Privacy Policy and
Personal Data Processing Notice

Article 1

Data Controller

Article 2

Legal Framework

This policy is governed by:

Article 3

Definitions

• Personal Data: Any information linked to, or that can be associated with, a natural person.
• Data Subject: The natural person whose personal data is being processed.
• Processing: Any operation on personal data (collection, storage, use, circulation, deletion).
• Data Controller: OWLY S.A.S., which decides how personal data is processed.
• Data Processor: Third parties that process data on behalf of OWLY S.A.S.

Article 4

Data We Collect

4.1 Identification Data

• Full name
• Identification number (national ID, tax ID)
• Email address
• Mobile phone number
• Home or work address

4.2 Browsing Data

• IP address
• Browser type
• Pages visited
• Time on site
• Cookies and similar technologies

4.3 Communication Data

• Messages sent and received via WhatsApp
• Emails
• Conversation history
• Communication preferences

4.4 Commercial Data

• Quote history
• Product and service preferences
• Interactions with real estate projects

Article 5

Purposes of Processing

Your personal data will be processed in order to:

5.1 Primary Purposes (Necessary)

• Manage business relationships
• Send quotes and proposals
• Handle requests, complaints and claims
• Fulfil contractual obligations
• Communicate the status of your requests

5.2 Secondary Purposes (Subject to consent)

• Send commercial and promotional information
• Send marketing communications via WhatsApp, email or SMS
• Run satisfaction surveys
• Perform statistical and market analysis
• Improve our products and services

Article 6

WhatsApp and Digital Channel Communication

6.1 Use of WhatsApp Business

OWLY S.A.S. uses the WhatsApp Business API (provided by Meta Platforms, Inc.) to:

• Send notifications about quotes and follow-ups
• Respond to customer enquiries
• Send reminders for appointments and site visits
• Share updates on real estate projects

6.2 WhatsApp Consent

By providing your phone number and accepting this policy, you authorise OWLY S.A.S. to:

• Send WhatsApp messages related to your requests
• Contact you for commercial follow-up
• Send notifications

6.3 Opting Out of Communications

You may opt out of WhatsApp communications at any time by:

• Replying "CANCELAR" to any message
• Emailing admin@owly.com.co
• Using our website

6.4 Meta Integration (Facebook/Instagram)

We may receive lead data from Facebook Lead Ads, Instagram Direct Messages and Facebook Messenger. That data is processed under the same terms set out in this policy.

Article 7

Sharing Data with Third Parties

7.1 Data Processors

We share data with providers that help us deliver our services:

7.2 International Transfers

Your data may be transferred to servers located in the United States. These providers meet protection standards equivalent to those required by Colombian law.

Article 8

Information Security

We implement technical and organisational measures:

• Encryption: Data in transit (TLS/SSL) and at rest (AES-256)
• Access control: Two-factor authentication, roles and permissions
• Monitoring: Detection of unauthorised access
• Backups: Periodic backup copies
• Training: Staff trained in data protection

8.1 OWLY S.A.S. Duties as Data Controller

OWLY S.A.S. undertakes to:

• Guarantee the data subject the full and effective exercise of the right to habeas data
• Request and retain a copy of the consent granted by the data subject
• Properly inform the data subject of the purpose of collection and of their rights
• Keep the information under security conditions that prevent tampering, loss or unauthorised access
• Ensure that information supplied to third parties is truthful, complete, accurate and up to date
• Correct information when it is inaccurate
• Handle enquiries and claims within the statutory deadlines
• Report breaches of security codes to the Superintendence of Industry and Commerce

8.2 Consent Process

OWLY S.A.S. requests prior, express and informed consent. Consent may be given through:

• A signed paper form
• An electronic form (web forms, email)
• Unambiguous conduct (voluntarily providing information)

For data collected before this policy took effect, OWLY S.A.S. sends a notice describing the processing and allows 30 days for the data subject to request deletion.

Article 9

Data Subject Rights (ARCO)

You have the right to:

9.1 How to Exercise Your Rights

Send your request to admin@owly.com.co with the subject "Ejercicio de Derechos ARCO", including:

• Your full name and identification number
• A detailed, clear and precise description of the request
• A reply address (email or postal)
• Supporting documents (if applicable)

If you submit the request on behalf of someone else, you must provide a power of attorney or the data subject’s authorisation, or evidence that you are their successor in title or legal representative.

9.2 Response Times

9.3 Exceptions to Deletion

OWLY S.A.S. may refuse to delete data when:

• The data subject has a legal or contractual duty to remain in the database
• Deletion would obstruct judicial or administrative proceedings
• The data is required for tax obligations or criminal investigations
• Deletion would make it impossible to provide a contracted service

9.4 Case Status Labels

Article 10

Cookies and Similar Technologies

You can configure your browser to reject cookies. Note that some features may then be unavailable.

Article 11

Minors

OWLY S.A.S. does not knowingly collect data from anyone under 18. If we identify a minor’s data, we delete it immediately.

Article 12

Data Retention

Article 13

Changes to This Policy

We reserve the right to amend this policy. Changes will be notified through:

• Publication on our website
• Email (for significant changes)

The last-updated date appears at the top of this document.

Article 14

Supervisory Authority

If you believe your rights have been infringed, you may file a complaint with:

Article 15

Contact

For any question about this policy:

Article 16

Acceptance

By using our services, providing your personal data or interacting with us via WhatsApp or other channels, you declare that you:

• Have read and understood this policy
• Accept the processing of your data as described herein
• Are over 18 or have the authorisation of your legal representative

© 2025 OWLY S.A.S. All rights reserved.