Privacy Policy — SOBE Invest by Sobe Collection SL

Last Updated: June 29, 2026

PRIVACY & COOKIE POLICY
Last Updated: July 2, 2026
1. Introduction
Welcome to SOBE Invest. This Privacy & Cookie Policy explains how Sobe Collection SL ("SOBE Invest", "we", "us") collects, uses, shares and protects your personal data when you visit sobeinvest.com, submit your details through our forms, contact us via WhatsApp, or interact with our advertising on third-party platforms.
We process personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR") and the Spanish Organic Law 3/2018 on Data Protection and Digital Rights (LOPDGDD).
2. Data Controller
The entity responsible for processing your personal data is:

• Company name: Sobe Collection SL

Registered address: Avda. Las Petunias 112, Edificio Noray Playa,

• 29670 San Pedro de Alcántara, Marbella (Málaga), Spain
• NIF (Tax ID): ES B75911685
• Contact email: sobe@sobeinvest.com

3. Data We Collect and How
We collect the following categories of personal data:

• Identity and contact data: your name, email address and phone number, provided when you submit a form on our website, complete a lead form on an advertising platform (such as Facebook or Instagram Lead Ads), or contact us via WhatsApp.
• Inquiry details: information you choose to share about your property search — for example budget range, preferred areas, property type, and the content of your messages.
• Technical and usage data: IP address, browser type and version, device and operating system, time zone, and information about how you navigate our website. This data is collected through cookies and similar technologies only with your consent (see Section 6).

We do not intentionally collect special categories of personal data (such as health information) and ask that you do not share such data with us.
4. How and Why We Use Your Data (Legal Bases)
Under Article 6 GDPR, we process your personal data on the following legal bases:

• Pre-contractual and contractual measures (Art. 6(1)(b)): to respond to your inquiries, send requested property information and catalogues, prepare personalised offers and investment data, schedule viewings, and assist you throughout a purchase, sale or rental process.
• Consent (Art. 6(1)(a)): (i) to place analytics and advertising cookies, based on the choice you make in our cookie banner (see Section 6); and (ii) to send you marketing communications, such as new property alerts, where you have opted in through a form. These are two separate consents, and each can be withdrawn at any time without affecting the other.
• Legitimate interest (Art. 6(1)(f)): to keep our website secure, prevent fraud and abuse, and maintain internal records of business communications.
• Legal obligation (Art. 6(1)(c)): to comply with Spanish tax, accounting and, where applicable, anti-money laundering legislation.

5. Lucas — Our AI Assistant on WhatsApp
Part of our client communication is handled by Lucas, an AI-powered virtual assistant, available via WhatsApp and through contact options on our website. When you chat with Lucas:

• Your messages are processed automatically in order to understand your request and provide relevant property information.
• The conversation is transmitted through WhatsApp (Meta Platforms) and processed by the AI technology provider operating the assistant on our behalf as our data processor.
• Lucas does not make any decisions with legal or similarly significant effects for you; all inquiries are reviewed by our advisors.
• You can ask to be connected with a member of our team at any time. Please avoid sharing sensitive personal information in chat.

Your use of WhatsApp is also subject to WhatsApp's own terms and privacy policy.
6. Cookies
Our website uses cookies and similar technologies (pixels, tags). We group them into four categories, matching the choices in our cookie banner:

• Essential cookies — required for the website to function correctly (security, navigation, form submission). They are always active and do not require consent.
• Analytics cookies — help us understand how visitors use the website (Google Analytics) so we can improve our pages and content.
• Advertising cookies — used by Google Ads and Meta to measure the performance of our campaigns and show you relevant property advertising.
• Preference (custom) cookies — remember optional on-site settings. We do not currently set cookies in this category.

No analytics or advertising cookies are placed on your device until you give consent through our cookie banner — either by clicking "Accept all" or by making your own selection under "Cookie settings". We also use Google Tag Manager to manage these technologies; it does not set cookies of its own.
You can change or withdraw your cookie choices at any time via the "Cookie settings" link in the website footer or the on-page cookie widget, and additionally through your browser settings.
The exact set of cookies may vary as our tools evolve; we review this list periodically.
7. Data Sharing and Recipients
We do not sell or rent your personal data, and we do not share it with third parties for their own marketing purposes. Your data is accessed by our advisors and by a limited number of service providers who process it on our behalf under data processing agreements (Art. 28 GDPR):

• Tilda Publishing — website platform and storage of form submissions;
• Google — advertising, analytics and tag management (Google Ads, Google Analytics, Google Tag Manager);
• Meta Platforms — WhatsApp Business communication and advertising services on Facebook and Instagram;
• our AI technology provider — operation of the Lucas assistant;
• our CRM provider — management of client inquiries.

Where a transaction requires it and with your knowledge, we may also share necessary data with lawyers, notaries, developers or financial institutions involved in your purchase. We may disclose data to public authorities where required by law.
8. International Data Transfers
We are based in Spain and primarily process data within the European Economic Area. Some of our providers — in particular Google and Meta — may process data on servers located in the United States. Such transfers are safeguarded by the EU-U.S. Data Privacy Framework, under which these providers are certified, and, where applicable, by Standard Contractual Clauses approved by the European Commission, together with additional safeguards where appropriate.
9. Data Retention
We keep personal data only for as long as necessary for the purposes described above:

• Inquiry and lead data: for the duration of our communication and up to 24 months after your last interaction, unless you ask us to delete it earlier.
• Marketing data: until you withdraw your consent or object to direct marketing.
• Transaction and contractual documentation: for the periods required by Spanish law — generally 6 years for commercial documentation and up to 10 years where anti-money laundering legislation (Law 10/2010) applies.

After these periods, data is securely deleted or anonymised.
10. Your Rights
Under the GDPR and LOPDGDD, you have the right to:

• Access the personal data we hold about you and receive a copy of it;
• Rectify inaccurate or incomplete data;
• Erase your data ("right to be forgotten"), subject to statutory retention obligations;
• Restrict processing in the circumstances set out in Art. 18 GDPR;
• Object to processing based on legitimate interest, and object at any time to direct marketing — in which case we will stop such processing;
• Data portability — receive the data you provided to us in a structured, commonly used, machine-readable format;
• Withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, email us at sobe@sobeinvest.com. We may ask you to verify your identity and will respond within one month. If you believe your data has been handled unlawfully, you have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, www.aepd.es).
11. Data Security
We apply appropriate technical and organisational measures to protect your personal data, including encrypted connections (HTTPS/TLS), access controls and confidentiality obligations for our team. No online transmission is completely secure, but we work continuously to safeguard your information.
12. Minors
Our services are directed at adults. We do not knowingly collect personal data from anyone under 18; if you believe a minor has provided us with data, please contact us and we will delete it.
13. Changes to This Policy
We may update this policy from time to time to reflect changes in our services or in legal requirements. The "Last Updated" date at the top of this page indicates the current version. Significant changes will be highlighted on this page.
14. Contact
For any questions about this policy or your personal data, contact us at sobe@sobeinvest.com or by post at Avda. Las Petunias 112, Edificio Noray Playa,

• 29670 San Pedro de Alcántara, Marbella (Málaga), Spain