Privacy Policy

Introduction

PropertyInvest ("we", "us", or "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our real estate crowdfunding platform.

We process personal data in accordance with the General Data Protection Regulation (GDPR), the Lithuanian Law on Legal Protection of Personal Data, and other applicable data protection laws.

By using our platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our policies and practices, please do not use our services.

Data Controller

The data controller responsible for your personal data is:

PropertyInvest UAB

Company registration number: 305123456

Address: Gedimino pr. 1, Vilnius, Vilnius, Lithuania

Email: [email protected]

Phone: +370 600 00000

Personal Data We Collect

We collect different types of personal data depending on how you interact with our platform:

Identity Data

Full name (first name, last name)
Date of birth
Gender
Nationality and citizenship
Personal identification number
Government-issued ID documents (passport, ID card, driver's license)
Photographs and selfies for identity verification

Contact Data

Email address
Phone number
Residential address
Mailing address (if different)

Financial Data

Bank account details (IBAN, account holder name)
Payment card information (processed securely by payment providers)
Source of funds information
Investment history and portfolio data
Tax identification number (TIN)
Tax residency information

Technical Data

IP address
Browser type and version
Device type and operating system
Time zone and location data
Cookies and similar tracking technologies (see our Cookie Policy)

Usage Data

Pages visited and features used
Time spent on pages
Click patterns and navigation paths
Search queries
Investment preferences and interests

Communication Data

Correspondence with our support team
Feedback and survey responses
Marketing preferences

How We Collect Your Data

We collect personal data through the following methods:

Direct Interactions

When you create an account, complete KYC verification, make investments, contact support, or fill out forms on our platform.

Automated Technologies

Through cookies, server logs, and analytics tools as you navigate our platform.

Third Parties

From identity verification providers, payment processors, credit bureaus, and public databases for AML/KYC compliance.

Public Sources

From publicly available sources such as company registries, sanctions lists, and politically exposed persons databases.

Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR:

Legal Basis	Processing Activities
Contract Performance Article 6(1)(b) GDPR	Creating and managing your account Processing investments and transactions Providing customer support Sending transactional communications
Legal Obligation Article 6(1)(c) GDPR	KYC/AML verification and monitoring Tax reporting requirements Responding to regulatory requests Fraud prevention and detection
Legitimate Interest Article 6(1)(f) GDPR	Platform security and fraud prevention Analytics and service improvement Direct marketing to existing customers Enforcing our terms and conditions
Consent Article 6(1)(a) GDPR	Marketing communications (newsletters, promotions) Non-essential cookies Sharing data with marketing partners

How We Use Your Personal Data

We use your personal data for the following purposes:

Platform Services

Create, maintain, and secure your investor account
Process your investments in real estate projects
Facilitate deposits, withdrawals, and returns payments
Provide portfolio tracking and reporting
Send transaction confirmations and account notifications

Regulatory Compliance

Verify your identity (KYC - Know Your Customer)
Conduct anti-money laundering (AML) checks
Screen against sanctions and PEP lists
Report to tax authorities as required by law
Comply with crowdfunding platform regulations

Communication

Respond to your inquiries and support requests
Send important service announcements
Notify you about new investment opportunities (with consent)
Send marketing materials and newsletters (with consent)

Platform Improvement

Analyze platform usage and user behavior
Improve our services and user experience
Develop new features and products
Conduct research and statistical analysis

Security

Detect and prevent fraud and unauthorized access
Maintain platform security and integrity
Investigate suspicious activities
Protect the rights and safety of our users

Data Sharing and Disclosure

We may share your personal data with the following categories of recipients:

Identity verification providers - for KYC/AML compliance (e.g., Onfido, Veriff)
Payment processors - for processing transactions (e.g., Stripe, banking partners)
Cloud hosting providers - for data storage and infrastructure
Email service providers - for sending communications
Analytics providers - for platform analytics (e.g., Google Analytics)
Customer support tools - for managing support requests

Bank of Lithuania (crowdfunding supervision)
Financial Crime Investigation Service (AML reporting)
Tax authorities (tax reporting obligations)
Other regulatory bodies as required by law

We may share limited investor information with real estate developers for projects you invest in, as necessary for contractual and legal purposes. This includes your name and investment amount for loan documentation purposes.

Legal counsel, accountants, auditors, and other professional advisors who need access to personal data to provide their services to us.

In connection with any merger, acquisition, sale of assets, or bankruptcy proceedings, your personal data may be transferred to the acquiring entity.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes.

International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer your data outside the EEA, we ensure appropriate safeguards are in place:

Adequacy decisions - transfers to countries deemed adequate by the European Commission
Standard Contractual Clauses (SCCs) - EU-approved contractual terms with data recipients
Binding Corporate Rules - for transfers within corporate groups
Certification mechanisms - such as approved codes of conduct

You can request a copy of the safeguards we use for international transfers by contacting us at [email protected].

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements.

Data Category	Retention Period	Reason
Account data	Duration of account + 10 years	Legal and regulatory requirements
KYC documents	10 years after relationship ends	AML regulations
Transaction records	10 years	Tax and accounting requirements
Investment contracts	10 years after maturity	Legal obligations
Support communications	3 years	Quality assurance
Marketing preferences	Until consent withdrawn	Consent-based
Analytics data	26 months	Platform improvement

Data Security

We implement appropriate technical and organizational security measures to protect your personal data:

Encryption

TLS/SSL encryption for data in transit; AES-256 encryption for data at rest.

Access Controls

Role-based access, multi-factor authentication, and principle of least privilege.

Monitoring

24/7 security monitoring, intrusion detection, and regular security audits.

Staff Training

Regular data protection training for all employees handling personal data.

While we implement robust security measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

Your Data Protection Rights

Under GDPR, you have the following rights regarding your personal data:

Right of Access

Request a copy of the personal data we hold about you.

Right to Rectification

Request correction of inaccurate or incomplete personal data.

Right to Erasure

Request deletion of your personal data (subject to legal retention requirements).

Right to Restriction

Request restriction of processing of your personal data.

Right to Data Portability

Receive your data in a structured, machine-readable format.

Right to Object

Object to processing based on legitimate interests or for direct marketing.

Right to Withdraw Consent

Withdraw consent at any time where processing is based on consent.

How to Exercise Your Rights

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

You also have the right to lodge a complaint with the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija) at vdai.lrv.lt.

Automated Decision-Making

We may use automated decision-making in the following circumstances:

KYC/AML screening - automated checks against sanctions lists and PEP databases
Fraud detection - automated analysis of transaction patterns
Risk assessment - automated investor classification based on provided information

You have the right not to be subject to a decision based solely on automated processing that produces legal effects or significantly affects you. If you believe an automated decision has been made incorrectly, you can request human review by contacting us.

Children's Privacy

Our platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from children. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately, and we will delete such information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

Posting the updated policy on this page with a new "Last updated" date
Sending you an email notification (for registered users)
Displaying a prominent notice on our platform

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

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