Data Privacy Policy
1. Who We Are and How to Contact Us
1.1. The Asette.ai Platform is owned and operated by Asette, Asette Holdings Limited, Al Maqam Tower, Abu Dhabi Global Market Square, Al Maryah Island, Abu Dhabi, UAE (“Asette.ai” or “We”).
2. Applicable Terms and Consent
2.1. When you access or use the Asette.ai Platform, or otherwise provide any personal data to us, you agree to this Data Privacy Policy, including the manner in which we use your personal data. If you do not agree to this Data Privacy Policy, or to any changes we subsequently make to this Data Privacy Policy, you must immediately stop using the Asette.ai Platform or otherwise providing any information to us. 2.2. Further, we reserve the right to change, in our sole discretion, the terms of this Data Privacy Policy at any time by publishing the varied terms on the Asette.ai Platform, with or without notice. 2.3. You are responsible for reviewing regularly information posted online to obtain timely notice of such changes. As such, we recommend that you check the Asette.ai Platform regularly to ensure you are aware of our current terms. We do not undertake to keep our Asette.ai Platform up-to-date and we are not liable if any content is inaccurate or out-of-date. Your continued use of the Asette.ai Platform after changes are posted constitutes your acceptance of the Data Privacy Policy as modified by the posted changes. 2.4. Regardless of later updates or changes to our Data Privacy Policy, we will never use the information you submit under our current Data Privacy Policy in a new way without first providing you an opportunity to opt-out or otherwise prevent that use.
3. Age of Consent and Third Party Services
3.1. The Asette.ai Platform is intended for users who are at least 18 years old. Persons under the age of 18 are not permitted to register for the Asette.ai Platform. 3.2. You need to create an account to access and use the Asette.ai Platform and in doing so, you must provide us with accurate and complete information as prompted by the registration process. 3.3. We may use various online third-party services, such as Google Email, Whatsapp, Calendly (“Third Party Services”). In order to use these features and capabilities, we may ask you to authenticate, register for, or log into Third Party Services on the websites of their respective providers. As part of this integration, the Third Party Services will provide us with access to certain information you have provided to them, and we will use, store, and disclose such information in accordance with this Data Privacy Policy. 3.4. Third Party Services use, store, and disclose your information solely in accordance with their own policies. We assume no responsibility or liability for the privacy practices or any other actions of any third-party website or service that may be enabled within our services or of which a link is included on the Asette.ai Platform. Further, we assume no responsibility or liability for any damage or loss caused or alleged to be caused by or in connection with the use of or reliance on any such Third Party Services.
4. Personal Data We Collect
4.1. To let us operate the Asette.ai Platform effectively and to let you use the Asette.ai Platform, we may collect, use, and store the personal data described below. We also disclose certain information to third parties, as described further below. The information we collect is received directly or indirectly from you and generated in the course of your use of the Asette.ai Platform. The data we collect is not used for marketing or any other purposes except as specified in this Privacy Policy. Identity Data includes name, nationality and residence status. Contact Data includes country of residence, address, email address and telephone numbers. Financial Data includes savings and loans data. Transaction Data includes details of properties you have invested through Asette.ai platform. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and other technology on the devices you use to access the Site. Account Registration Data includes certain information in connection with the account registration process such as whether you registered using any Third-Party Services and whether you verified your email address or phone number. Usage Data includes information about how you use Asette.ai Platform and all our services under the domain. Login Data includes information regarding logins and activity conducted during that log in. Marketing and Communications Data includes your preferences in receiving marketing and your communication preferences. 4.2. We also get information about you and your activity outside the Asette.ai Platform from our affiliates, advertisers, partners and other third parties we work with. For example, online advertisers or third parties share information with us to measure, report on or improve the performance of ads, or to figure out what kinds of ads to show you. 4.3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Data Privacy Policy.
5. How We Collect Your Personal Data
5.1. We collect personal data through one or more of the following ways: • when you visit the Asette.ai Platform we collect data regarding the particular pages you have visited or viewed, the amount of time you spent on the Asette.ai Platform, the errors you experienced, your mobile device ID and IP address. • when you register your account as an investor we collect Identity Data and Contact Data. • when you enter into an investment transaction facilitated by the Asette.ai Platform. • referring websites or third parties, including social media sites. • when you elect to receive marketing communications from us. • the maintenance and analysis of our server logs; and • “cookies” (small text files placed by us on your computer(s)), single pixel GIF image files, website server log analysis and other similar technological means.
6. How We Use your Personal Data
6.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: • With your consent. • Where we need to perform the contract we are about to enter into or have entered into with you. • Where we need to comply with a legal obligation. 6.2. We plan to use your personal data for the following purposes: • To communicate with you, verify your identity, and conduct AML/KYC assessments (Identity/Contact Data; Lawful basis: Consent/Performance of contract). • To create and manage your account and provide support (Identity/Contact Data; Lawful basis: Consent/Performance of contract). • To assess suitability for investment (Identity/Contact/Financial Data; Lawful basis: Consent/Performance of contract). • To facilitate investment transactions (Identity/Contact/Financial/Transaction/Marketing Data; Lawful basis: Consent/Performance of contract). • To manage our relationship, notify about changes, or ask for reviews (Identity/Contact/Profile/Marketing Data; Lawful basis: Consent/Performance of contract/Legal obligation). • To review content for risk detection (Identity/Contact Data; Lawful basis: Protect your interest). • To deliver relevant content and advertising (Identity/Contact/Profile/Usage/Marketing/Technical Data; Lawful basis: Consent/Performance of contract). • To make suggestions and recommendations (Identity/Contact/Technical/Usage/Profile/Marketing Data; Lawful basis: Consent/Performance of contract). • To comply with legal or regulatory requirements (Identity/Contact Data; Lawful basis: Protect your interest/Legal obligation). 6.4. “Performance of Contract” means processing your personal data where it is necessary for the performance of a contract to which you have consented to be a party.
7. How We Make Sure Your Personal Data Is Secured
7.1. To protect your personal data, we take reasonable precautions to try to ensure that it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. 7.2. We implement and maintain appropriate technical, security and organizational measures in relation to the processing of your personal data so that the processing will meet the requirements of applicable Data Protection Laws and ensure the protection of your rights.
8. Retaining Personal Data
8.1. We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 8.2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your data, and whether we can achieve those purposes through other means.
9. Your Rights
9.1. Under certain circumstances, you have rights under applicable Data Protection Laws in relation to your personal data: • Right to request access to your personal data. • Right to request correction of the personal data that we hold about you. • Right to request erasure of your personal data. • Right to object to processing of your personal data. • Right to request restriction of processing of your personal data. • Right to request the transfer of your personal data to you or a third party. • Right to withdraw consent at any time where we are relying on consent. 9.2. To make enquiries, exercise any of your rights set out above, or withdraw your consent, please contact us via: Hello@asette.com. 9.3. You will not have to pay a fee to access your personal data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. 9.4. We may need to request specific information from you to help us confirm your identity and ensure your right to access. 9.5. We try to respond to all legitimate requests within one month. 9.6. You may have the right to lodge a complaint with the supervisory authority in your country of residence. 9.7. It is important that the personal data we hold about you is accurate and current.
10. Sharing of Personal Data With Third Parties
10.1. We will not sell your personal data to third parties. 10.2. Your personal data may be disclosed to third parties for business purposes, advertising, and facilitating Transactions with Real Estate Developers. 10.3. We may share information with vendors, service providers (data hosting/storage), analytics/advertising providers, and professional advisers (auditors, law firms). 10.4. We may also share data with third parties to whom we may choose to sell, transfer, or merge parts of our business. 10.5. We require all third parties to respect the security of personal data and to treat it in accordance with the law. 10.6. We will not otherwise share personal information except where permitted or required by law. 10.7. You can opt out of receiving email marketing by using the unsubscribe link provided in our communications.
11. International Transfers
11.1. The Asette.ai Platform is controlled and operated by us from the United Arab Emirates. By accepting the terms of this Privacy Policy you agree that any personal information you provide may be stored, processed, and transferred between the United Arab Emirates and other countries. We will handle your personal information in accordance with this Privacy Policy at all times.
12. Privacy Disputes
12.1. You will resolve any claim, cause of action or dispute (claim) you have with us arising out of or relating to this Data Privacy Policy exclusively in the ADGM Courts. The laws of England and Wales will govern this Data Privacy Policy. 12.2. If anyone brings a claim against us related to your actions, content or information on our Asette.ai Platform, you will indemnify and hold us harmless from and against all damages, losses, and expenses.
13. Cookies and Other Web Technologies
13.1. The types of cookies and similar technologies used by us and our partners in connection with the Asette.ai Platform can be classified into one of five categories, namely ‘essential website cookies’, ‘functionality cookies’, ‘analytics and performance cookies’, ‘advertising cookies’, and ‘social media cookies’. Cookies do a lot of different tasks to ensure you enjoy your visit to our Asette.ai Platform. For example, they are used to remember your preferences, help you navigate between pages more efficiently, enable you to log into your account more easily, and make sure the adverts you see are relevant to you and your interests. 13.2. You can block these cookies and similar technologies by changing your browser setting. However, in relation to those that are essential for the operation or improve the functionality of the Asette.ai Platform, this may impact your use of the Asette.ai Platform.
13.3. You can choose to enable or disable cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser. 13.4. You can choose to delete cookies at any time; however you may lose any information that enables you to access the Asette.ai Platform more quickly and efficiently including, but not limited to, personalisation settings. 13.5. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings. 13.6. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.