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Draft pending legal review

This text is a working draft. Items marked “to confirm” have not been verified yet.

Personal Data Processing Policy

Draft version of 29 September 2026 · Effective date: [to confirm]

1. Data controller

GRUPO BRIK S.A.S., NIT 900.951.177 [to confirm], domiciled in Medellín, Antioquia, Colombia [to confirm notice address], is the controller of the personal data collected through grupobrik.com, its forms, its WhatsApp and phone channels, and search alerts.

Controller contact: Write to us on WhatsApp [to confirm whether a dedicated data-protection address will be used] · +57 3176398104.

This policy is issued under Colombian Law 1581 of 2012, Decree 1377 of 2013 (compiled in Decree 1074 of 2015) and any rules that amend or complement them.

2. Data we process

  • Identification and contact data: first and last names, phone number and email address.
  • The message you write to us and the property you ask about (code and name).
  • Account data: the email used for your sign-in link, saved properties, comparisons and search alerts with their criteria.
  • Browsing data: IP address, device, pages visited and cookies (see section 8).

We do not request sensitive data or data about children or adolescents. If you send it to us in a free-text message, we will delete it.

3. Purposes

We process your data to:

  • Commercial contact: answer your requests, schedule visits and support you in buying, selling or renting a property.
  • Sending proposals: share property sheets and proposals that match what you are looking for, by email or WhatsApp.
  • Search alerts: email you when a property matching your alerts is published; you can turn them off from the link in each email or from your profile.
  • Analytics: measure how the site is used and how our campaigns perform, and improve our services.
  • Comply with legal and contractual obligations and requests from authorities.

[to confirm whether other purposes apply, such as screening against restrictive lists (SARLAFT) or satisfaction surveys].

4. Your rights (habeas data)

As the data subject you may, free of charge:

  • Access, update and correct your personal data.
  • Request proof of the authorization you gave us.
  • Be informed about how your data has been used.
  • Revoke your authorization and request deletion of your data when there is no legal or contractual duty to keep it.
  • File complaints with the Superintendencia de Industria y Comercio (SIC) after completing the inquiry or claim process with us.

5. Contact channel and procedure

Write to Write to us on WhatsApp [channel to confirm] with your name, your ID document, your specific request and a way to reply to you.

  • Inquiries: answered within ten (10) business days, extendable by five (5) more business days if we tell you why.
  • Claims (correction, update, deletion or revocation): handled within fifteen (15) business days, extendable by eight (8) more business days if we tell you why.

Team responsible for requests: [to confirm].

6. Processors, transmissions and transfers

To provide our services we share data with providers acting as data processors, some of them with servers outside Colombia (mainly the United States) [to confirm countries and transmission agreements]:

  • vTiger: the CRM where contact requests are recorded.
  • Google: Google Analytics (measurement), reCAPTCHA (spam protection) and Google Maps (maps).
  • Meta: the Meta pixel to measure and optimize campaigns.
  • Postmark: delivery of sign-in and alert emails.
  • Sentry: logging of technical errors on the site.
  • Amazon Web Services (AWS): storage of photos and files.
  • DigitalOcean: hosting of the site and its database.

We do not sell your personal data.

7. Security and retention

We apply reasonable technical and administrative measures to protect your data. We keep it for as long as needed for the purposes described and for the periods required by law [retention periods to confirm].

8. Cookies

We use first-party cookies needed for the site to work (for example, your account session) and third-party analytics and advertising cookies (Google Analytics and the Meta pixel). You can block or delete them in your browser settings. [to confirm once the cookie notice is in place].

9. Validity and changes

This policy applies from [date to confirm]. The databases remain in force for as long as the purposes described apply. If we make material changes we will announce them on this site before they take effect.

National Database Registry (RNBD): [registration with the SIC to confirm].

The Spanish version of this policy prevails in case of any discrepancy.

See also our Terms and Conditions.