Privacy policy

Disclaimer: This translation is provided for convenience only. The Spanish version is the only legally binding text and prevails in any dispute. The site is operated from Chile and governed by Chilean law.

1. Identity of the Data Controller

The controller of personal data collected through the website homenewenpropiedades.cl and related channels is:

• Corporate name: [pendiente: razon social]
• Taxpayer ID (RUT): [pendiente: rut]
• Address: [pendiente: domicilio], Chile
• Email for privacy matters: legal@homenewenpropiedades.cl
• General contact email: contacto@homenewenpropiedades.cl
• Phone: +56 9 1234 5678
• Broker registration: [pendiente: registro corredor]

Hereinafter, "Home & Newen Propiedades", "the Brokerage", "we", or "the Controller".

This Privacy Policy describes how we collect, use, store, communicate, and protect the personal data of users (the "Data Subject" or "User") interacting with our services, website, forms, messaging channels, and other contact means.

2. Personal data we collect

We collect only the personal data necessary to fulfill the purposes described in this Policy.

2.1. Identification and contact data (voluntarily provided):

• Name and surname
• Email address
• Phone or mobile number
• Message, inquiry, or request
• Type of transaction of interest (purchase, sale, lease)

2.2. Contractual and commercial data (when the Data Subject enters into a mandate, promise, lease, or other contract):

• RUT
• Address
• Marital status and property regime (if applicable)
• Profession or occupation
• Financial information related to the real-estate transaction

2.3. Technical and navigation data (collected automatically):

• IP address (anonymized for analytics)
• Device type, operating system, and browser
• Date and time of access
• Pages visited and time on page
• Traffic source (referrer)
• Cookie identifiers and similar technologies

2.4. Behavior and interaction data:

• Properties viewed or favorited
• Email-campaign interactions
• WhatsApp Business conversations when the Data Subject contacts us via that channel

We do not collect sensitive data under Law 19,628 or specially protected data under Law 21,719 (racial or ethnic origin, political opinions, religious convictions, health, sexual life, biometric or genetic data), unless the Data Subject provides them voluntarily and they are strictly necessary for the real-estate transaction.

3. Purposes and legal bases of processing

We process the Data Subject's personal data only when at least one of the following legal bases applies, in line with article 4 of Law 19,628 and the legal bases recognized by Law 21,719:

3.1. Data Subject's consent

• Responding to inquiries via forms, listings, and messaging channels.
• Sending commercial communications, newsletters, or property information when expressly authorized.
• Installing non-strictly-necessary cookies (analytics, personalization, future remarketing).

3.2. Performance of a contract or pre-contractual measures

• Managing brokerage mandates, promise, sale, lease, and other agreements with the Data Subject.
• Coordinating visits, appraisals, signings, and notarial or registry procedures.
• Issuing and managing invoices under tax regulations.

3.3. Controller's legitimate interest

• Analyzing user behavior in aggregated, anonymized form to improve the site (Google Analytics 4 with IP anonymization).
• Preventing fraud and abuse and ensuring site security.
• Handling claims and inquiries directed to the Brokerage.

3.4. Compliance with legal obligations

• Retaining accounting and tax records under the Tax Code and SII regulations.
• Responding to requests from competent authorities (courts, SII, UAF, SERNAC, future Personal Data Protection Agency).
• Meeting Law 19,913 anti-money-laundering obligations where applicable.

We will not process data for purposes different from or incompatible with those described without first obtaining the Data Subject's consent when legally required.

4. Communication of data to third parties (data processors)

To deliver our services, we rely on technology providers acting as processors. Each processes data only under our instructions and under contractual agreements ensuring confidentiality and security.

About WhatsApp Business: when the Data Subject contacts us via WhatsApp, messages are processed by Meta Platforms Inc. in the USA and/or its global subprocessors. Note that WhatsApp Business accounts may not feature end-to-end encryption to the same degree as personal accounts, depending on configuration. Meta may retain messages for up to 30 days on its servers under its current policy. Data Subjects who prefer not to use this channel may reach us by email at contacto@homenewenpropiedades.cl or phone at +56 9 1234 5678.

In addition, we may share data with:

• Notaries, Real Estate Registry conservators, lawyers, accountants, and banks involved in the transaction, exclusively for its proper execution.
• Competent public authorities under legal obligation or duly grounded request.

We do not sell, assign, or market the Data Subject's personal data to third parties for purposes other than those described.

5. International data transfers

The Brokerage may transfer data to providers located in the United States, the European Union, or other jurisdictions, exclusively based on:

(i) standard contractual clauses or equivalent approved by the competent Chilean authority or, failing that, the European Commission's Standard Contractual Clauses as a minimum protection reference;

(ii) provider certifications (SOC 2 Type II, ISO 27001, EU-U.S. Data Privacy Framework where applicable);

(iii) strict minimization of transferred data.

The Data Subject may specifically object to international transfers by writing to legal@homenewenpropiedades.cl. The Brokerage will inform the Data Subject, before the transfer when not already described in this Policy, of the destination country and applicable safeguards. Once Law 21,719 is in force and the Personal Data Protection Agency is established, the Brokerage will align its mechanisms with the adequacy decisions issued.

6. Retention periods

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected and to meet legal obligations:

• Leads and inquiries with no subsequent transaction: up to 12 months from the Data Subject's last explicit interaction (sending a message, call, scheduled visit, or direct reply to communication). Mere opening of an email or click on a link does not count as explicit interaction for restarting the period. Upon expiry, data will be irreversibly deleted or anonymized, unless additional express consent for extended retention.
• Clients with closed transactions (sale, lease, executed mandate): 6 years from closing, under tax/accounting obligations (article 17 of the Tax Code).
• Accounting, tax, and UAF records (where applicable): the legal retention period required.
• Cookie and analytics records: per each tool's configuration (Google Analytics 4: default maximum 14 months).
• WhatsApp and email communications: while necessary to handle the request and per the relevant category.

After the retention period, data will be irreversibly deleted or anonymized, except for a legal hold for defense against claims.

7. Data Subject rights

Under Law 19,628 and the new rights recognized by Law 21,719, the Data Subject may at any time exercise:

• Access: know what personal data we process and under what conditions.
• Rectification: request correction of inaccurate, outdated, or incomplete data.
• Cancellation or erasure: request deletion when data is no longer necessary, processing is unlawful, or consent has been withdrawn, absent a legal retention obligation.
• Objection: object to processing on legitimate personal grounds, especially regarding commercial communications and international transfers.
• Portability (in force with Law 21,719): request the delivery of data in a structured, commonly used format, or its direct transfer to another controller when technically possible.
• Blocking: request temporary suspension of processing pending verification of a request.
• Withdrawal of consent: revoke consent at any time without retroactive effect.

How to exercise. Send a request to legal@homenewenpropiedades.cl including:

1. Full name and RUT.
2. The right exercised and a concrete description of the request.
3. Contact means for the response.

Identity verification. We will use reasonable, proportionate means (validation of registered email, phone confirmation, security questions), and may request a copy of an ID card only when there is reasonable doubt about the requester's identity and no less intrusive means exist. This requirement will be interpreted under the data-minimization principle.

Timelines.

• Acknowledgment of receipt: within 5 business days of the request.
• Substantive response: maximum 20 calendar days from full receipt, extendable once for an additional 10 calendar days with reasoned communication.

Accessible channels. Requests may be submitted in writing, by phone, WhatsApp, video call with sign-language interpreter (to be coordinated in advance), or in person at [pendiente: domicilio]. Timelines will accommodate reasonable flexibility when the accessible channel requires prior coordination, without prejudice to the Data Subject.

Exercising these rights is free of charge, except for manifestly unfounded or excessive requests.

8. Security measures

We apply reasonable technical and organizational measures proportionate to the risk:

Technical measures:

• TLS/HTTPS encryption in transit throughout the site.
• Encryption at rest in the Supabase database.
• Mandatory two-factor authentication (2FA) for all administrative access.
• Role-based access control and least-privilege principle.
• Activity logs and security-event monitoring.
• Regular backups and incident recovery procedures.
• Regular dependency updates and security patches.

Organizational measures:

• Confidentiality agreements with collaborators and providers.
• Data processing agreements (DPAs) with processors.
• Internal incident-management and breach-notification protocols.
• Periodic data-protection training.

Security breach procedure. Should we detect a personal-data breach, the Brokerage will:

(i) notify affected Data Subjects within 72 hours of detection where the breach poses high risk to rights and freedoms, describing the incident, affected data, measures, and recommendations;

(ii) notify the Personal Data Protection Agency (once constituted) within the timelines and form required by Law 21,719 and its regulations;

(iii) maintain an internal incident register;

(iv) review security measures and apply corrective actions.

No system is fully impervious.

9. Cookie policy

9.1. What cookies are. Cookies are small files a website stores on the user's device to remember information about the visit. We also use similar technologies (local storage, pixels, tags).

9.2. Types of cookies we use.

a) Strictly necessary (technical) cookies: maintain the session, remember basic preferences, ensure site operation. Consent not required.

b) Analytics cookies: Google Analytics 4 with IP anonymization. Measure audience and aggregated behavior without individually identifying the user. Activated only with the Data Subject's consent.

c) Marketing and remarketing cookies (future use): if we implement remarketing or advertising cookies in the future (e.g., Meta Pixel or Google Ads), they will be declared in this Policy and activated only with the Data Subject's prior express consent.

9.3. Cookie banner. On first entry, the Site shows a banner allowing, with equal visual prominence and the same number of clicks:

(a) accept all cookies; (b) reject all non-strictly-necessary cookies; (c) configure preferences by category.

Until the Data Subject makes a choice, no analytics, marketing, or personalization cookie or script will be loaded. Consent is logged with date, time, IP, and banner version. The Data Subject may modify or withdraw consent at any time from the "Cookie settings" link in the Site footer, with the same ease as granting it.

9.4. Browser settings. The Data Subject may also block or delete cookies directly from browser settings. Disabling strictly necessary cookies may affect site functionality.

This cookie policy follows general SUBTEL guidelines and international best practices.

10. Minors

10.1. Our services target persons over 18. The registration form will require sworn confirmation of legal age.

10.2. If we learn of processing of data of minors under 14 without parental/guardian consent, we will proceed with immediate erasure within 5 business days.

10.3. For adolescents between 14 and 18, processing requires: (a) the adolescent's consent for purposes understandable for their age; and (b) the legal representative's consent for processing with contractual effects or exceeding simple inquiry.

10.4. The Brokerage commits to applying the best interest of the minor and to not directing real-estate advertising at minors.

Parents and legal representatives detecting this situation may contact us at legal@homenewenpropiedades.cl.

11. Automated decisions and profiling

Home & Newen Propiedades does not make decisions based solely on automated processing producing legal effects or similarly significantly affecting the Data Subject.

Likewise, we do not perform profiling for credit scoring, automated real-estate scoring, or advanced advertising segmentation based on sensitive categories.

The Brokerage will review this declaration semi-annually. Should it implement tools entailing profiling or automated decisions with significant effects, it will update this Policy at least 30 calendar days in advance, request express consent where required, and implement mechanisms for human intervention, algorithm explanation in comprehensible terms, and result contestation under article 8 ter of Law 21,719.

12. Changes to this Privacy Policy

We may amend this Policy to adapt to legal, technical, or operational changes. The current version will always be available at homenewenpropiedades.cl with the last-updated date.

For substantial changes —especially those affecting purposes, data categories, processors, or international transfers— we will notify the Data Subject by a reasonable means (prominent site notice or email where available) at least 15 calendar days before the effective date, and seek consent again when legally required.

13. Applicable legal framework and alignment with Law 21,719

This Policy is governed by Chilean law, in particular:

• Law 19,628 on Privacy Protection, currently in force.
• Law 21,719 on personal data protection and creation of the Personal Data Protection Agency, with general entry into force in December 2026.
• Law 19,496 on Consumer Rights Protection.
• Law 19,913 on anti-money-laundering, where applicable.
• Other complementary sectoral regulations.

Alignment with Law 21,719. Home & Newen Propiedades commits to progressively aligning its processes, processor agreements, processing activity records, impact assessments, and rights-exercise mechanisms with Law 21,719 before its entry into force.

From the entry into force of Law 21,719, references in this Policy to Law 19,628 should be understood as referring to the new regulation where applicable, with the standard most favorable to the Data Subject always prevailing.

14. Claims before authorities

Without prejudice to contacting us directly, the Data Subject may file claims with:

• Personal Data Protection Agency: once constituted and operational under Law 21,719.
• National Consumer Service (SERNAC): to the extent the facts also constitute a possible infringement of Law 19,496. Claims at www.sernac.cl.
• Ordinary courts of justice: for civil or constitutional actions (including habeas data).

We recommend contacting us first at legal@homenewenpropiedades.cl to seek direct resolution.

15. Language and prevalence

This Privacy Policy is drafted in Spanish, which is the official language for all legal and interpretive purposes. Versions in other languages (English, Portuguese, or others) are courtesy translations. In case of discrepancy, contradiction, or interpretive doubt, the Spanish version will always prevail.

For inquiries about this Policy, the Data Subject may write to legal@homenewenpropiedades.cl or contacto@homenewenpropiedades.cl.

Last updated: June 2026.