Privacy Policy relating to the use of the Bricksave Real Estate Crowdfunding platform
1. The present Privacy Policy (“Privacy Policy”) applies to the use of the services (“Services” as a whole, and each of them, a “Service”), offered or made available through the Website owned by Bricksave (Diversified Real Estate Asset Management Ltd.), a company constituted under the laws of the United Kingdom, as well as its branches or other companies controlled by it (as a whole, “Diversified Real Estate Asset Management Ltd.”).
1.1. Using any of the Services implies becoming a Bricksave (Diversified Real Estate Asset Management Ltd.) user (“User”) and the full and unrestricted acceptance by the User of each and every clause of the version of the Privacy Policy published by Bricksave (Diversified Real Estate Asset Management Ltd.) that is in place at the very moment the User uses the Services. Consequently, the Privacy Policy will be a valid and mandatory agreement between the User and Bricksave (Diversified Real Estate Asset Management Ltd.) regarding privacy in the use of the Services. For this purpose, the User must thoroughly read the Privacy Policy before using the Services. Likewise, the use of the Services implies full and unrestricted acceptance by the User of the Terms of Use of the Services (“Terms of Use”), which are complemented by this Privacy Policy.
1.2. If necessary, Bricksave (Diversified Real Estate Asset Management Ltd.) will complement the Privacy Policy with information and/or specific terms and conditions related to a specific Service.
1.3. Bricksave (Diversified Real Estate Asset Management Ltd.) may modify the Privacy Policy at any time. The new version will be communicated by (i) its publication on the Website and/or (ii) by email to the Users with a link to Privacy Policy.
1.4. The User accepts he will be considered notified of any changes in the Privacy Policy once Bricksave (Diversified Real Estate Asset Management Ltd.) has published them at the Privacy Policy site, and that the following uses of the Services by the User will imply acceptance of the new version of the Privacy Policy. Consequently, the User accepts to (i) check Bricksave (Diversified Real Estate Asset Management Ltd.)´s privacy policy periodically, and (ii) read any email sent by Bricksave (Diversified Real Estate Asset Management Ltd.) containing changes or updates of the Privacy Policy.
1.5. If in doubt regarding the Privacy Policy, please write to us at [email protected]
1.6. To Bricksave (Diversified Real Estate Asset Management Ltd.) privacy of Personal Data is a very important matter.
2. Bricksave (Diversified Real Estate Asset Management Ltd.) will eventually collect information about the behavior of its Users, by means of cookies, tags, web beacons and other methods, such as the information provided by the Users upon registration on the Website.
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
a) A cookie is a small text file by which an internet browser may be exclusively identified, and it is usually installed in, sent to or written in the internet users’ computers when they browse an internet website, with the purpose of obtaining automatic information about their behavior when browsing the site. A cookie file generally has the name of the website where it has been transferred, its creation date and an identification code. The only personal information a cookie may contain is information the user himself provides when surfing the internet, such as IP address, visited sites, order of visits, time spent on each site, date and time, etc. (“Activity Information”). A cookie cannot read the User’s hard drive data nor other cookie files created by other websites.
b) A tag is a small image embedded in a website so that the site’s owner or a third party may monitor who is visiting the website, collect his IP, the URL of the site it comes from and the exact moment it was seen there. These tags may be used together with cookies.
c) A Web beacon is an electronic image, also called single-pixel (1 x 1) o transparent pixel that is embedded in a website. A Web beacon has similar uses as cookies, and also measures users’ web traffic patterns. The User accepts that Bricksave (Diversified Real Estate Asset Management Ltd.) may use a follow-up system based on Web beacons.
2.1. Bricksave (Diversified Real Estate Asset Management Ltd.) usually collects User information in order to improve service quality, by storing User preference data and supervising behavior trends, as in the kind of searches they perform.
2.2. It is possible that a User register at Bricksave (Diversified Real Estate Asset Management Ltd.) through his personal account on a social network (“Personal Account”) and enters the Website through it. In that case, the User accepts that Bricksave (Diversified Real Estate Asset Management Ltd.) may access the information in his Personal Account that the User accepts to share when registering at Bricksave (Diversified Real Estate Asset Management Ltd.).
3. Also, as part of the Services, Bricksave (Diversified Real Estate Asset Management Ltd.) will collect User information by means of cookies, web beacons, and/or tags. The information collected by Bricksave (Diversified Real Estate Asset Management Ltd.) may include browsing behavior, IP address, logs and other kind of information. This will be informed by Bricksave (Diversified Real Estate Asset Management Ltd.) to the Users, thus obtaining their express or tacit consent. However, Bricksave (Diversified Real Estate Asset Management Ltd.) will not collect personal identifiable information in a direct way of any User, neither by cookies nor by tags.
3.1. Bricksave (Diversified Real Estate Asset Management Ltd.) will at any time provide information or segmentation analysis services to third parties that are either networks or service providers, who will be able to use the information collected to predict User characteristics, behaviors or preferences, typically used to consequently publish advertising.
3.2. Bricksave (Diversified Real Estate Asset Management Ltd.) will process the information and the personal and non-personal data in accordance with the provisions laid down in this Privacy Policy and in the Additional Notices included in certain Services. Likewise, Bricksave (Diversified Real Estate Asset Management Ltd.) recommends, supports and strongly encourages third parties and other Users, to adopt privacy policies designed to inform about the information collection practices they apply. The User must be familiar with the privacy policies of the websites he visits to understand what information the site collects, how it uses it, what his options are and how he is protected.
4. Bricksave (Diversified Real Estate Asset Management Ltd.)’s Website (“The Website”) collects contact information of Users and potential Users who requested information or Services from Bricksave (Diversified Real Estate Asset Management Ltd.) The identifiable personal contact information collected at the Website will be used to answer those requests or to provide access to the Services through email contact methods. Bricksave (Diversified Real Estate Asset Management Ltd.) will not sell, rent or lease any personal information to a third party with promotional purposes or any other purpose, except as established in the present clause. Any person who provides personal contact information through the Website will be able to update, delete and/or correct his personal contact information through the same Website or, if unable to do so, by contacting Bricksave personnel at [email protected]. In the event that the correction of the personal information is not successfully accomplished by either of those two means, Users may turn to the corresponding authorities to require said corrections. The information shall be redundantly stored on multiple Amazon server devices across multiple facilities.
4.1. Bricksave (Diversified Real Estate Asset Management Ltd.)’s Website uses cookies to register User patterns. In case a Website User does not want to accept these cookies, he must configure his browser so as to have the option of accepting cookies or rejecting unwanted ones. The Website will also be able to use cookies, logs and tag analysis tools.
4.2. Bricksave (Diversified Real Estate Asset Management Ltd.)’s Website may have links to other internet websites that neither belong to nor are controlled by Bricksave (Diversified Real Estate Asset Management Ltd.). Consequently, Bricksave (Diversified Real Estate Asset Management Ltd.) will not be held responsible for any actions of those internet websites, to which this Privacy Policy does not apply. Bricksave (Diversified Real Estate Asset Management Ltd.) recommends attentively examining the privacy policies of such internet websites to understand their procedures for collection, use and disclosure of personal data.
4.3. The provisions of the Privacy Policy will comprehend all users of the Website, whether they are registered Users or not.
5. Due to the fact that under age individuals (under 18 years) may not fully understand the Privacy Policy and its implications, nor make valid decisions about the options available to Users, the Users must, in their respective Privacy Policies, respect the corresponding regulations applicable to minors and also encourage all parents or substitutes, tutors or adults supervising those minors who surf internet websites, to active and carefully participate in the activities the minors perform while they are online, in the services used by them, in the information they access to, whether when visiting the Users’ websites or those of third parties, and guide them and teach them how to protect their own personal data while surfing the net.
6. The information provided by the Users to Bricksave (Diversified Real Estate Asset Management Ltd.) and that collected directly by Bricksave (Diversified Real Estate Asset Management Ltd.) may be transferred between different ad servers or other internet sites such as search engines and others that may be based in different countries, with different legislations regarding data protection. The use of the Services implies the Users’ authorization of the international transference of information provided by the Users to Bricksave (Diversified Real Estate Asset Management Ltd.) and that which Bricksave (Diversified Real Estate Asset Management Ltd.) collects directly or on their behalf.
7. Bricksave (Diversified Real Estate Asset Management Ltd.) has adopted reasonable security measures to protect the Users’ information and to prevent unauthorized access to their data or any unauthorized modification, dissemination or destruction of that data. The information collected by Bricksave (Diversified Real Estate Asset Management Ltd.) will be kept in strict confidence. Access to personal data is restricted to those employees, contractors, representatives and agents of Bricksave (Diversified Real Estate Asset Management Ltd.) that need to know said data in order to carry out their functions and develop or enhance the Services. Bricksave (Diversified Real Estate Asset Management Ltd.) requires from its suppliers the same confidentiality standards each time they provide Bricksave (Diversified Real Estate Asset Management Ltd.) with services related to the Users’ information. Bricksave (Diversified Real Estate Asset Management Ltd.) does not disclose this information to third parties outside Bricksave (Diversified Real Estate Asset Management Ltd.)., unless expressly requested to do so by the User. Payment transactions are always encrypted.
7.1. Notwithstanding the foregoing, and considering the internet is an open system with public access, Bricksave (Diversified Real Estate Asset Management Ltd.) cannot guarantee that unauthorized third parties might eventually cross over security barriers and misuse the Users’ information, in which case, Bricksave (Diversified Real Estate Asset Management Ltd.) shall not be liable and any data transmitted by Users is at their own risk.
8. Bricksave (Diversified Real Estate Asset Management Ltd.) reserves the right to transfer the information collected in case of sale or merger of Bricksave (Diversified Real Estate Asset Management Ltd.), or of an acquisition of the main assets of Bricksave (Diversified Real Estate Asset Management Ltd.) related to the business for which that information was collected, or with any other kind of transference of Bricksave (Diversified Real Estate Asset Management Ltd.) to another entity. In that case, Bricksave (Diversified Real Estate Asset Management Ltd.) must take all reasonable measures to ensure that the information will be used in a way that is consistent with the Privacy Policy.
9. Most internet browsers are configured to accept cookies, but the Users may reconfigure their own browser to reject all cookies or to have the system show a notice when one is received. However, if cookies are disabled, it is possible that some characteristics and services of internet websites may not function correctly.
10. Bricksave (Diversified Real Estate Asset Management Ltd.) will try by all possible means to facilitate access to personal data to Users from whom it has collected or stored personal information (“Right of Access”), as well as the possibility of rectification, modification or update of the mentioned data (“Right of Rectification”), or even their cancellation (“Right of Removal”), unless Bricksave (Diversified Real Estate Asset Management Ltd.) denies a request in case it is obliged or has the right to keep that personal data in accordance with applicable legislation.
a) For this purpose, the User must send a request by email with the subject “Access to Personal Data” to [email protected]. Bricksave (Diversified Real Estate Asset Management Ltd.) may require the User to prove his identity, which may be verified by Bricksave (Diversified Real Estate Asset Management Ltd.), and to specify the personal data he wants to access, rectify or remove.
b) Bricksave (Diversified Real Estate Asset Management Ltd.) may reject the requests that are unreasonably repetitive or systematic, that require a disproportionated technical effort, that jeopardize the privacy of other Users, or are considered impractical, or for which access to data is unnecessary.
c) Access, rectification and removal of personal data service will be provided by Bricksave (Diversified Real Estate Asset Management Ltd.) free of charge, unless it requires an inordinate or non reasonable effort, in which case an administration fee may be charged.
11. Regardless of any other provision against the Privacy Policy, Bricksave (Diversified Real Estate Asset Management Ltd.) will be able to disclose certain personal information of Users, when in good faith, it believes this disclosure is reasonably necessary to: a) avoid a legal liability; b) comply with a legal request such as a search warrant, a court order, a subpoena; c) comply with the request of a government or regulatory authority; d) protect the rights, property or security of Bricksave (Diversified Real Estate Asset Management Ltd.), the Users, or a third party.
12. Bricksave (Diversified Real Estate Asset Management Ltd.) is allowed to use and uses third party services and is not responsible for the information they collect or for the way they protect personal data. Each of these services has its own Privacy Policy and in certain cases, they provide an opt-out method to Users. Among them are the following:
http://www.google.com/privacy.html
https://wise.com/gb/legal/global-privacy-policy-en
https://www.metamap.com/global-privacy-policy/
https://aws.amazon.com/privacy/
13. Bricksave (Diversified Real Estate Asset Management Ltd.) will be able to modify the present Privacy Policy in case it is considered necessary. If the changes related to the treatment of personal data collected in relation with the Services are substantial, they will also be communicated by a prominent notice posted on the Website’s Homepage. If the User wants to be notified via email of any changes, he must send an email to [email protected] with “List of Changes in Privacy Policy” as Subject, from the email address where he wants to receive the mentioned information.
14. If the User is in doubt regarding the Privacy Policy, or its application, he must contact Bricksave (Diversified Real Estate Asset Management Ltd.) at any time, via email, to [email protected]
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