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Draft — pending legal review. This document is a working template and does not yet constitute final, legally binding terms. It must be reviewed and approved by qualified counsel before launch.

Privacy Policy

Last updated: June 2026

This Privacy Policy explains how Assukna Real Estate 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 and crypto payment details are handled by our payment providers, 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.

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.

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 cookies and similar technologies that are strictly necessary to authenticate you and keep the Platform secure, and, where applicable, optional cookies to understand and improve usage. You can control non- essential cookies through your browser or any consent controls we provide. [Confirm cookie-consent mechanism and any analytics cookies with counsel.]

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.