Data Protection Policy

This Privacy Policy explains how EstateX collects, uses, and discloses information about you when you use our website https://www.estatex.eu and online services (the “Services”) when you interact with us as described below.

We may change this Privacy Policy over time at our sole discretion. If we make changes, we will notify you by revising the date at the top of this Privacy Policy, and the updated Privacy Policy will be posted via a hyperlink at the bottom of our website homepage. In some cases, we may provide you with additional notice (such as by adding a statement relating to Privacy Policy changes to our website homepage or by sending an email notification). We encourage you to review this Privacy Policy whenever you access the Services to stay informed about our information practices and the choices available to you.

It is your obligation to periodically visit our Website to review any changes that may be made to this Privacy Policy. Your continued use of our Website and Services constitutes your agreement to be bound by our Privacy Policy and any changes to the Privacy Policy. If you do not agree with this Privacy Policy, you are not authorized to use our Website and your sole recourse is to not use our Website or the Services.

We understand that your privacy is important, and we are strongly committed to protecting it. This includes the Personal Data or Information that you may provide when you access and use the content we own or operate on the websites located at https://www.estatex.eu, or any other websites, apps, pages, features, or content we own or operate (hereafter: the “Site(s)”) and/or when you use our mobile application and related services (referred to collectively hereinafter as “Services”).

In addition, information that you submit to EstateX in response to an email, request for information, or other outreach to EstateX, or through any EstateX application processes, will also be treated in accordance with this Privacy Policy.

In this written Privacy Policy, EstateX describes the use of your Personal Data by EstateX and the scope and breadth of our commitment to privacy. We undertake to ensure that your Personal Data is handled responsibly and in compliance with the legal requirement of State and Federal laws and regulations.

1. Acceptance of EstateX Privacy Policy

By exploring and using the EstateX Site and/or Services, and by submitting information to EstateX, you signify acceptance to the terms of our Privacy Policy.

Where we require your consent to process your Personal Data, we will ask for your consent to the collection, use, and disclosure of your Personal Data as described further below.

EstateX may provide additional “just-in-time” disclosures or additional information about the data collection, use, and sharing practices of specific Services.

If you do not agree with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

2. Personal Data & GDPR

Personal Data is data that can be used to identify you directly or indirectly or to contact you.

Our Privacy Policy covers all Personal Data that you voluntarily submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymized data, as it cannot be used to identify you. You may be asked to provide Personal Data anytime you are in contact with us.

EstateX may also combine your Personal Data with other information to provide and improve our products, services, and content (see the section below).

Except as described in this Privacy Policy, EstateX will not give, sell, rent or loan any Personal Data to any third party.

2.1 Personal Data We Collect

We collect personal data you provide directly to us or which you generate when you open an account with us, use our Services or our website(s) and platform(s).

We collect your information strictly under the General Data Protection Regulation and which applies across the European Union.

When we require certain personal data from users it is because we are required by law to collect this data (anti-fraud / anti-money laundering / counter financing of terrorism / know your customer obligations) or it is relevant for specified purposes. Any information you provide to us that is not required is voluntary.

You are free to choose whether to provide us with the types of Personal Data requested, but we may not be able to serve you as effectively or offer you all of our Services when you do choose not to share certain information with us.

We also collect Personal Data when you use or request information about our Services, subscribe to marketing communications, request support, complete surveys, or sign up for one of our events.

We may also collect Personal Data from you offline, such as when you attend one of our events, or when you contact customer support.

We may use this information in combination with other information we collect about you as set forth in this Privacy Policy.

3. What information do we collect?

Personal information you disclose to us;

We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services when you participate in activities on the Services, or otherwise when you contact us.

All Sensitive Information (Passport/ID) is securely encrypted and processed by accredited 3rd party providers.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information – such as your Internet Protocol (IP) address and/or browser and device characteristics – are collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

4. How do we process your information?

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with the Services, including:

• To deliver, maintain, and improve our Services and Website.
• To communicate with you about your account, the Services, and changes to our terms or policies.
• To facilitate compliance with anti-money laundering (AML), counter-terrorist financing (CTF), and know-your-customer (KYC) obligations.
• To detect, prevent, and respond to fraud, abuse, security incidents, or other harmful activity.
• To comply with our legal obligations under European Union law, including the Markets in Crypto-Assets Regulation (MiCA) and the General Data Protection Regulation (GDPR), and applicable national laws.
• To respond to your inquiries, support requests, and other communications.
• To send you marketing communications where permitted by law and where you have not opted out.
• To enforce our terms and protect our rights, property, and the safety of our users and others.

5. When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

6. Do we use cookies and other tracking technologies?

We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

7. How do we handle your social logins?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

8. Is your information transferred internationally?

We may transfer, store, and process your information in countries other than your own.

Our servers and primary data processing facilities are located in the European Economic Area, principally in the Netherlands and in Microsoft Azure’s West Europe region. If you are accessing our Services from outside the EEA, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “When and with whom do we share your personal information?” above), in the European Union and other countries where our service providers operate.

Where personal data is transferred outside the EEA, we rely on appropriate safeguards under the GDPR, including the European Commission’s Standard Contractual Clauses and, where applicable, adequacy decisions.

If you are a resident in the European Economic Area (EA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

9. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). In general, we retain personal information for the longer of (a) the period during which you maintain an active account or relationship with us, (b) any retention period required by applicable law — typically up to seven (7) years for financial, tax, and AML records under Dutch law — or (c) the duration of any active dispute, investigation, or legal claim involving your information.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. Do we collect information from minors?

We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please contact us at [email protected].

11. What are your privacy rights?

In Short: You may review, change, or terminate your account at any time.

If you are located in the EA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account on our investment platform and update your information directly through your account settings; or
• Contact us by email at [email protected] with your request.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

12. Controls for Do-Not-Track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized.

As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. Do California residents have specific privacy rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request the removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

14. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible.

If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

15. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at [email protected]

16. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request by email at [email protected].

17. Contact us

Contact [email protected]