This Privacy Policy (“Policy”) explains what you can expect from us and what we need from you in relation to your personal data. Kindly read this Policy carefully because this is legally binding when you use C Estates Services, no matter how you access or use them, including through mobile devices.
We reserve the right to revise, amend or update this Policy at any time by posting the updated version on this site including its effective date. Moreover, we shall announce material changes to this Policy by email.
Definitions
The following terms used in this Policy are defined as follows:
“Cryptoasset” is a digital representation of value (also referred to as “cryptocurrency,” “virtual currency,” “digital currency,” “crypto token,” “digital asset,” or “digital commodity”), such as bitcoin (BTC), ether (ETH), XEM, or XCET, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.
“C Estates Account” means a user-accessible account offered via the C Estates Tokenized Real Estate Platform where Digital Assets are stored by C Estates.
“C Estates, “We,” and “Us” refers to C Estates and its wholly owned subsidiaries (also referred to collectively as 'we,' or 'us').
“Personal Information” or “Personal Data” refers to any information relating to you, as an identified or identifiable natural person, including your name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.
Data controller
C Estates provides various Cryptoasset-related services within its Tokenized Real Estate Platform. C Estates is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards, this Privacy Policy, as well as any relevant national laws.
C Estates uses encryption to protect your information and store decryption keys in separate systems. Data controllers process and retain your personal information on our servers where our data centers are located.
Where we have a legal obligation to do so, we have appointed Data Protection Officers (DPOs) to be responsible for privacy program for the respective data controllers. If you have any questions about how we protect or use your Personal Information, you can contact our DPOs by email at info@cestates.io.
Protecting personal information
We are serious about guarding the privacy of your Personal Information and work hard to protect C Estates and you from unauthorized access to, or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take include encryption with SSL; the availability of two-factor authentication (2FA) at your discretion, and periodic review of our Personal Information collection, storage, and processing practices.
We restrict access of your Personal Information only to C Estates employees, affiliates, and subcontractors who have a legitimate business need for accessing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information. We maintain physical, electronic, and procedural safeguards that comply with the relevant laws and regulations to protect your Personal Information from unauthorized access.
Unfortunately, despite best practices and technical safeguards, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data during transmission, and any acts of transmission are at your own risk.
Information we may collect about you
When using the C Estates Services, we may collect and use the following data about you:
Other Personal Information or commercial and/or identification information – Whatever information we, in our sole discretion, deem necessary to comply with our legal obligations under various Anti-Money Laundering (AML) obligations, such as those under the Anti-Money Laundering Act of 2001 (as amended), European Union’s 4th AML Directive and the U.S. Bank Secrecy Act (BSA).
Information we may collect about you
Account Information. Information that is generated by your C Estates account activity including, but not limited to, instructions regarding funding and disbursement, orders, trades, and account balances;
Log Information. Information that is generated by your use of C Estates Services that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page;
Location Information. Information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform;
Correspondence. Information that you provide to us in written or oral correspondence, including opening a C Estates account, and with respect to ongoing customer support; and logging of phone numbers used to contact us.
Information we receive about you from other sources.
We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them. For example:
General Provisions
Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned. If you are located within the European Economic Area (EEA), this Information will not be retained without your consent.
In providing the personal data of any individual (other than yourself) to us during your use of the C Estates Services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal data for the purposes set out in this Privacy Policy.
Uses of Personal Data
Below we set forth in a table format, a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at info@cestates.io if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| What we use your personal information for | Type of information | Our reasons | Our legitimate interests |
|---|---|---|---|
To provide the C Estates Services:
| Submitted Information | Fulfilling contracts Our legitimate interests Our legal obligation | Being efficient about how we fulfill our legal and contractual duties. Our commercial interest in providing Provide you with good service. Complying with regulations that apply to us. |
| Submitted Information Device Information Third Party Information | Our legitimate interests Our legal obligation | Complying with regulations that apply to us. |
To combat against fraud:
| Submitted Information Device Information Third Party Information | Fulfilling contracts Our legitimate interests Our legal obligation | As part of C Estates’s efforts to keep our Services safe and secure. |
To help C Estates to market and provide services that interest you:
| Submitted Information Device Information Third Party Information | Our legitimate interests | Developing products and services for existing customers and any applicable fees in relation to them. Defining types of customers for new products or services. Being efficient about how we fulfil our legal and contractual duties. Seeking your consent when we need it to contact you. |
To keep the C Estates Services available and properly functioning; To administer internal operations necessary to C Estates Services, including troubleshooting, data analysis, testing, research, statistical, and survey purposes; To notify you about changes to our service, changes to our terms and policies, and as part of our efforts to keep the C Estates Services, safe and secure. | Submitted Information Device Information | Fulfilling contracts Our legitimate interests Our legal obligation | Being efficient about how we fulfill our legal and contractual duties. Complying with regulations that apply to us. |
Disclosure of your personal information
We may share your personal information with selected third parties including:
We may disclose your personal information to third parties when:
We seek information necessary to maintain or develop customer relationships, services and systems.
We do not maintain a published list of all of the third parties with whom we share your personal information with, as this would be heavily dependent on your specific use of our Services. However, if you would like further information about who we have shared your personal information with, or to be provided with a list specific to you, you can request this by writing to info@cestates.io.
Where we store your personal data
Our operations are supported by a network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers store and process your personal data in the European Union, Japan, Singapore, the United States of America, and elsewhere in the world.
Sharing your data outside EEA
To provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties that are based outside of the European Economic Area (EEA). In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical, and organizational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties.
By using C Estates Services, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than in your country. In all such transfers, we will protect your personal information as described in this Policy and in a manner consistent with the best practices in data protection. For more information, please contact us at info@cestates.io.
Profiling and automated decision making
We may use Automated Decision Making (ADM) to improve your experience or help fight financial crime. For example, so that we can provide you with a fast and efficient service, we may use ADM to verify your identity documents, or to confirm the accuracy of the information you have provided to us. None of our ADM processes will adversely the privacy of your personal data.
We may use Automated Decision Making (ADM) to improve your experience or helpfight financial crime. For example, so that we can provide you with a fast and efficientservice, we may use ADM to verify your identity documents, or to confirm the accuracyof the information you have provided to us. None of our ADM processes will adverselythe privacy of your personal data.
Privacy when using digital assets and blockchains
Your cryptoasset transactions may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data.
Because blockchains are decentralized or third-party networks which are not controlled or operated by C Estates or its affiliates, we are not able to erase, modify, or alter personal data from such networks.
Data Retention
As C Estates is subject to various legal, compliance and reporting obligations, including AML requirements, we are required by law to store some of your personal and transactional data beyond the closure of your account with us. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary. We will delete data that is no longer required by any relevant law or jurisdiction in which we operate.
Cookies
When you use C Estates Services, we observe standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit C Estates Services. We use Cookies to (i) help us recognize you as a customer, collect information about your use of C Estates Services to better customize our services and content for you, and to collect information about your computer or other access devices as part to ensure our compliance with our Anti-Money Laundering and Combating of Terrorist Financing obligations and (ii) ensure that your account security has not been compromised by detecting irregular or suspicious account activities
We use both session and persistent Cookies. Session Cookies expire when you log out of your account or close your browser. Persistent Cookies remain on your computer or mobile device until deleted or otherwise expire. Most web browsers are set to accept Cookies by default. You are free to decline most of our session Cookies if your browser or browser add-on permits but choosing to remove or disable our Cookies may interfere with your use and functionality of the C Estates Services.
Email Communications
Subject to applicable laws and regulations, we may from time to time send communications promoting services, products, facilities, or activities to you using information collected from you. When you create a C Estates Account you are agreeing to opt-in to all communications from us. We will provide you with an opportunity to opt-out of newsletter communications. We will never provide your Personal Information to third parties for direct marketing or other unrelated purposes without your written consent. Unfortunately, we are unable to allow you to opt-out of the emails we send you for certain legal or administrative purposes.
Cookies
You may decline session cookies if your browser or browser add-on permits but choosing to remove or disable our cookies may interfere with your use and functionality of the C Estates Services.
Right of Rectification
You have the right to correct any personal information We hold on you that is inaccurate, incorrect, or out of date.
Right of Erasure
You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which C Estates is subject to.
Portability
You may have the right to transfer certain of your personal data between data controllers, for example, to move your account details from one online platform to another.
Location Information
You may be able to stop the collection of location information through your device settings or by following the standard uninstall process to remove our applications from your device; however, because such data is used by us to meet legal requirements, as well as for ongoing fraud and risk monitoring purposes, choosing to remove or disable location services may interfere with your use and functionality of the C Estates Services.
Access to information
Subject to applicable laws, you may have the right to access information we hold about you. Your right of access can be exercised in accordance with the relevant data protection legislation. For further information, please contact info@cestates.io.
Changes to this Privacy Policy
Any changes we may make to our Privacy Policy will be posted on C Estates’ Site and applications and, where appropriate, notified to you by email. Kindly monitor periodically the Site to see any updates or changes to our Privacy Policy.
Contact
We welcome any questions, comments and requests regarding this Privacy Policy and should be addressed to info@cestates.io.