Privacy Policy

We collect personal data that you voluntarily provide when registering or using our real estate crowdfunding services:

• Identification data: full name, type and number of identity document, date of birth, nationality.
• Contact data: email address, phone number, residential address.
• Financial data: banking information necessary to process investments and return distributions.
• Browsing data: IP address, browser type, pages visited, time spent, cookies and similar technologies.
• KYC/AML verification data: documentation required by Colombian anti-money laundering regulations.

We use your personal data for the following purposes:

• Managing your account and investor profile on the platform.
• Processing your investments in real estate projects and distributing corresponding returns.
• Complying with legal and regulatory obligations before the Financial Superintendence of Colombia and the UIAF.
• Sending you communications related to your investments, project updates, and platform news.
• Improving our services through statistical and browsing behavior analysis.
• Preventing fraud, money laundering, and terrorist financing.

The processing of your data is based on:

• Your informed, prior, and express consent granted upon registering on the platform.
• Fulfillment of contractual obligations arising from your participation in investment projects.
• Compliance with legal duties under current Colombian legislation, including Law 1581 of 2012, the Tax Statute, and anti-money laundering regulations.
• Novumdigitalio's legitimate interest in improving its services and preventing fraudulent activities.

We may share your personal data with:

• Colombian financial entities for transaction processing.
• Competent authorities (Financial Superintendence, DIAN, UIAF) when required by law.
• Associated real estate developers, exclusively the information necessary for managing your investment.
• Technology service providers who assist us in platform operations, under confidentiality and data processing agreements.
• External auditors responsible for verifying regulatory compliance.

As a personal data subject, you have the right to:

• Know, update, and rectify your personal data.
• Request proof of the authorization granted.
• Be informed about the use given to your data.
• Revoke the authorization and/or request the deletion of your data when the legal principles, rights, and guarantees are not respected.
• Access your personal data that has been processed free of charge.
• File complaints before the Superintendence of Industry and Commerce (SIC) for violations of data protection law.

To exercise your rights, send a request to: privacidad@novumdigitalio.com

We implement technical, human, and administrative measures to protect your personal data against unauthorized access, loss, alteration, or destruction. These measures include data encryption in transit and at rest, multi-factor authentication, continuous access monitoring, and periodic security audits in accordance with international standards.

We retain your personal data for the time necessary to fulfill the described purposes and in accordance with the periods established by Colombian legislation. Financial and investment data is retained for a minimum of ten (10) years in accordance with the Commercial Code and current tax regulations.

We reserve the right to modify this Privacy Policy at any time. Modifications will take effect upon publication on the platform. We will notify you of substantial changes through your registered email address.

If you have questions or concerns about the processing of your personal data, you can contact us at:

Novumdigitalio S.A.S.
Carrera 7 #71-52, Torre B, Office 1201
Bogotá D.C., Colombia
Email: privacidad@novumdigitalio.com
Phone: +57 (601) 742-3891