PRIVACY POLICY
Version Date: October 17, 2025
Introduction
We are RealFi Foundation (referred to as “RealFi”, “we”, “us” or “our”) and we are committed to protecting our stakeholders' and customers' personal data in accordance with applicable data protection laws."Personal data" means any data about an individual who can be identified from that data, as more specifically defined under applicable data protection laws.Our privacy policy ("Privacy Policy") describes how we collect, use, store and protect personal data. The Privacy Policy also describes how you can control the personal data that we hold on you, and your rights on your personal data, where applicable.We may from time to time update the Privacy Policy to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Such changes will be published here and effective upon publication. Please check the Privacy Policy regularly for an updated version. Your continued access and/or use of our website, our mobile application, our products and/or our services will constitute your agreement to the Privacy Policy and any revisions thereto.
Information that we collect from you
We collect, use, store and transfer different kinds of personal data about you, including but not limited to the following:
(a) Identity and contact data, which includes your name, passport or other unique identification number, telephone number, mailing address, email address, images of your passport or identification document, and your likeness (including selfies and biometric information).
(b) Financial data, which includes information about your financial position, status and history, and payment account details (such as bank or other payment details).
(c) Transaction data, which includes details about fiat currency transfers, as well as issuance, transfer, and recording activities in respect of tokens to, from and amongst your accounts with us.
(d) Technical data, which includes internet protocol (IP) address, your login data, and other technology on the devices you use to access our website, products and/or services.
(e) Usage data, which includes information about how you use our website, products and/or services, including cookies, IP address, and account details.
(f) Blockchain data, which includes blockchain addresses, public keys and related transaction information.
How we collect information from you
We collect personal data from you in various ways, including but not limited to the following:
when you access and/or use our websites or mobile applications.
when you submit forms relating to our website, mobile application and/or any of our products or services.
when you register as a member of channels owned and/or operated by us, or use services on such channels.
when you interact with our personnel such as customer service officers.
when you request that we contact you.
when you ask to be included in an email or other mailing list.
when you respond to our promotions and other initiatives.
when we receive references from business partners and third parties, for example, where you have been referred by them.
when you submit personal data to us for any other reason.
Purposes for the Collection, Use and Disclosure of Personal Data
Generally, RealFi collects, uses and/or discloses personal data, and you consent to such collection, use and/or disclosure by RealFi, for the following purposes:
to provide products and services to you.
to communicate with you on matters relevant to your relationship with or interest in us.
to assess and improve the products and services that you use or may use.
to selectively send you information about our products, services, activities and/or events that may be relevant to you.
to fulfil the contractual/legal obligations under the contracts or other legal arrangements entered into between us and you.
to protect and enforce our contractual and legal rights and obligations.
to verify your identity.
to prevent, detect and investigate crime, including fraud, money-laundering, and terrorist financing, and analyse and manage other commercial risks.
to conduct audits, reviews and analysis of our internal processes and for action planning.
to comply with any applicable rules, laws and regulations (including any laws and regulations relating to anti-money laundering, countering the financing of terrorism, and tax reporting obligations), codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities anywhere in the world.
to provide such personal data to issuers on our platform and/or their financial intermediaries (where applicable) to allow them to comply with any applicable rules, laws and regulations.
any other purpose relating to any of the above.
We may share personal data with our regulators, related corporations, services providers, agents and other third parties for the purposes set out above, for legal reasons, or where permitted under applicable laws, such as in response to law enforcement agencies. If we transfer personal data to countries outside of where the personal data is collected, it will be done in accordance with the relevant laws and regulations.
Marketing Communications
It is in our legitimate interests to process personal data to selectively contact you and/or send you information about our products, services, activities and/or events that may be relevant to you (“Marketing Communications”). You may opt-out of receiving Marketing Communications by using the unsubscribe link contained in the relevant email, or by contacting us at [email protected]. To the extent that our processing of your personal data for Marketing Communications is subject to the European General Data Protection Regulation, you have the right to object to such processing by us.
Cookies
When you browse our websites or use our mobile applications, we use cookies to store information about how you use these websites or mobile applications in order to improve the quality of service provided to you. To understand what type of cookies we use and how these work when you use our websites, please refer to our Cookie Policy.
Retention of personal data
We retain personal data about you for as long as is necessary for the purposes for which such personal data was collected, and take reasonable measures to destroy any personal data that is no longer necessary to meet those purposes.
Security measures
All personal data is kept confidential and we take all reasonable measures to protect it from unauthorised or accidental access, processing or loss, by implementing appropriate physical, electronic and supervisory controls.
How you can control your information
If you do not want us to contact you via electronic messaging - You may select the "unsubscribe" option in all our electronic communications with you.
If you want to be removed from our customer database - You may email us at [email protected].
If you believe we have inaccurate information about you and you want to correct such data - You may email us at [email protected].
If you wish to know what personal data we have on you and how it has been used - You may email us at [email protected].
It is important to note that we use personal data to provide you with the products and services you wish to use. We also comply with various regulatory requirements in doing so, including for customer due diligence. Withdrawal of consent for RealFi to collect, use or disclose personal data means that we may need to stop these activities, and the absence of certain key personal data may cause us to be unable to continue providing the relevant products and services to you.
Your rights regarding your personal data
Under applicable data protection laws (such as the European General Data Protection Regulation), you may have the following rights:
access to your personal data;
rectification of your personal data;
erasure of your personal data;
restrict processing of your personal data;
object to processing (including object to receiving marketing) of your personal data;
data portability; and
lodge a complaint with a supervisory authority.
If you wish to exercise these rights, or have any questions about these rights, you may email us at [email protected]. We may charge a fee for processing your request for access, depending on the nature and complexity of your request.
Contacting us
If you have any questions about this Privacy Policy, or our handling of your personal data, please email our Data Protection Officer at [email protected].
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