Privacy Policy

1. Who is responsible for your data

The company responsible for your personal data (the “controller”, or “responsable del tratamiento” under Colombian law) depends on the home or project you ask about:

• Pernefer Group SAS, a company incorporated in Colombia, for enquiries and purchases relating to Umbral Alto (El Carmen de Viboral, Antioquia).
• Pernefer Group LLC, a company incorporated in Georgia, for enquiries and purchases relating to Obsidian Crown (Tbilisi Sea, Tbilisi).

Where an enquiry does not relate to a specific project, or relates to both, the two companies act as joint controllers for that enquiry. You can contact either company about any request using the details on our Contact page.

2. The personal data we collect

We collect only the data we need to answer you and, if you proceed, to sell you a home:

• Contact details you give us: your name, email address, telephone or WhatsApp number, and city and country.
• Details of your interest: the project and home you selected, your preferred payment plan, your intended use and timing, an indicative budget range, your shortlist and any message you write.
• Your consent record: that you asked us to contact you, and when.
• Journey information: the pages and homes you viewed on our site in the same visit, the page and link that brought you to us (including campaign tags in the link), your browser language, time zone and screen size. This helps us answer your question precisely.
• Technical data: IP address, browser type and request logs kept by our servers for security and to prevent abuse.
• Purchase data, if you go on to buy: identity and residence documents, tax identifiers, payment records and contract details, as required by law.

We do not ask for special categories of data (sensitive data), and we ask you not to include them in messages. The site is not intended for children and we do not knowingly collect data from anyone under 18.

3. Why we use your data, and on what legal basis

• To answer your enquiry and send you the availability, prices and terms you asked for — on the basis of your consent and of steps you ask us to take before entering into a contract.
• To prepare, sign and perform a purchase contract, receive payments and hand over your home — because it is necessary for the contract.
• To meet legal obligations, including anti-money-laundering, tax, accounting and consumer-protection rules — because the law requires it.
• To keep the site secure, prevent spam and fraud, and understand which pages help buyers — on the basis of our legitimate interests, which we balance against your rights.
• To send you news about our projects, but only if you have agreed to receive it. You can withdraw that consent at any time.

Under Colombian law, we process your data on the basis of the prior, express and informed authorisation you give when you tick the consent box and submit a request, and for the purposes described in this policy.

4. Who we share it with

• Between Pernefer Group SAS and Pernefer Group LLC, so that the right team can answer you.
• Our service providers, who act on our instructions under written agreements: website hosting and security, our customer-relationship and communication platform, email and messaging services, and our construction and project-management partners where your purchase requires it.
• Morency & Co, which holds buyer payments in trust, and banks and payment providers that process your payments.
• Lawyers, notaries, registries, auditors and public authorities where required to complete a sale or by law.

We do not sell your personal data, and we do not share it with third parties for their own advertising.

5. International transfers

Our companies operate in Colombia and Georgia, and some service providers may process data in other countries. When your data moves between countries, we use the safeguards the applicable law requires — for example, transfer agreements based on standard contractual clauses for data from the EU/EEA, and the conditions for international transfers set out in Colombian law and in the Law of Georgia on Personal Data Protection.

6. How long we keep it

We keep enquiry data for up to 24 months after our last contact with you, unless you ask us to delete it sooner. If you buy a home, we keep contract and payment records for as long as the law requires (typically ten years for accounting and tax records). Security logs are kept for a short period, normally no more than 12 months.

7. Your rights

Whichever law applies to you, you can ask us to:

• Tell you whether we hold your data and give you a copy of it.
• Correct, update or complete it.
• Delete it, or stop or restrict using it, where the law allows.
• Withdraw your consent at any time, without affecting what we did before.
• Object to processing based on our legitimate interests, and to direct marketing at any time.
• Receive the data you gave us in a portable format, where the GDPR applies.

Colombia (Law 1581 of 2012): as a data subject (titular) you may know, update and rectify your data; request proof of the authorisation you gave; be informed of how your data is used; revoke your authorisation or request deletion when the processing does not respect the law; access your data free of charge; and file a complaint with the Superintendencia de Industria y Comercio (SIC) once you have first contacted us. We answer queries (consultas) within ten business days and claims (reclamos) within fifteen business days, extendable as the law allows with notice to you.

Georgia: under the Law of Georgia on Personal Data Protection you may request information about and access to your data, and its correction, blocking or deletion, and you may lodge a complaint with the Personal Data Protection Service of Georgia.

European Union and EEA: if you are in the EU/EEA, the GDPR applies when we offer you our homes or analyse your use of the site. You may lodge a complaint with the data protection authority of the country where you live or work.

To exercise any right, contact us through the Contact page, stating which right you wish to exercise. We may need to verify your identity before we act.

8. Cookies and local storage

We do not use advertising cookies or third-party tracking. The site stores a small amount of information in your own browser (local and session storage) so that it works as you expect: the home you selected, your shortlist, your chosen payment plan and display currency, a random visitor identifier and the page that first brought you to us. This information stays on your device unless you send us a request, in which case it is attached to that request as described above. You can clear it at any time in your browser settings.

Exchange rates, fonts and the 3D walkthrough are served from our own servers; your browser does not contact third-party services for them.

9. Security

We protect personal data with appropriate technical and organisational measures, including encrypted connections, access controls and restricted administrative access. No system is completely secure; if a breach affects your rights, we will notify you and the relevant authority as the law requires.

10. Changes to this policy

We may update this policy from time to time. The date at the top shows the latest version; material changes will be highlighted on this page before they take effect.

11. How to contact us

For any privacy question or request, write to us through the Contact page and mark your message “Privacy”. Please say whether your question relates to Umbral Alto (Pernefer Group SAS) or Obsidian Crown (Pernefer Group LLC).