This Privacy Notice describes how We collect, use, disclose and store Your Data when You use the Fractual Platform (the “Platform”) and its services (the “Services”), in compliance with the applicable legal & regulatory framework.

Which personal data do we collect from you?

We only collect the following Data from You:

E-mail address (primary, verified); to send you notifications about the full Platform launch; and
Newsletter subscription preference (optional/checkbox); to determine whether You wish to receive updates & promotional materials.

Who controls and processes your personal data?

The Data Controller of your Data is FRACTUAL LTD, a company incorporated in Cyprus, with registered office at Omonoias 52, TROODOS COURT, 1st Floor, Flat/Office 3, 3052, Limassol.

Your Data may also be shared with authorized Fractual personnel and/or trusted work associates, who may process Your Data under strict confidentiality and access control protocols to provide You the Platform's Services (the “Data Processors”).

Why and on which legal basis do we process your personal data?

We shall process Your Data for the following purposes & on the following legal bases:

Data	Purpose	Legal Basis
	Create a user account and authenticate access	Performance of a contract
	Verify identity to comply with regulatory requirements	Legal obligation
	Signing legal agreement prior to investment	Performance of a contract
	Facilitate investment transactions	Performance of a contract
	Provide documentation of transaction	Performance of a contract
	Provide investment overview and tracking	Performance of a contract
	Facilitate deposits and flexible investment options	Performance of a contract
	Inform users about new offerings/investment opportunities and company updates	Consent
	Carry out company’s legal obligations, providing the necessary information to the competent authorities	Legal obligation
	Facilitate your subscription to the Fractual platform, when it is finalized	Consent

How long do we keep your data for and where?

We will keep all Your Data until you withdraw your consent and in any case for no longer than one (1) year.
We retain your Data within the European Union (“EU”) on Amazon Web Services servers. Nonetheless, your Data may be transmitted to the United States of America (“US”) by some of our Data Processors, based on the EU-US Data Privacy Framework.
If at any time the EU-US Data Privacy Framework is suspended/declared invalid, or if a Data Processor fails to re-certify for the EU-US Data Privacy Framework, any EU-US Data transfer will be subject to the Standard Contractual Clauses Schedules 1-3, which shall be enforced between the aforementioned Data Processor(s) and Us.

Which rights do you have?

You may ask us to:

Provide you with a copy of the personal data we keep for you.
Correct some data if it is not correct.
Erase your data.
Stop processing your data or delimit its processing to certain uses.
Send your data to another company or entity via logical means.
Withdraw your consent if you have provided it to us.

You may also contact Us at any time to request more information about your Data or opt-out of profiling–based communications.

How can you exercise your data rights?

If, at any time, You would like to exercise Your rights or ask any question(s) about Your Data, feel free to send an e-mail to the following address: dpo@fractual.com

We will respond to You within thirty (30) days from reception of Your request.

If You feel that the protection of Your Data has been violated, You may file a complaint with the Office of the Commissioner for Personal Data Protection (www.dataprotection.gov.cy)