Cookie Policy

Faro, by Navigamo Website: holafaro.com and app.holafaro.com

Last updated: August 6, 2026

1. Who we are and scope of this policy

This Cookie Policy explains what cookies and similar technologies are, which ones we use on the marketing website holafaro.com and on the platform app.holafaro.com (collectively, the “Websites”), for what purpose, who places them, how long they last, and how you can manage, accept or reject them.

The Data Controller responsible for the Processing of the personal data associated with these cookies is:

• Company name: Navigamo S.A.S.
• NIT: 902.022.728-1
• Registered address: Carrera 7a No. 106-75, oficina 502, Bogotá D.C., Colombia
• Channel to exercise your rights, questions and requests (petitions, complaints and claims) regarding personal data and cookies: faro@navigamo.co

This Policy must be read together with our Privacy Policy and Personal Data Processing Policy and our Personal Data Processing Policy, which describe in greater detail the purposes, the Data Processors and your rights as a Data Subject.

This Policy is governed by Law 1581 of 2012, Decree 1377 of 2013 and the other rules of the Colombian data protection regime (Habeas Data), under the supervision of the Superintendence of Industry and Commerce (SIC). It also includes specific provisions for visitors from the European Union (General Data Protection Regulation, GDPR, and the electronic communications regulations applicable to cookies) and for residents of the United States and the State of California (CCPA/CPRA), as indicated in Sections 8 and 9.

2. What cookies and similar technologies are

A cookie is a small text file that a website stores in your browser or device when you visit it. It serves to enable the website to remember information about your visit, such as the fact that you logged in, your preferences, or to measure how the website is used.

When in this Policy we say “cookies” we also refer to other similar technologies that perform equivalent functions, among them:

• Local browser storage (local storage and session storage): data that the website stores in your browser in a manner similar to a cookie.
• Pixels or web beacons (for example, the Meta pixel): invisible images or code fragments that allow a third party to know that you visited a page or performed an action.
• Device identifiers and measurement tags that associate your browser with an identifier for analytics or advertising purposes.

Cookies may be classified according to who places them:

• First-party cookies: placed directly by the domain that you visit (holafaro.com or app.holafaro.com).
• Third-party cookies: placed by a provider other than Navigamo (for example, Google, Meta or Microsoft) through a service integrated into our Websites.

And according to their duration:

• Session cookies: deleted when you close the browser.
• Persistent cookies: remain on your device for a determined period or until you delete them.

3. Types of cookies we use, by category

We classify the cookies and technologies of our Websites into the categories described below. Section 5 details, provider by provider, each specific technology.

3.1. Strictly necessary cookies (technical or essential)

These are indispensable for the Websites to function and to provide you with the service you request. Without them we could not, for example, keep your session logged in on the platform, remember the verification status of your email in the diagnostic, or protect the Websites against abuse.

They do not require your consent because they are necessary to provide a service that you have expressly requested. They cannot be deactivated from our cookie management mechanism; you may block them in your browser, but in that case parts of the Websites could stop functioning.

3.2. Analytics and performance cookies

These allow us to understand how visitors use the Websites: which pages are viewed, how long they stay, where they arrive from, what fails and what works. With this information we measure and improve the product. Some of these tools, such as Microsoft Clarity, may record the navigation session (cursor movements, clicks and scrolling through the page) to reconstruct in aggregate form how the website is used. These tools are configured not to capture the content that you type into sensitive fields.

They require your consent in the jurisdictions that so require (European Union) and we offer you control over them in the others (see Sections 7, 8 and 9).

3.3. Advertising and marketing cookies

These allow us to measure the effectiveness of our campaigns (for example, to know that a visit came from an ad and whether the person went on to request the diagnostic) and, where applicable, to display more relevant advertising on third-party platforms. These cookies are usually placed by third parties such as Google and Meta and may be used to create remarketing audiences.

They require your consent in the jurisdictions that so require (European Union) and we offer you control over them in the others (see Sections 7, 8 and 9).

3.4. Functional cookies (chat assistant)

These allow the chat assistant we offer on holafaro.com to attend to your inquiries. This assistant is provided by a third party (nemo, gonemo.ai) and may place cookies or use the browser’s local storage to remember the state of the conversation and its operation. It is a function that you initiate: it loads so that the chat is available when you need it.

These cookies are functional and are not used for analytics or for advertising. You can avoid them by refraining from using the assistant and by blocking cookies from your browser (see Section 7.2).

4. Summary of categories

Advertising and marketing cookies are activated solely on the marketing website holafaro.com. Analytics and performance cookies are activated on the marketing website and on the platform app.holafaro.com, and in both cases only after you give your consent. On the platform, analytics records only navigation (routes visited, clicks, scrolling and browser errors) and does not capture the content of the screens: neither what you type, nor the text you read, nor your documents nor your images.

5. Detail of the technologies we use

Below, each technology is described, who places it, its purpose, its category and where to consult the third party’s privacy policy. The exact duration of each cookie may vary according to the provider’s configuration; the indicated ranges are approximate.

5.1. Strictly necessary (first-party)

Platform authentication session (Supabase Auth). On app.holafaro.com, access is carried out by magic link or one-time code sent to your email, without a password. To keep your session logged in securely, we store session identifiers and authentication tokens in your browser storage (first-party cookies or local storage, depending on the flow). Without them you could not remain authenticated. Category: strictly necessary. Placed by: Navigamo (through the technology of Supabase). Duration: session and short-duration persistent.

Diagnostic status and email verification (holafaro.com). During the free diagnostic we store in your browser minimal technical information to remember the status of the form and of the verification by 6-digit code, so that the “verify first, run later” flow functions correctly. Category: strictly necessary. Placed by: Navigamo. Duration: session or short-duration.

Security and abuse prevention. Our Websites run on the infrastructure of Vercel, which may place technical cookies for load balancing and security necessary to serve the pages. In addition, for anti-abuse reasons we record on the server the IP address of the diagnostic visitor (this is explained in the Privacy Policy and Personal Data Processing Policy); that record is server-side and is not a browser cookie. Category: strictly necessary. Placed by: Navigamo / Vercel. Duration: session or short-duration.

5.2. Analytics and performance (third-party)

Google Analytics 4 (GA4). Measurement identifier G-PWK8NCDF39. Measures the traffic and use of the marketing website: page views, source of visits, events and conversions. It places cookies and identifiers in your browser and processes your IP address and your navigation behavior. Provider: Google. The data is processed in the United States (international transfer). Category: analytics. Placed by: Google (third party). Typical duration: up to 2 years (persistent). Google privacy policy: https://policies.google.com/privacy How to opt out of Google Analytics on any site: https://tools.google.com/dlpage/gaoptout

Microsoft Clarity. Experience analysis tool that may record the navigation session (cursor movements, clicks and scrolling) and generate heat maps, in order to understand how the marketing website is used and to improve it. On the marketing website the recording is in aggregate form and is configured to mask the content of text fields. Provider: Microsoft. The data is processed in the United States (international transfer). On the platform app.holafaro.com this tool records only navigation (routes visited, clicks, scrolling and browser errors), for the purpose of diagnosing failures of use. There the content of the screens is hidden completely and without exceptions: neither what you type, nor the text you read, nor your documents nor your images are captured. Category: analytics and performance (includes session recording). Placed by: Microsoft (third party). Typical duration: up to 1 year (persistent). Microsoft privacy policy: https://privacy.microsoft.com/privacystatement

5.3. Advertising and marketing (third-party, only on holafaro.com)

Google Ads (conversion tag and remarketing). Measures whether a visit came from one of our ads and whether it led to a conversion (for example, requesting the diagnostic), and allows the creation of remarketing audiences. Provider: Google. The data is processed in the United States (international transfer). Category: advertising and marketing. Placed by: Google (third party). Typical duration: up to 1 year or more (persistent). Google privacy policy: https://policies.google.com/privacy

Meta Pixel (Facebook). Measurement pixel that records visits and actions on the website to measure the effectiveness of the campaigns on Meta’s platforms (Facebook, Instagram) and to allow remarketing. Provider: Meta Platforms. The data is processed in the United States (international transfer). Category: advertising and marketing. Placed by: Meta (third party). Typical duration: up to 1 year (persistent). Meta privacy policy: https://www.facebook.com/privacy/policy

Note on international transfers. The third-party cookies described in 5.2 and 5.3 imply that your data (cookie identifiers, IP address and navigation behavior) is processed by providers located in the United States. The bases and guarantees of those transfers are described in the Privacy Policy and Personal Data Processing Policy and in the Personal Data Processing Policy.

5.4. Functional (third-party, only on holafaro.com)

Chat assistant (nemo, gonemo.ai). Chat widget we make available on holafaro.com to attend to your inquiries. It is provided by a third party, nemo (gonemo.ai), which may place cookies or use the browser’s local storage for the operation of the assistant and to remember the state of the conversation. It is a function that you initiate; the widget loads so that the chat is available when you need it. It is not used for analytics or for advertising. The provider may process the data you type into the chat in accordance with its own terms. Category: functional. Placed by: nemo (gonemo.ai) (third party). Typical duration: session or short-lived persistent, depending on the provider. Provider website: https://gonemo.ai

6. On what basis we process cookie data

• The strictly necessary cookies are processed because they are indispensable to provide you with the service you request (execution of the service or legitimate interest in the security of the Website). They do not require consent.
• The analytics, advertising and marketing cookies are processed, where the law so requires, on the basis of your consent, which you grant through our cookie management banner (see Section 7) and which you may withdraw at any time.

7. How to manage, accept or reject cookies

You are in control. You can manage cookies in two ways:

7.1. From our cookie consent banner

The first time you visit any of the Websites we show you a cookie management banner that allows you to:

• Accept all cookies.
• Reject all non-essential cookies (only the strictly necessary ones will be kept).
• Configure by category which ones you accept (analytics, advertising and marketing).

Analytics, advertising and marketing cookies are not activated until you give your consent in the jurisdictions that so require. You may change or withdraw your choice at any time by reopening the cookie preferences panel from the link available in the footer of the Websites. The withdrawal of consent does not affect the validity of the Processing carried out before the withdrawal.

7.2. From your browser settings

Independently, you may accept, block or delete cookies from your browser settings. Please note that if you block the strictly necessary cookies, some parts of the Websites could fail to function (for example, you could not keep your session logged in on the platform). Instructions for the most common browsers:

• Google Chrome: https://support.google.com/chrome/answer/95647
• Mozilla Firefox: https://support.mozilla.org/es/kb/proteccion-antirrastreo-mejorada-firefox-escritorio
• Apple Safari: https://support.apple.com/es-es/guide/safari/sfri11471/mac
• Microsoft Edge: https://support.microsoft.com/es-es/microsoft-edge

To opt out specifically of Google Analytics on all the sites you visit, you can install the opt-out add-on: https://tools.google.com/dlpage/gaoptout

8. Visitors from the European Union (GDPR)

If you visit us from the European Union or the European Economic Area, the following additional guarantees apply:

• Prior consent. Analytics, advertising and marketing cookies are installed only after you grant your free, specific, informed and unequivocal consent through the banner. Before that consent, only the strictly necessary cookies are active.
• Rejecting is as easy as accepting. The banner allows you to reject all non-essential cookies with the same ease with which you can accept them.
• Withdrawal of consent. You may withdraw your consent at any time from the cookie preferences panel, without this affecting the lawfulness of the prior Processing.
• International transfers. Accepting third-party cookies (Google, Meta, Microsoft) entails the transfer of your data to the United States. The guarantees of that transfer are described in the Privacy Policy and Personal Data Processing Policy.
• Your rights. You may exercise your rights of access, rectification, erasure, objection, restriction and portability by writing to faro@navigamo.co.

9. Residents of the United States and of California (CCPA/CPRA)

If you are a resident of the United States, and in particular of California, please note the following:

• Navigamo does not sell your personal data in exchange for money.
• The use of advertising and third-party cookies for analysis and targeted marketing purposes may be considered, under the CCPA/CPRA, a “share” of personal information for cross-context behavioral advertising.
• You have the right to opt out of such sharing (“Do Not Sell or Share My Personal Information”). You may exercise it from our cookie preferences panel by rejecting the advertising and marketing categories, and through our opt-out page available in the footer of the website.
• We honor the privacy preference signals emitted by your browser when they are technically recognizable, such as the Global Privacy Control (GPC).
• You also have the right to know what information we collect, to request its deletion, and not to be discriminated against for exercising these rights. To exercise them, write to faro@navigamo.co.

10. Minors

Our Websites and the Faro service are directed to persons of legal age who manage their professional presence. They are not directed to minors and we do not knowingly collect the data of minors through cookies. If you are responsible for a minor and consider that we have processed their data, write to us at faro@navigamo.co to address your request.

11. Changes to this Policy

We may update this Cookie Policy to reflect changes in the technologies we use, in our providers or in the applicable regulations. We will publish the version in force at this same address and we will indicate the date of “Last updated” in the header. When the change is substantial and affects the Processing based on your consent, we will request it from you again through the banner.

12. Contact

For any question, request or complaint (petitions, complaints and claims) related to this Cookie Policy or to the Processing of your personal data, you can write to us at:

Navigamo S.A.S. Carrera 7a No. 106-75, oficina 502, Bogotá D.C., Colombia Email: faro@navigamo.co