATA TRANSFERS

Personal information may be transferred, processed, stored, or accessed outside a user’s country of residence.

By using LiBe Services, users acknowledge and consent to international data transfers subject to applicable legal protections and safeguards.

10. CONSUMER PRIVACY RIGHTS

Depending on applicable law, users may have the right to:

• Access information
• Correct information
• Update information
• Delete information
• Restrict processing
• Object to processing
• Withdraw consent
• Request portability
• Appeal decisions
• Receive equal treatment regardless of exercising privacy rights

11. NO SALE OF PERSONAL INFORMATION

Unless expressly disclosed otherwise, LiBe does not sell personal information in exchange for monetary compensation as traditionally defined under applicable privacy laws.

12. AUTOMATED DECISION-MAKING AND AI

LiBe may utilize:

• Artificial intelligence
• Machine learning
• Lead scoring systems
• Recommendation engines
• Marketing automation
• Customer service automation

Automated systems may influence recommendations, marketing, lead qualification, or service delivery.

LiBe does not guarantee the accuracy of automated outputs.

13. AML, KYC, AND REGULATORY COMPLIANCE

Where required by law, LiBe may collect:

• Identity documents
• Beneficial ownership information
• Source-of-funds information
• Corporate records
• Compliance documentation

LiBe reserves the right to refuse services where compliance requirements cannot be satisfied.

14. BUSINESS TRANSFERS

Personal information may be transferred during:

• Mergers
• Acquisitions
• Reorganizations
• Asset sales
• Financing transactions
• Corporate restructurings

subject to applicable law.

15. DATA RETENTION

Personal information shall be retained only for as long as reasonably necessary to:

• Provide services
• Fulfill legal obligations
• Resolve disputes
• Protect legal rights
• Enforce agreements
• Maintain business records

16. SECURITY

LiBe implements commercially reasonable administrative, technical, organizational, and physical safeguards designed to protect personal information.

No system can guarantee absolute security.

17. DATA BREACH RESPONSE

LiBe maintains incident response procedures and may, following a security incident, notify affected individuals, regulators, law enforcement authorities, or other entities as required by law.

18. CHILDREN’S PRIVACY

LiBe does not knowingly collect personal information from minors except where authorized by a parent or guardian, required by law, or necessary for lawful business purposes.

19. THIRD-PARTY WEBSITES

LiBe is not responsible for:

• Third-party privacy practices
• Third-party content
• Third-party policies
• Third-party security practices

Users should independently review third-party policies.

20. CLASS ACTION WAIVER SAVINGS CLAUSE

To the fullest extent permitted by law, users agree to pursue claims individually and not as part of:

• Class actions
• Collective actions
• Representative actions
• Mass actions

Where prohibited by law, applicable legal protections shall prevail.

21. INTERNATIONAL APPLICABILITY AND MANDATORY LAW SAVINGS CLAUSE

This Privacy Policy is intended to apply throughout:

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

Nothing in this Privacy Policy shall limit any non-waivable rights granted under applicable privacy, consumer protection, telecommunications, cybersecurity, employment, or data protection laws.

Where local law grants rights, protections, disclosures, restrictions, obligations, 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.

22. GOVERNING LAW

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

23. JURISDICTION

Except where prohibited by mandatory law, disputes relating to this Privacy Policy shall be subject exclusively to the courts located in Barranquilla, Atlántico, Colombia.

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 Update: September 7, 2026