Privacy Policy

Last updated: January 2026

At Strategiaandin S.A.S. (hereinafter "Strategiaandin," "we," or "the Company"), we are committed to protecting the privacy and personal data of our users, investors, and visitors to the strategiaandin.com website. This policy describes how we collect, use, store, and protect your personal information in accordance with Law 1581 of 2012, Decree 1377 of 2013, and current Colombian legislation on personal data protection.

1. Data Controller

Strategiaandin S.A.S., identified with NIT 901.456.789-3, with domicile at Carrera 11A #93-52, Oficina 401, Bogotá D.C., Colombia, is the entity responsible for the processing of personal data collected through this website and the real estate crowdfunding services it offers.

2. Personal Data We Collect

We collect the following types of information: identification data (full name, document number, date of birth), contact data (email address, phone number, address), financial data necessary for the investment process (banking information, investment history), browsing data (IP address, browser type, pages visited, time spent), and any other information you voluntarily provide through the forms on our website.

3. Purpose of Processing

We use your personal data to: manage your registration and account on the platform, process and administer investments in real estate projects, comply with legal and regulatory obligations before the Superintendencia Financiera de Colombia and other competent authorities, send you communications related to your investments and available opportunities, improve our services and user experience, and prevent fraud and ensure platform security.

4. Legal Basis for Processing

Data processing is carried out based on: your prior, express, and informed consent, the execution of the contractual relationship between you and Strategiaandin, compliance with applicable legal obligations (Law 1581 of 2012, Colombian financial and tax regulations), and the legitimate interest of Strategiaandin to improve its services and prevent fraudulent activities.

5. Data Transfer and Transmission

We may share your personal data with: developers and builders of the real estate projects in which you invest (exclusively the necessary information), financial entities for transaction processing, competent authorities when required by law, and technology service providers that process data on our behalf, under strict confidentiality and data protection agreements. We do not sell or transfer your personal information to third parties for commercial purposes.

6. Data Subject Rights

As a personal data subject, you have the right to: know, update, and rectify your personal data, request the deletion of your data when there is no legal obligation to retain it, revoke the authorization granted for the processing of your data, file complaints with the Superintendencia de Industria y Comercio (SIC) for violations of data protection law, and access your personal data that has been processed free of charge.

7. Security Measures

We implement reasonable 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, role-based access controls, continuous security monitoring, and periodic audits of our systems.

8. Retention Period

We retain your personal data for as long as necessary to fulfill the purposes described in this policy and in accordance with the deadlines established by applicable Colombian legislation. Investment-related data is retained for a minimum of ten (10) years in compliance with tax and financial regulations.

9. Contact and Service Channel

To exercise your rights as a personal data subject or for any inquiries related to this policy, you may write to us at: contacto@strategiaandin.com or visit us at Carrera 11A #93-52, Oficina 401, Bogotá D.C., Colombia. We will respond to your request within a maximum period of fifteen (15) business days.