Privacy Policy
This Privacy Policy explains how Assukna Real Estate Lebanon SARL (“Assukna”, “we”, “us”) collects, uses, shares, and protects your personal data when you use our platform, websites, and mobile applications (the “Platform”). By using the Platform you acknowledge the practices described here.
1. Data we collect
Information you provide
- Account data: name, email address, phone number, country of residence, and password.
- Identity verification data: government identification, photographs/selfies, date of birth, address, and related documents collected through our verification provider to meet KYC/AML obligations.
- Financial data: wallet balances, transactions, investments, and payout details. Card payment details are handled by our payment provider, not stored by us.
- Communications: messages, support requests, and preferences (including language).
Information collected automatically
- Device and usage data such as IP address, browser type, pages viewed, and timestamps.
- Authentication cookies and similar technologies necessary to keep you signed in and to secure the Platform.
2. How we use your data
- To create and administer your account and provide the Platform.
- To verify your identity and comply with KYC, anti-money-laundering, and sanctions obligations.
- To process deposits, investments, distributions, and withdrawals.
- To detect, prevent, and investigate fraud, abuse, and security incidents.
- To communicate with you about your account, transactions, and important changes.
- To comply with legal obligations and enforce our terms.
- To improve and maintain the Platform.
3. Legal bases
Where data-protection law requires a legal basis, we rely on: performance of our contract with you; compliance with legal obligations (including financial and AML rules); our legitimate interests in operating and securing the Platform; and your consent where applicable (for example, optional marketing). You may withdraw consent at any time where consent is the basis.
Which law applies. Assukna is established in Lebanon, so the processing described here is governed by Lebanese law — principally Law No. 81 of 10 October 2018 on electronic transactions and personal data, together with the identity and record-keeping obligations of Law No. 44/2015 described in our AML & KYC Policy. Law No. 81/2018 requires that personal data be collected for a stated, lawful purpose, that it be accurate and no more than the purpose needs, that it be kept secure, and that the people it concerns be able to see it and have it corrected. It also regulates the collection of certain categories of data and their transfer abroad.
Many of our users live outside Lebanon, in countries whose own data-protection law — the EU and UK GDPR among them — may apply to them. This policy is deliberately written to the higher of the two standards. Where Lebanese law and the law of your country of residence differ, we apply whichever gives you more protection, except where Lebanese law obliges us to do something specific, in which case we comply with it and say so.
4. How we share your data
We share personal data only as needed, including with:
- Service providers who process payments, verify identity, send communications, and host our infrastructure, under contractual confidentiality and security obligations.
- Professional advisers such as auditors and lawyers.
- Authorities and regulators where required by law, court order, or to protect our rights, users, or the public.
- Successors in connection with a merger, acquisition, or sale of assets.
We do not sell your personal data.
5. International transfers
Your data may be processed in countries other than your own, including where our service providers operate. Where required, we put appropriate safeguards in place for such transfers.
6. Data retention
We keep personal data for as long as your account is active and thereafter as required to meet legal, regulatory, accounting, and dispute-resolution obligations — in particular, identity-verification and transaction records must be retained for periods set by applicable financial and AML law. When you delete your account, we begin a grace period before permanent deletion; certain records are retained where the law requires.
7. Your rights
Depending on your jurisdiction, you may have the right to access, correct, delete, or port your data, to object to or restrict certain processing, and to lodge a complaint with a supervisory authority. Some rights are limited where we must retain data to meet legal obligations. To exercise your rights, contact us using the details below.
Lebanon has no data-protection supervisory authority of the kind found in the EU — no independent regulator you can complain to about how your data has been handled. Rights under Law No. 81/2018 are exercised against us directly and, if necessary, through the Lebanese courts. We therefore commit to handling data requests as complaints, under the timelines in our Complaints & Dispute Resolution procedure. If a supervisory authority in your own country has jurisdiction over us, nothing here prevents you from complaining to it.
8. Security
We use technical and organizational measures to protect your data, including encryption in transit, hashed passwords, access controls, and audit logging. No system is perfectly secure, and we cannot guarantee absolute security.
9. Cookies
We use only cookies that are strictly necessary to authenticate you, keep the Platform secure, and remember your language preference. We set no advertising, tracking or analytics cookies. Because nothing we set today is optional, the notice shown on your first visit is an acknowledgement rather than a consent gate; if we introduce non-essential cookies, they will be placed only with your consent through a control that lets you decline. Every item we set is listed individually in our Cookie Policy.
10. Children
The Platform is not directed to anyone under 18, and we do not knowingly collect data from minors.
11. Changes to this Policy
We may update this Policy from time to time and will post the updated version with a revised “last updated” date. Material changes will be communicated where appropriate.
12. Contact
For privacy questions or to exercise your rights, contact our data-protection contact at privacy@assukna.com.