Privacy Policy

1. Information We Collect

1.1 Personal Information

We collect information you provide directly to us, including:

• Identity Information: Full legal name, date of birth, nationality, government-issued ID documents
• Contact Information: Email address, phone number, mailing address
• Financial Information: Bank account details, cryptocurrency wallet addresses, source of funds documentation
• KYC/AML Data: Proof of identity, proof of address, selfie verification, accreditation status
• Investment Information: Investment history, portfolio preferences, risk tolerance

1.2 Automatically Collected Information

When you use our Platform, we automatically collect:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, time spent on pages, click patterns, features used
• Location Data: General geographic location based on IP address
• Cookies and Tracking: Session data, preferences, analytics information

2. How We Use Your Information

We use the information we collect to:

3. Information Sharing

We may share your information with:

• Service Providers: Third parties who perform services on our behalf (payment processors, KYC providers, cloud hosting)
• Property Partners: Property managers and partners involved in managing your investments
• Regulatory Authorities: Government agencies and regulators as required by law
• Legal Purposes: To comply with legal obligations, enforce our terms, or protect our rights
• Business Transfers: In connection with any merger, acquisition, or sale of company assets

We do not sell your personal information to third parties for marketing purposes.

4. Data Security

We implement industry-standard security measures including:

• SSL/TLS encryption for all data transmissions
• Encryption of sensitive data at rest using AES-256
• Multi-factor authentication for account access
• Regular security audits and penetration testing
• Access controls and employee training
• Secure data centers with physical security measures

While we take reasonable precautions, no security system is impenetrable. We cannot guarantee absolute security of your data.

5. Data Retention

We retain your personal information for as long as necessary to provide our services and fulfill the purposes described in this policy. We may retain certain information for longer periods as required by law (e.g., tax records, AML compliance) or for legitimate business purposes.

After account closure, we typically retain:

• Transaction records: 7 years (regulatory requirement)
• KYC documents: 5 years after relationship ends
• General account data: 3 years or as required by law

6. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access: Request a copy of the personal data we hold about you
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data (subject to legal retention requirements)
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to certain processing activities
• Restriction: Request limitation of processing in certain circumstances

To exercise these rights, please contact us at privacy@fractly.io. We will respond within 30 days.

7. International Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United Arab Emirates where our primary operations are based. We ensure appropriate safeguards are in place for such transfers in compliance with applicable data protection laws.

8. Third-Party Links

Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

9. Children's Privacy

Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we will take steps to delete such information.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by email or through a prominent notice on our Platform. Your continued use of our services after changes become effective constitutes acceptance of the revised policy.

11. Contact Us

For privacy-related inquiries or to exercise your rights: