PRIVACY POLICY, DATA PROTECTION AND COMPLIANCE TERMS

Last updated: July, 2026.

At Altavista Inmobiliaria (hereinafter “Altavista”), accessible through the domain altavistacr.com , we take with absolute seriousness and professional rigor the commitment to protect the privacy of our users, clients, and counterparties. This Policy governs the collection, storage, use, and protection of personal data in strict compliance with the Law on the Protection of Individuals with regard to the Processing of their Personal Data (Law No. 8968) and its regulations, as well as the risk prevention guidelines issued by the Law on Narcotics, Psychotropic Substances, Drugs of Unauthorized Use, Related Activities, Money Laundering, and Financing of Terrorism (Law No. 7786) in the Republic of Costa Rica.

1. Data Controller

The legal entity responsible for the safekeeping, administration, and processing of information collected on this website and its associated channels is the operating entity of Altavista Inmobiliaria, located in San José, Curridabat, Costa Rica. For any questions, requests, or to exercise your legal rights related to your data, please contact our Compliance Department through their official electronic communication channel.

2. Data Subject to Collection

Altavista collects information through various interactions on the platform, classifying it under the following criteria:

• Voluntarily Provided Data (Users and Clients): Information actively provided through contact forms, requests for listing information, appointment scheduling, or subscriptions. This includes: full name, identification number (physical ID, legal ID, DIMEX, or passport), telephone number, email address, and characteristics of the properties of interest.

• External Broker and Applicant Data: Professional information, contact details, suitability records and commercial attestations provided by independent brokers requesting co-brokerage alliances, or by individuals applying to internal recruitment processes.

• Automated Browsing Data (Cookies): Non-nominal technical information passively collected (such as anonymized IP addresses, approximate geolocation data, browser type, operating system, pages visited and dwell times) in order to optimize the performance of the web architecture.

3. Purpose of Information Processing

The data collected by Altavista is processed for the following legitimate and specific purposes:

1. Manage, channel and respond promptly to requests for information on the purchase, sale, lease or prospecting of real estate.

2. Coordinate the schedules of physical or virtual visits to the properties in our catalog, guaranteeing the safety of our advisors and the property owners.

3. Evaluate business profiles and feasibility of alliances with external real estate brokers for authorized commission sharing.

4. Compliance and Prevention of Legal Risks: Execute the mandatory due diligence protocols and “Know Your Customer” (KYC) policies, in order to mitigate risks associated with money laundering and terrorist financing, in accordance with the guidelines of Article 15 bis of Law No. 7786.

4. Commercial and Credit Risk Verification Protocol

As an entity subject to Costa Rican law, Altavista uses private credit bureaus and tools for the proactive evaluation of financial and real estate transactions. However, this procedure is governed by strict rules of legal proportionality, described in the following scenarios:

• Initial Prospecting Phase (Calls, emails, appointment requests): Applies to prospects, leads, legal advisors, or external brokers. It is limited to identity verification using public sources (TSE or National Registry). It does not require credit approval, and this profile is completely excluded from credit bureaus.

• Formal Phase (Submission of Offers, Option or Lease Agreements): This applies strictly to the direct commercial parties (Buyer, Seller, Lessee). Private risk platforms (such as Equifax, Cero Riesgo, TransUnion, or similar ) are used. Prior signature of an Express Informed Consent form is mandatory.

Third-Party Protection Clause: No automated inquiries will be made to private credit bureaus or commercial risk analysis platforms during the initial prospecting or contact phase. These tools are reserved solely for the formal stages of the offer or contract, and are strictly limited to the direct financial parties and require prior written authorization. Legal advisors, managing attorneys for the parties, or technical intermediaries are categorically excluded from these credit risk inquiries, unless they are acting as orderers of funds or direct commercial agents for the transaction.

5. External Channels, Social Networks and Messaging

This privacy and data protection policy extends its regulatory effects to all information collected through advertising forms on official social media platforms (such as Facebook Ads or Instagram Ads) and direct communications conducted via the corporate WhatsApp Business platform. By interacting through these instant communication channels, the user agrees that the processing of their contact information will be governed by the confidentiality standards and purposes set forth herein.

6. Data Retention and Storage Period

Private personal data will be kept in our systems only for as long as strictly necessary to fulfill the requested business relationship. However, in the case of formalized real estate transactions, and in strict compliance with the legal obligations of public order established by Law No. 7786 and SUGEF regulations, Altavista is legally obligated to retain due diligence files and records for a minimum period of five (5) years. Mandatory legal retention periods will prevail over the right to immediate deletion in compliance audit records.

7. Transfer of Data to Third Parties

Altavista does not sell, lease, transfer, or commercialize personal data under any circumstances. Information may only be shared with technology sub-processors involved in maintaining the digital infrastructure (under confidentiality and data processing agreements), or with Costa Rican judicial and regulatory authorities when there is a formal, binding request based on current legal framework.

8. ARCO Rights of the Data Subject

In accordance with Law No. 8968, every citizen maintains the full exercise of their inherent rights over their personal data:

• Access: The ability to request knowledge of specific data stored in the company’s databases.

• Rectification: Right to correct, update or modify inaccurate, erroneous or incomplete data.

• Cancellation / Deletion: Right to request the deletion of data when the commercial purpose has concluded, subject to the retention restrictions of Law 7786.

• Opposition: Right to refuse to have your data used for secondary purposes such as sending direct marketing campaigns.

To exercise any of these rights, the data subject must send a written request to the company’s official Compliance Department email address.

9. Intellectual Property of the Catalog and Images

All audiovisual material, including photographs of facades and interiors, architectural plans, promotional videos, virtual tours, and drone footage published on altavistacr.com or its social media channels, constitutes the exclusive intellectual property of Altavista or has the explicit contractual authorization of the registered owners. The downloading, reproduction, copying, distribution, or commercial use of said material by third parties or independent brokers is strictly prohibited without the prior written authorization of Altavista’s management.

10. Disclaimer Regarding Reference Data and Inaccuracies

The information displayed on altavistacr.com regarding the physical characteristics of the properties (such as land measurements, square meters of construction, internal distribution, condominium maintenance fees and list prices), as well as location references, distances to urban centers or estimated travel times, is published for strictly reference, informative and guidance purposes.

Since much of this data is provided by the sellers, municipalities, or automated satellite navigation platforms, Altavista does not guarantee the accuracy or real-time updating of this information. The exact measurements, legal boundaries, encumbrances, and liens of each property will be solely and exclusively those officially recorded in the certifications from the National Registry of Costa Rica and in the respective duly approved cadastral maps. It is the sole responsibility of the interested parties to verify the technical and legal information before signing any purchase option or final contract.