Last Updated: 13/07/2025
1. Introduction and Scope
ASQARAT ("Company," "we," "us," or "our") is deeply committed to protecting the privacy and security of our users ("Data Subject," "user," or "you"). As the Data Controller, this Privacy Policy has been prepared to comprehensively explain what personal data we collect, for what purposes we process this data, to whom and for what reasons we may transfer it, our legal bases for data processing, and your rights concerning your personal data in connection with your use of our real estate investment platform, including our website (www.asqarat.com) and its associated services.
This policy aims to ensure full compliance with applicable data protection legislation.
2. Definitions
Personal Data: Any information relating to an identified or identifiable natural person.
Data Subject: The natural person whose personal data is being processed (our users, visitors, etc.).
Data Controller: The natural or legal person who determines the purposes and means of the processing of personal data and is responsible for establishing and managing the data filing system (ASQARAT, within the scope of this policy).
Data Processor: A natural or legal person who processes personal data on behalf of the data controller, based on the authority granted by the controller.
Processing: Any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
3. Personal Data We Collect and Methods of Collection
During your use of our platform, we collect and process various types of personal data due to the nature of our services.
Data Provided Directly by You:
Identity Information: Name, surname, national identification number, passport number, date of birth, and other identifying information required for Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures.
Contact Information: Email address, telephone number, residential address, and mailing address.
Financial Information: Bank account details (IBAN), credit card information (processed securely by our payment processor), investment preferences, income status, and investment history.
Account Information: Username, password (stored in encrypted form), profile picture, and other account settings on the platform.
Investment and Transaction Data: Investments you make, properties you show interest in, transaction history, contracts, and payment receipts.
Communication Records: The content of your support tickets, feedback, survey responses, and any communication you have with us via email or other channels.
Data Collected Automatically:
Device and Usage Data: Technical data such as your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths. This data is collected automatically through cookies and similar tracking technologies to ensure platform security, analyze performance, and improve user experience.
4. Purposes of Processing Personal Data
Your personal data is processed for the following purposes and is based on lawful grounds as defined by applicable data protection laws:
Provision of Our Services: To create and manage your investment account, execute your investment transactions, and carry out all operational activities directly related to the establishment or performance of a contract.
Compliance with Legal Obligations: To comply with our legal and regulatory obligations, including those related to Know Your Customer (KYC), Anti-Money Laundering (AML), tax, and other financial regulations.
Communication and Support: To respond to your inquiries, requests, and feedback; and to send you important information such as service updates, technical notices, and transaction confirmations.
Security: To ensure the security of our platform, your accounts, and your data; and to detect and prevent fraud, unauthorized transactions, and other illegal activities.
Marketing and Promotions (Based on Your Explicit Consent): Where we have your explicit consent, to send you marketing communications about new investment opportunities, promotions, newsletters, and other information we believe may be of interest to you.
Platform Improvement: To analyze user behavior and preferences in order to improve and personalize our services, our website's interface, and its functionality.
5. Transfer and Disclosure of Personal Data
User privacy is a fundamental principle for us. However, we may need to share your data with certain third parties to provide our services and fulfill our legal obligations.
Prohibition on the Sale of Personal Data: ASQARAT solemnly pledges that we will never sell, rent, or trade your personal data with any third party for marketing or any other commercial purposes.
Service Providers and Business Partners: We may share data with trusted service providers and business partners who act on our behalf and under our instructions for purposes such as platform hosting, data analysis, payment processing, email delivery, legal counsel, and auditing. These parties are contractually obligated to maintain the confidentiality of your data and are prohibited from using it for any purpose other than those specified in our contract.
Legal Obligations and Disclosure to Competent Public Authorities:
The Company reserves the right and obligation to disclose your personal data to competent official authorities in order to fulfill our legal duties, including but not limited to the following circumstances:
To comply with an applicable law, regulation, or legal statute.
To respond to a court order, subpoena, administrative investigation order, or other binding legal processes.
To fulfill information requests from regulatory and supervisory bodies, such as Financial Intelligence Units (FIUs).
When deemed necessary in good faith to protect the rights, property, or safety of our Company, our employees, or our users.
Any such data disclosure will always be based on a legitimate legal ground, will adhere to the principle of proportionality, and will be limited strictly to the scope of the request. Competent public authorities may contact us for legal data requests via official channels at contact@asqarat.com.
6. Data Security
We implement and maintain industry-standard technical and administrative security measures to protect your personal data from unauthorized access, loss, misuse, disclosure, alteration, and destruction. These measures include data encryption (SSL), firewalls, access control procedures, and staff training. However, we must remind you that no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security.
7. Your Rights as a Data Subject
In accordance with applicable data protection laws, you have the following rights concerning your personal data:
The right to be informed about and to access your personal data.
The right to request the correction (rectification) of inaccurate or incomplete data.
The right to request the deletion (erasure) of your personal data, also known as the "right to be forgotten."
The right to object to the processing of your personal data for certain purposes.
The right to request the restriction of processing of your personal data.
The right to data portability, allowing you to obtain and reuse your data for your own purposes across different services.
The right to withdraw consent at any time, where processing is based on consent.
To exercise these rights, you may submit your requests in writing to contact@asqarat.com.
8. Changes to This Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. Any material changes to this policy will be communicated to you by posting the updated version on our website and/or by notifying you via email. We encourage you to review this policy periodically to stay informed about our current practices.
9. Contact Information
If you have any questions or concerns about this Privacy Policy or our processing of your personal data, please do not hesitate to contact us at contact@asqarat.com.
Disclaimer: This Privacy Policy is provided for general informational purposes and does not constitute legal advice. It is strongly recommended that you consult with a legal professional to ensure full compliance with all legal obligations specific to your company's unique circumstances and jurisdiction.