PRIVACY POLICY

Effective Date: September 30, 2024

SAKARA Group (collectively, “SAKARA,” “we,” “us,” or “our”) are committed to protecting the privacy of identifiable individuals through our compliance with this Privacy Policy. We have created this Privacy Policy to inform you of our policies regarding the collection, use and disclosure of personal information as well as the rights and choices you have associated with that information.

This Privacy Policy applies to all personal information collected during any written, electronic, and oral communications or collected online or offline or to provide you with our services (the “Services”). Such personal information may be collected in the following manners:

• our website located at www.sakaragroup.com and all corresponding webpages and websites that link to this Privacy Policy (the “Site”);
• any mobile applications that link to this Privacy Policy (e.g., Apple iOS Apps, etc);
• when you interact with our advertising and applications on third party websites and services, if the advertising and applications include links to this Privacy Policy;
• via email or phone; and
• in person at our offices.

By using our Services, you consent to the collection and use of the personal information in accordance with this Privacy Policy. If you do not feel comfortable with any part of this Privacy Policy, you should not use or access our Site or Services.

We may update this Privacy Policy from time to time and make changes to information previously collected, as permitted by law. If we make material changes, we will post the updated Privacy Policy on this page with the “Effective Date” of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this date when you access our Site. Your continued use of the Services following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendments.

Please note that our Site may contain links to third-party websites, such as social media pages. These links are intended for your convenience only. These third-party websites and services are not related to us and may have separate privacy policies and data collection practices. We have no responsibility for these websites or their privacy practices and encourage users to read the privacy policies of all websites they visit.

1. Information We Collect and How We Collect It

We may collect your personal information when you interact with our Site, mobile applications, with us over email or phone and at physical locations. Personal information or personal data is generally any information that relates to you, identifies you personally, or could be used to identify you including, but not limited to: your name, mailing address, email address, telephone number, or any other information.  The definition of personal information or personal data depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Policy.

The types of personal information that we may collect about you include but are not limited to: information you provide to us, information collected automatically about your use of our Site and Services, information from other sources to help us supplement our records, improve the personalization of our service to you, promote safety at our apartment communities and other properties we control, and/or detect fraud.

Information You Voluntarily Provide to Us. The personal information we collect on or through our Site or Services may include:

• Contact information, such as your name, address, email, and phone number.
• Unique personal identifiers, such as SSN or TIN.
• If applicable, loan information, financial statements and records (and related documents), and required verifications.
• Payment card information, wire instructions, transaction, bank or financial account information;
• Information you provide by filling in forms that we make available.
• Information you provide when you report a problem with our Site or an in-person location, a payment or other transaction with us by email, our Site, telephone, in writing or through other means.
• Records and copies of your correspondence (including email addresses), if you contact us.

Information from Third Parties. We may receive information about you from other sources and combine that information with the personal information we collect directly from you. For example, we may receive payment information from the organization you use to pay us to correct our records. Additionally, we may collect credit or identity information, as well as conduct civil and criminal background checks, which we use to help prevent and detect fraud or to assist us in maintaining safety at our apartment communities and other properties we control.

Information Collected from Other Sources. We may receive information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud.

Information Collected Automatically. As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Site, including, but not limited to, traffic data, location data, logs and other communication data and the resources that you access and use on the Site.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• Information about the type of device you are using, mobile ad identifiers, the time and length of your visit, the website that referred you to our website, and the subject of the ads you click or scroll over.
• Information about your preferences to make your use of the Site more productive, via the use of Cookies. For more information on Cookies, please see Section 2.

2. Cookies and Other Tracking Technologies

We may use cookies, embedded scripts, software development kits (“SDKs”) and other similar tracking technologies (collectively, “Tracking Technologies”) to collect additional personal information automatically as you interact with the Services and to personalize your experience with our Services. We also may use these technologies to collect information about your online activities over time and across third party websites or other online services (“behavioral tracking”).

Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the Site’s or provider’s system to recognize your browser and remember certain information. We use first-party and third-party cookies for the following purposes: to make our Services function properly, to improve our Services, to make login to our Site or Services easier (such as by remembering your User ID), to recognize you when you return to our Site, to track your interaction with the Site, to enhance your experience with the Site, to remember information you have already provided, to collect information about your activities over time and across third party websites or other online Services in order to deliver content and advertising tailored to your interests; and to provide a secure browsing experience during your use of our Site. The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted.

We may place cookies from third-party service providers who may use information about your visits to other websites to target advertisements for products and Services available from us. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party’s website for more information on how they use cookies. The following types of cookies are used on our Site:

• Strictly Necessary Cookies. These cookies are essential because they enable you to use our Site. For example, strictly necessary cookies allow you to access secure areas on our Site. Without these cookies, some Site cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Site to work and they cannot be disabled.
• Functional or Preference Cookies. We use functional cookies to remember your choices so we can tailor our Site to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Site. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Site.
• Performance or Analytic Cookies. These cookies collect passive information about how you use our Site, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Site. We do not use these cookies to target you with online marketing. You can disable these cookies.

Use of Cookies in E-Mails. We send marketing e-mails on behalf of SAKARA and its affiliates. There are no cookies in the e-mail. However, when an e-mail recipient clicks on a link provided in a marketing email of SAKARA or its affiliates, a persistent cookie is placed on the user’s computer which is used to measure the effectiveness of the e-mail marketing efforts by helping to better understand how our users navigate through the site. The cookie will remain on your hard drive 30 days after the last time you clicked on the coded link in the e-mail, or until you delete it. These cookies do not corrupt or damage your computer or computer files. In addition, we do not use cookies to gather information concerning your visits to websites belonging to parties other than SAKARA.

Pixel Tags. To track the effectiveness of the advertisements of SAKARA or its affiliates, we may use pixel tags (also known as clear gifs, beacon gifs, 1-by-1 gifs, or web bugs). Pixel tags are not visible to the user of the site and consist of a few lines of computer coding. If you are visiting www.SAKARAgroup.com from an advertisement on another site, the pixel tag references the cookie you received when you clicked on the advertisement. The pixel tag then registers this activity to allow us to count the number of times an advertisement is accessed. In addition, we also measure the requests generated from a particular ad. We may use pixel tags in marketing e-mails that helps us send the e-mail in a format you can read and allows us to know which e-mails you act upon.

Analytics. We may use third-party service providers to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic.

For your choices in relation to cookies, please see the section below entitled Choices and Rights.

3. How We Use Your Information

We use your personal information as described in this Policy for business and commercial purposes, or as disclosed to you prior to such processing taking place. We may process your personal information for the reasons described below.

• To Provide SAKARA’s Services. We will use your personal information to provide information or perform Services that you request, including request for information. We work diligently with such third parties to protect your information.
• To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to fulfill our business obligations, ensure compliance with education and student information protection laws, to manage risk as required under applicable laws and regulations, or to respond to requests by judicial process or governmental agency.
• To Enforce Compliance with Our Terms, Agreements and Policies. When you access or use our Services, you are bound to our Terms. We may process your personal information for compliance purposes, such as carrying out our obligations and enforcing our Terms or other legal rights, including those arising from any contracts entered between you and us, including for billing and collection.
• To Detect and Prevent Fraud and Security Risks. We may process your personal information to help monitor, prevent, and detect fraud and abusive use of our Service, monitor, and verify your identity so that unauthorized users do not gain access to your information, enhance system security, and combat spam, malware, malicious activities, or other security risks.
• To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure your continued use and satisfaction of the Services. Additionally, we may copy your data into other tools as we act upon your suggestions. You may withdraw from participation in the portals by sending us an email.
• To Provide You with Service-Related Communications. We will send you administrative or account-related information to keep you updated about your account and the Services. Such communications may include information about Privacy Policy updates, security updates, tips, or other relevant transaction-related information. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Services.
• To Provide Marketing Communication. We may collect your email address, phone number or other electronic addresses that you voluntarily provide to us when you subscribe to our marketing communications. We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. We will occasionally send you information on products, services, and promotions. When you no longer wish to receive these marketing messages from us, you can opt out at any time by unsubscribing or following the instructions contained within such messages by emailing us.
• To Research and Develop of Our Services. We may process your personal information and derive analytical and statistical data to better understand the way you use and interact with our Services. For instance, analyzing where, on which types of devices and how our Site is used, how many visitors we receive, and where they click on the Site may help us improve our existing Services and to build new Services. Please see our Cookies and Other Tracking Technologies section for more information.
• To Personalize Your Experience. We may process your information to personalize your experience. By personalization, we enable you to interact with our Services more easily across platforms and devices.
• To Facilitate Corporate Acquisitions, Mergers and Transactions. We may process any information regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions.
• With Your Consent. For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction.

4. Sharing and Disclosure of Personal Information

We share your personal information as needed to fulfill the purposes described in this Policy and as permitted by applicable law. We may disclose your personal information as described below.

• As Required by Law. We may access, preserve, and disclose information about you if we believe doing so is required or appropriate to (a) comply with law enforcement requests and legal processes, such as a court order or subpoena; (b) comply with requests from auditors, examiners, or other regulators; (c) respond to your requests; or (d) protect your, our, or others’ rights, property, or safety.
• Within Our Corporate Organization. We may share your personal information within our organization to provide you with the Services and take actions based on your request.
• With Our Service Providers. We may share your personal information with third-party service providers acting on our behalf to help us operate our Services. Service providers and vendors provide us with support services such as credit card processing, website hosting, single-sign-on, community and feedback management, analytics services, surveys and research services, and network maintenance. These third parties can only use your information in accordance with our written instructions and must comply with the information security protections we have put in place.
• During Business Transaction or Other Asset Transfers. We may disclose and transfer information about you to buyers, service providers, advisors, potential transactional partners or other third parties in connection with the advisors, potential transactional partners or other third parties of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets. By engaging with us or using our Services, you understand and agree to our assignment or transfer of rights to your personal information. In the event of any such change in ownership or control of your personal information, we will notify you of such changes to the extent required under applicable law.
• With Our Business Partners. Subject to applicable law, we may share your personal information with our business partners, such as, for permitted marketing purposes, or for co-sponsored events based on your voluntary participation.
• With Your Consent. We may share your personal information for any purpose with your consent.

5. Legal Basis for Processing

Our legal bases for processing your information under the applicable data protection laws will depend on the personal information at issue, the specific context in which the personal data is collected and the purposes for which it is used. We generally only process your data where we are legally required to; where processing is necessary to perform any contracts we entered with you or to take steps at your request prior to entering into a contract with you; where processing is in our legitimate interests to operate our business and not overridden by your data protection interests or fundamental rights and freedoms; or where we have obtained your consent to do so. Below is a chart showing how SAKARA uses your personal information, as described above in Sections 3 and 4, with the corresponding legal bases for processing.

6. Data Security

We are committed to protecting your personal information from unauthorized access and use. To help protect your personal information, we implement and maintain appropriate technical, physical, and administrative safeguards. Access to your personal information is restricted solely to those employees and vendors who need to know that information to provide our Services to you. Our employees receive training to maintain the confidentiality, privacy, and security of your personal information.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

7. Retention

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws and regulations), resolve disputes and enforce our legal agreements and policies. We will also retain Site and Services usage data for internal analysis purposes.

8. Children’s Privacy

We do not offer Services to minors and do not intend to collect personal information from children under the age of 18, and we do not knowingly collect any personal information from children under the age of 18. If an individual under the age of 18 has provided us with personal information, we ask that a parent or guardian contact us as described below so that we may promptly delete the child’s information from our record.

9. Your Choices

Analytics. We use Google Analytics. For information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.

Cookies.  Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.

• First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
• Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to http://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers.

We do not control third parties’ collection or use of your information to serve interest-based advertising.  You can decide whether to accept cookies. If you do not want us to deploy cookies in your browser, you may exercise your preference by modifying your web browser setting to either (1) refuse some or all cookies, or (2) notify you and ask for your permission when a website tries to set a cookie. If you want to learn the correct way to modify your browser settings, please use the “Help,” “Tools” or “Edit” menu in your browser or review the instructions provided by the following browsers:

• Google Chrome
• Mozilla Firefox
• Microsoft Internet Explorer

If you disable or remove cookies, some parts of the Services may not function properly. Information may still be collected and used for other purposes, such as research, online services analytics or internal operations, and to remember your opt-out preferences.

10. Notice to California Residents

This section applies only to California residents. Pursuant
to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect your Personal Information, where we obtain the Personal Information,
and the third parties with whom we may share your Personal Information.

We generally collect the following categories of Personal Information about your when you use our Services:

• Identifiers such as a name, address, email, phone number, your device’s IP address, software, and identification numbers associated with your devices;
• Commercial information such as records of services purchased, obtained, or considered by you;
• Internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
• Professional or employment-related information;
• Unique personal identifier (e.g., SSN) may be collected if you link within the Site to transact with us to lease real estate.
• Your geolocation, to the extent you have configured your device to permit us to collect such information.

We generally do not collect biometric information, audio recordings of your voice, education-related information, or inferences about your preferences, characteristics, behavior and attitudes. For more information about the Personal Information we collect please refer to Sections 1 and 2, above.

We collect your Personal Information for the business purposes described in Section 3, above. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.  The categories of third parties with whom we may share your Personal Information are listed in Section 4, above.

If you are a California resident, you have certain rights in relation to your Personal Information which are listed below; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our network systems.

• Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
• Right to Know. You have the right to request in writing: (i) a list of the categories of Personal Information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of Personal Information we have collected about you, (ii) the categories of sources from which Personal Information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared Personal Information, and (v) the specific pieces of Personal Information we hold about an individual.
• Right to Access. You have the right to request access to a copy of the specific Personal Information we collected about you during the 12 months before your request.
• Right to Deletion. You have the right to request that we delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.
• Right to Opt-Out of Sales. You have the right to opt-out of any sales your Personal Information. We do not sell any of your Personal Information.

You or your authorized agent may submit a request to exercise any of the above rights by contacting us at  [email protected], and putting “CCPA Rights Request” in the subject line. We may require additional information to verify your identity or to verify that your authorized agent has the authority to make the request on your behalf before responding to a CCPA rights request.  If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

Do Not Track.  Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DENT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

11. Your Privacy Rights and Choices

Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, SAKARA has absolute discretion in providing you with those rights.

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in to determine your rights under the applicable data protection law in your jurisdiction. Your rights to personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.

• Access and portability. You may request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another data controller.
• Rectification of incomplete or inaccurate personal information. You may request us to rectify or update any of your personal information held by us that is inaccurate. You may do this at any time by logging in to your account and clicking the Profile or My Account tab.
• Erasure. You may request to erase your personal information, subject to applicable law. If you close your SAKARA Account, we will mark your account in our database as “Closed,” but will keep certain account information, including your request to erase, in our database for a period of time as described above. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account, and to comply with SAKARA’s legal obligations. However, if you close your account, your personal information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.
• Withdraw consent. To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of SAKARA’s processing based on consent before your withdrawal.
• Restriction of processing. In some jurisdictions, applicable law may give you the right to restrict or object to us processing or transferring your personal information under certain circumstances. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
• Automated individual decision-making, including profiling. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.  SAKARA does not engage in automated individual decision-making that produce legal or similarly significant effects.
• Marketing communications. You can opt-out of receiving marketing communications from us. Direct marketing includes any communications to you that are only based on advertising or promoting our products and services. We will only contact you by electronic means (email or SMS) based on our legitimate interests, as permitted by applicable law, or your consent. To the extent we can and do rely on legitimate interest under the applicable law, we will only send you information about our Services that are like those which were the subject of a previous sale or negotiations of a sale to you. We will contact you by electronic means for marketing purposes only if you have consented to such communication. You may raise such objections regarding initial or further processing for purposes of direct marketing, at any time and free of charge.
  • If you do not wish to receive non-transaction/security-related communications from SAKARA, you may opt-out by clicking the “unsubscribe” link in the communication or contact us via email or where specified in the “Contact Us” section, below. Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your Information shall remain subject to the prior privacy settings. Additionally, you should be aware that any Information provided to third parties prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.

12. International Transfers

Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer data, including personal information, to United States and process it there. In such cases, we will take appropriate steps to ensure an adequate level of data protection of the recipient as required under the applicable data protection law, including the GDPR, and as described in this Privacy Policy. Before we share your information with any party, we will enter into a written agreement that requires that party to provide at least the same level of protection for the personal information as required under applicable data protection laws. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Services.

13. Notice to EU, UK, and Swiss Residents

When SAKARA collects and processes personal information from data subjects while they are located in the European Economic Area (EEA), the United Kingdom (UK) and Switzerland (collectively, “European Residents”) the provisions in this section apply.

Data Controller.  SAKARA Group, [email protected].

Complaints.  If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry first to us per the Contact Us section below, and include “GDPR Compliant” in the subject line.  If you reside in the UK, you may file a complaint with the relevant data protection authority, Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, 0303 123 1113, [email protected].

14. Notice to Colombian Residents

As a Colombian resident, your rights to your personal information are those provided in the Constitution and in Law 1581 of 2012, including the following: (a) access, free of charge, to the data provided that has been processed; (b) requesting the updating and adjustment of your information in the event of partial, inaccurate, incomplete, fractioned or misleading data, or of data whose handling is prohibited or has not been authorized; (c) requesting proof of the authorization granted; (d) submitting to the Superintendence of Industry and Commerce complaints for violations to the provisions of the regulations in force;  and (e) revoking the authorization and/or requesting the deletion of the data, unless there is a legal or contractual duty that makes it imperative to keep the information. For information regarding the handling of data, submitting requests, exercising your rights and/or request email us at [email protected], and put “Colombia Data Rights Request” in the subject line, or you can write to us at: 315 South Biscayne Boulevard, Miami Florida, 33131, Attention Legal Department (Privacy).

15. Contact Us

We welcome your questions, comments, and concerns about privacy. If you have any questions or comments regarding this Privacy Policy please email [email protected].