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LOGO URBALIA

Privacy Policy

PERSONAL DATA PROCESSING AND PROTECTION POLICY

URBALIA S.A.S.

Effective date: August 8, 2026 Last updated: August 8, 2026

This English version is provided for the convenience of international clients. In the event of any discrepancy, the Spanish version published at urbalia.site/politica-de-privacidad shall prevail.

1. Identification of the data controller

URBALIA S.A.S., a Colombian company registered under tax ID (NIT) 901.952.682-6, domiciled in Bogotá D.C., Colombia — hereinafter Urbalia — is the data controller for the personal data described in this policy.

Urbalia is a real estate firm specializing in the marketing of high-value properties in Bogotá and Cundinamarca.

Contact channel for data protection matters:

Requests are handled electronically, which allows us to respond within the legal deadlines without requiring the data subject to travel.

This policy is issued in accordance with Law 1581 of 2012, Decree 1377 of 2013 and other applicable Colombian personal data protection regulations.

2. Scope

This policy applies to the personal data that Urbalia processes through its channels:

  • Website: urbalia.site and its forms.

  • WhatsApp: commercial service line, including conversations with our digital assistant.

  • Urbalia OS: our internal commercial management system.

It covers buyers, tenants, property owners, commercial partners and website visitors.

3. Definitions

  • Data subject: the natural person whose personal data is being processed.

  • Data controller: URBALIA S.A.S.

  • Data processor: a person or entity that processes personal data on behalf of Urbalia.

  • Authorization: the data subject's prior, express and informed consent.

  • Sensitive data: data affecting the data subject's privacy, or whose misuse could lead to discrimination.

  • Privacy notice: the brief communication provided to the data subject at the time their data is collected.

4. Authorization

Colombian law requires the data subject's authorization to be prior, express and informed, and requires the controller to be able to demonstrate it. Urbalia obtains it as follows:

4.1 When you write to us on WhatsApp

At the start of the conversation, within our first messages, we inform you that we store the conversation and your contact details in order to assist you, and we tell you where to find this policy. Continuing the conversation constitutes your authorization for the processing described here.

That communication is recorded in our system with its text and date, and constitutes proof of authorization.

4.2 When you complete a form on the website

Authorization is granted expressly upon submitting the form, after this policy has been made available to you.

4.3 Third-party data you provide to us

If you provide us with another person's data — for example, that of those accompanying you to view a property — we will ask you to confirm that you have that person's authorization to share it with Urbalia. You are responsible for holding such authorization.

4.4 Withdrawal

You may withdraw your authorization at any time by replying "stop" on WhatsApp or by writing to the email address in section 1. The request is honored immediately and permanently, unless a legal or contractual obligation requires us to retain certain information.

5. Data we collect

5.1 From those looking to buy or rent

  • Identification and contact details: full name, telephone number and email address.

  • Search criteria: area of interest, budget, property type, timeline, involvement of third parties in the decision, and any other preferences you share.

  • Relationship history: conversations held with Urbalia, properties viewed, materials sent and your comments on each property.

  • Data for property visits: see section 7.

5.2 From those entrusting Urbalia with the sale or rental of their property

  • Identification and contact details of the owner.

  • Property information: location, characteristics, asking price, photographs, HOA fees and property tax.

  • Documentation: certificate of title (certificado de tradición y libertad), brokerage agreement and other documents required for marketing the property.

  • Context of the transaction: expected timeline and reason for the sale, when the owner chooses to share them.

5.3 From website visitors

IP address, browser type, approximate location and data collected through cookies or similar technologies.

5.4 Sensitive data

Urbalia does not request sensitive data — such as ethnic origin, political or religious beliefs, health data, biometric data or sexual orientation — and does not require it to provide its services. Data subjects are under no obligation to provide it.

6. Use of artificial intelligence

Urbalia's WhatsApp line is served by a digital assistant powered by artificial intelligence. We state this expressly because you have the right to know the nature of the party you are communicating with.

What the assistant does:

  • Reads and responds to your messages.

  • Recommends properties, sends materials, coordinates visits and follows up on your enquiry.

  • Records relevant information from the conversation in Urbalia's system.

Limits established by Urbalia:

  • It makes no financial decisions. Accepting an offer, closing a transaction and setting a price are always decisions made by a person at Urbalia.

  • It does not replace a human advisor. You may ask to be assisted by a member of our team at any time.

  • It does not conceal its nature. If you ask whether you are speaking with a person, the assistant will tell you the truth.

To provide this service, the content of conversations is processed by the data processors listed in section 9.

7. Identity documents for property visits

To visit a property, Urbalia requires the full name and identity document number of every person attending, together with the vehicle license plate where applicable.

Purpose: the residential complexes and buildings where our properties are located require this information in order to authorize entry. Without it, the visit cannot take place.

Urbalia's commitments regarding this data:

  • It is used solely to authorize access to the property.

  • It is shared exclusively with the management or security desk of the relevant complex.

  • It is not used for commercial purposes, is not transferred to third parties, and is not cross-referenced with other databases.

  • It is retained only for as long as necessary for the visit and its record, as set out in section 10.

When you attend accompanied, Urbalia will ask you to confirm that you have your companions' authorization to share their data with the property management.

8. Purposes of processing

Urbalia processes personal data in order to:

  1. Attend to your enquiry and recommend properties matching your criteria.

  2. Coordinate and confirm visits, and manage access to residential complexes.

  3. Follow up commercially on your interest and keep you informed about relevant properties.

  4. Market the property of those who entrust us with its sale or rental, and report periodically on its performance.

  5. Produce internal statistics and improve the quality of our service.

  6. Comply with legal, contractual, accounting and tax obligations.

  7. Prevent fraud and protect the rights of Urbalia and its clients.

Commercial communications. Urbalia will contact you on WhatsApp within the framework of the commercial relationship you initiated. You may ask us to stop at any time, as set out in section 4.4.

9. Data processors and international transfers

Urbalia does not sell or rent personal data.

To operate, your information is processed by the following data processors, each for the stated purpose and under confidentiality and security obligations. All of them are located outside Colombia:

  • Meta Platforms, the company that owns WhatsApp: provision of the messaging channel.

  • Anthropic: processing of conversations through artificial intelligence.

  • Railway: hosting of the system and its database.

  • Google: corporate email and backups.

International transfer. By granting authorization under section 4, you expressly authorize your data to be processed by the processors listed above in countries other than Colombia, under adequate standards of security and confidentiality.

Urbalia may also share information with:

  • Property owners and residential complex management, limited strictly to what is necessary to authorize and coordinate a visit.

  • Competent authorities, where legally required.

  • Legal, accounting or financial advisors involved in a specific transaction.

Urbalia does not share one client's contact information with other clients, nor does it transfer data to third parties for advertising purposes unrelated to Urbalia.

10. Data retention

  • Data and conversations of active clients: for the duration of the commercial relationship.

  • Inactive clients: two (2) years from the last contact, unless deletion is requested.

  • Identity documents for visits: only for as long as necessary for the visit and its record.

  • Documentation of closed transactions: for the period required by Colombian law for contractual, accounting and tax purposes.

  • Browsing data: according to the lifespan of the relevant cookies.

Once these periods expire, the data is deleted or anonymized.

11. Rights of the data subject

Under Article 8 of Law 1581 of 2012, you have the right to:

  1. Access, update and rectify your personal data.

  2. Request proof of the authorization granted to Urbalia.

  3. Be informed about the use made of your personal data.

  4. File complaints with the Superintendence of Industry and Commerce (Superintendencia de Industria y Comercio) for breaches of the law.

  5. Withdraw authorization and request deletion of your data, where no legal or contractual duty prevents it.

  6. Access your personal data free of charge.

12. How to exercise your rights

Channels: email nhernandez@urbalia.site or WhatsApp +57 313 232 9299.

What to include: your name, a contact detail, a description of the facts giving rise to the request, and any supporting documents.

Response times, as required by law:

  • Enquiries: ten (10) business days, extendable by a further five (5) business days.

  • Claims: fifteen (15) business days, extendable by a further eight (8) business days.

If a claim is incomplete, Urbalia will request the missing information within the following five (5) days. If two (2) months pass without the requested information being provided, the claim will be deemed withdrawn.

You may escalate to the Superintendence of Industry and Commerce once the procedure before Urbalia has been exhausted.

13. Information security

Urbalia applies technical, administrative and physical measures to protect personal data:

  • Restricted access limited to authorized personnel, with each consultation logged.

  • Strong authentication for access to internal systems.

  • Encryption of data in transit.

  • Regular, verified backups stored outside the primary system.

  • Role-based segregation of information: each team member accesses only what their role requires.

No transmission over the internet is completely secure, so absolute security cannot be guaranteed. Should an incident affecting personal data occur, Urbalia will notify the data subject and report it to the competent authority as required by law.

14. Minors

Urbalia's services are intended for adults. Urbalia does not knowingly collect personal data from minors. If we detect that we have received information from a minor without the authorization of their legal guardians, it will be deleted.

15. Cookies

The website uses cookies to improve the browsing experience. Users may configure their browser to reject them, with the caveat that some functionality may be affected.

16. Term and amendments

This policy is effective as of August 8, 2026 and will remain in force for as long as Urbalia conducts its business. Databases will be retained for the periods set out in section 10.

Urbalia may amend this policy when its services or applicable regulations change. The current version will always be published on this page with its update date. Material changes will be communicated through the available contact channels.

17. Contact

URBALIA S.A.S. Tax ID (NIT) 901.952.682-6 Bogotá D.C., Colombia

nhernandez@urbalia.site +57 313 232 9299

Urbalia treats its clients' information with the same discretion it brings to the properties it represents.

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