POLICY FOR THE PROCESSING OF PERSONAL DATA

OF VIVEFY.CO

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For VIVEFY, it is essential to inform our Users and other visitors to the Portal www.vivefy.co about the rights, protection, and current legal regulations that their personal data will have when registering their data for real estate market studies on the Portal.

IDENTIFICATION OF THE PERSONAL DATA PROCESSING RESPONSIBLE PARTY

The party responsible for processing the personal data authorized and granted by Subscribers will be the VIVEFY Portal, whose details are as follows:

Address: Calle 114a #19a-36

Phone: 313456666

Email: vivefy1@gmail.com

CURRENT LEGAL FRAMEWORK

The current legal framework regarding the protection and processing of personal data includes:

Law 1266 of 2008

Statutory Law 1581 of 2012

Regulatory Decrees 1727 of 2009

Regulatory Decrees 2952 of 2010

Partial Regulatory Decrees 1377 of 2013

DEFINITIONS

In accordance with Statutory Law 1581 of 2012 and other legal sources, the following definitions are provided:

Data Subject: Natural person whose personal data will be processed.

Processing: Any operation or set of operations on personal data, such as collection, storage, use, circulation, or deletion.

Authorization: Prior, express, and informed consent of the Data Subject necessary for the processing of personal data.

Privacy Notice: A verbal or written communication generated by the data processing controller informing about the existence, application, and purposes of the Personal Data Processing Policies.

Database: An organized and stored set of personal data provided by subscribers that will be processed by the Portal.

Personal Data: Any information linked or associated with one or more natural persons who can be identified.

Public Data: Data that is not semi-private, private, or sensitive. Public data can be publicly available, such as marital status, profession or occupation, and the status of being a merchant or public servant.

Sensitive Data: Data that can affect the privacy of the Data Subject or whose misuse could lead to discrimination. This includes data revealing racial or ethnic origin, political orientation, religious or philosophical beliefs, membership in unions, social organizations, human rights organizations, or promoting any political interest. It also includes data related to health, sexual life, or biometric data.

Data Processor: A natural or legal person, public or private, who, by itself or in association with others, will process personal data on behalf of the data processing controller.

Data Processing Responsibility: The natural or legal person, public or private, responsible for deciding not only to store the personal database but also for processing the data.

PRINCIPLES

According to Statutory Law 1581 of 2012, the following principles are established:

Principle of Legality in Personal Data Processing: Data processing under this law is a regulated activity that must comply with its provisions and other applicable regulations.

Principle of Purpose: Processing must comply with a legitimate purpose according to the Constitution and the Law, which must be communicated to the Data Subject.

Principle of Freedom: Processing can only be carried out with the prior, express, and informed consent of the Data Subject.

Principle of Veracity or Quality: Processed information must be truthful, complete, accurate, up-to-date, verifiable, and understandable.

Principle of Transparency: Data Subjects have the right to obtain information about their data from VIVEFY at any time without restrictions.

Principle of Restricted Access and Circulation: Processing is subject to limits derived from the nature of personal data and legal provisions.

Principle of Security: Information subject to processing must be handled with technical, human, and administrative measures to provide security and prevent unauthorized access.

Principle of Confidentiality: Everyone involved in personal data processing must ensure the confidentiality of the information, even after their relationship with data processing activities ends.

AUTHORIZATION OF THE PERSONAL DATA PROCESSING POLICY

According to Article nine (09) of Law 1581 of 2012, the processing of personal data requires the prior and informed authorization of the Data Subjects. Once the Data Subjects accept the Personal Data Processing Policies stated here, it is understood that they voluntarily consent to the processing of their personal data by VIVEFY, following the policies established here.

RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

VIVEFY will be responsible for the processing of the personal data of natural persons contained in the Portal's databases. In this regard, for the proper development of the company's commercial activities, as well as for strengthening it with third parties, VIVEFY will collect, store, and use the personal data corresponding to natural persons contained in the databases. This is done in accordance with national laws and the policies established here.

The Data Subject agrees that the information processed by this Portal may be delivered and/or transferred to companies and/or natural or legal persons outside of Colombia. This may involve an international transfer of personal data. However, the Portal will not be responsible for any improper or inappropriate use of personal information delivered to third parties when these third parties directly receive and/or request or process the personal information of the Data Subjects as responsible for its processing.

PURPOSE OF PERSONAL DATA

The personal data processed by VIVEFY is intended for:

Storing the provided data, recording incoming and outgoing calls, outgoing and incoming emails from the Data Subject and the Portal.

Contacting Users for commercial, advertising purposes, and all activities in order to fulfill the Object of the VIVEFY Portal.

Using the data provided by the Portal to fulfill the purposes of sending and disseminating advertising information related to the Portal.

Conducting market studies and creating profiles of Users to determine the object and scope of the Users, to adapt them to the needs and real estate projects for the market studies to be carried out.

Transferring the personal data and information provided to the Portal by the Owner to third parties, suppliers, contractors, and business partners of the Portal, in order to effectively carry out the requirements of the Users.

Complying with the information requirements and SAGRILAFT policies established by national and international authorities.

Other activities that seek to fulfill the Object of the Portal, related to the real estate market studies to be carried out.

Adapting the Portal when necessary to the tastes and needs of Users. This is done in accordance with surveys, commercial and advertising studies.

Informing about changes, updates, or modifications to our Service Content, rates, changes in our Terms and Conditions, technical support, events, promotions, among many other purposes focused on the interest and benefit of the subscriber.

Promoting products, events, contents, whether own or third-party, to enrich the Content of the Portal web Service and inform about new real estate projects in Colombia and other countries in Latin America to Users who have provided their data.

Preventing and detecting possible illegal conduct.

Ensuring the security and integrity of the web Portal.

In any case, in accordance with current regulations and the Personal Data Processing Policy, the Data Subject may rectify, withdraw, and/or request any changes to the information stored by the Portal and/or request not to receive advertising information.

DELIVERY OF PERSONAL DATA TO THIRD PARTIES

The User accepts that the information processed by this Portal may be delivered and/or transferred to companies outside of Colombia, which may imply an international transfer of personal data. Notwithstanding the foregoing, the Portal will not be responsible for any improper or inappropriate use of personal information delivered to third parties when these third parties directly receive and/or request or process the personal information of the Holders as responsible for the processing.

INDUSTRIAL AND INTELLECTUAL PROPERTY

The User acknowledges and consents that the copyright, rights to registered trademarks, and other industrial and intellectual property rights over the materials or contents contributed as part of the website belong to the Portal or those who have granted the license for their use. The User may use such material only in the manner authorized by the Portal or by those who granted a license for its use. This will not prevent the User from using this website to the extent necessary to copy information about their order or contact details.

VIRUSES, PIRACY, AND OTHER CYBER ATTACKS

The User must not misuse the Portal by intentionally introducing viruses, trojans, worms, logic bombs, or any other program or material that is technologically harmful or damaging. The User will not attempt to gain unauthorized access to this website, the server on which this page is hosted, or any server, computer, or database related to our website. The User agrees not to attack this website through a denial-of-service attack or a distributed denial-of-service attack. The breach of this clause could imply the commission of crimes typified by the applicable regulations. The Portal will inform the competent authorities of any breach of said regulations and will cooperate with them to discover the identity of the attacker. Likewise, in the event of a breach of this clause, the User will immediately cease to be authorized to use this website. The Portal will not be responsible for any damage or loss resulting from a denial-of-service attack, virus, or any other technologically harmful or damaging program or material that may affect the User's computer, computer equipment, data, or materials as a result of using this website or downloading content from it or to which it redirects.

LINKS FROM THE PORTAL

In the event that the Portal contains links to other websites and materials from third parties, such links are provided solely for informational purposes, without the Portal having any control over the content of such websites or materials. Therefore, the Portal accepts no responsibility for any damage or loss arising from their use.

WRITTEN COMMUNICATIONS

Applicable regulations require that part of the information or communications that the Portal sends will be in writing. By using this website, the User agrees that most of these communications with the Portal will be electronic. The Portal will contact the User by email or provide information by posting notices on this website. For contractual purposes, the User consents to the use of this electronic means of communication and acknowledges that all contracts, notices, information, and other communications that the Portal sends to them electronically comply with the legal requirements of being in writing. This condition will not affect the rights recognized by law to the User.

RIGHT TO MODIFY TERMS AND CONDITIONS

The Portal reserves the right to modify the Terms and Conditions at any time. The effects of any modification made by the Portal will take place from the publication of the same. If the User does not agree with the introduced modifications, it is recommended not to use the Portal.

APPLICABLE LEGISLATION AND JURISDICTION

The use of the Portal and the contracts for the purchase of products through said website will be governed by Colombian law. Any dispute that arises or is related to the use of the website or such contracts will be subject to the exclusive jurisdiction of the courts and tribunals of the Republic of Colombia. If the User is contracting as a consumer, nothing in this clause will affect the rights recognized by law to the User.

COMMENTS, SUGGESTIONS, COMPLAINTS, AND CLAIMS

Comments and suggestions will be well-received. Comments, suggestions, as well as any queries, complaints, or claims, can be sent via email to: vivefy1@gmail.com or by phone at 316666666. Complaints and claims to customer service will be addressed within a period of 20 business days and, in any case, within the legally established period. Likewise, they will be recorded with an identification code that will be made known to the User and will allow them to follow up on them.