Effective Date: 15.12.2024
RealHub Marketplace Ltd ("RealHub," "we," "us," or "our") is committed to protecting your privacy and complying with the General Data Protection Regulation (GDPR) and other applicable data protection laws. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website **real-hub.com** (the "Website") or use our real estate marketplace platform (the "Marketplace").
By accessing or using the Website and Marketplace, you agree to the terms of this Privacy Policy. If you do not agree, please refrain from using our services.
1. Information We Collect
We collect information directly from you, automatically through your use of the Website and Marketplace, and from third-party sources. The types of information we may collect include:
1.1 Information You Provide
- Account Registration: Name, email address, phone number, and any information required for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance.
- Transaction Details: Information related to purchases or sales of blockchain assets (BAs) on the Marketplace.
- Contact Information: When you contact us for support or inquiries, we collect the details of your communication.
1.2 Information Collected Automatically
- Device Information: IP address, browser type, operating system, and device identifiers.
- Usage Data: Pages visited, time spent on the Website, links clicked, and navigation paths.
- Cookies and Tracking Technologies: We use cookies and similar technologies to enhance your user experience and collect data.
- Google Analytics: We use Google Analytics to analyze how users interact with the Website, track user activity, and gather demographic information. Google Analytics may collect your IP address and other usage data. For more information, please refer to [Google’s Privacy Policy](https://policies.google.com/privacy).
- Blockchain Scanning Technologies: We use blockchain scanning tools, including services provided by Chainalysis, to monitor transactions for anti-fraud and AML purposes. These tools evaluate blockchain activity to detect suspicious patterns and assess whether a sender’s wallet has been involved in criminal activities, ensuring compliance with regulations and the integrity of the Marketplace.
- Location Data: Where permissible, we may collect location information from your device to provide location-based services or insights.
1.3 Information from Third Parties
- Verification data from identity verification providers.
- Financial information from payment processors.
- User activity data from third-party analytics providers.
2. Legal Basis for Processing Your Information
Under GDPR, we process your personal data based on the following legal grounds:
- Consent: When you provide your explicit consent for specific uses, such as receiving marketing emails.
- Contractual Necessity: To fulfill a contract with you, such as facilitating transactions on the Marketplace.
- Legal Obligations: To comply with applicable laws, such as KYC and AML regulations.
- Legitimate Interests: To improve our services, enhance security, and protect against fraud.
3. How We Use Your Information
We use the information collected for the following purposes:
3.1 To Provide Services
- Facilitate transactions and verify your identity.
- Process payments and manage user accounts.
3.2 To Improve the Website and Marketplace
- Analyze usage trends and optimize user experience.
- Diagnose technical issues and improve security.
- Utilize insights from Google Analytics to enhance our Website and Marketplace functionality.
3.3 For Compliance and Legal Obligations
- Comply with KYC, AML, tax, and other regulatory requirements.
- Enforce our Terms and Conditions and prevent fraud.
- Use blockchain scanning technologies, including Chainalysis, to monitor for fraudulent activity, evaluate sender wallet integrity, and ensure AML compliance.
3.4 For Communication
- Respond to user inquiries and provide support.
- Send important updates about the Marketplace or changes to policies.
3.5 For Personalization
- Customize your user experience based on your preferences and interactions.
- Provide recommendations and tailored content.
4. Sharing Your Information
We do not sell your personal information. However, we may share your information with third parties as follows:
4.1 Service Providers
We share information with vendors and service providers who perform services on our behalf, such as payment processing, identity verification, blockchain analysis, and data hosting.
4.2 Legal Compliance
We may disclose your information to comply with applicable laws, regulations, legal processes, or government requests.
4.3 Business Transfers
If we merge, sell, or transfer part or all of our business, your information may be transferred as part of that transaction.
4.4 Protection of Rights
We may disclose information to protect our rights, users, or the public, including to detect or prevent fraud.
4.5 Aggregated or Anonymized Data
We may share aggregated or anonymized information that cannot be used to identify you with third parties for research or analytical purposes.
5. Your Rights and Choices
Under GDPR, you have the following rights:
5.1 Right to Access
You have the right to access your personal data and obtain a copy of the information we hold about you.
5.2 Right to Rectification
You can request corrections to your personal data if it is inaccurate or incomplete.
5.3 Right to Erasure
You can request that we delete your personal data, subject to our compliance with legal obligations.
5.4 Right to Restriction of Processing
You can request that we limit the processing of your personal data under certain circumstances.
5.5 Right to Data Portability
You can request a copy of your personal data in a structured, commonly used, and machine-readable format.
5.6 Right to Object
You can object to the processing of your personal data for direct marketing purposes or when we rely on legitimate interests.
5.7 Right to Withdraw Consent
You can withdraw your consent at any time for processing activities that rely on your consent.
To exercise these rights, please contact us at privacy@realhub.com.
6. Data Security
We implement technical, administrative, and physical safeguards to protect your information from unauthorized access, disclosure, or misuse. While we strive to protect your data, no security system is completely foolproof. You are responsible for maintaining the security of your account credentials and wallet keys.
7. International Data Transfers
If you are located outside the United Kingdom, your information may be transferred to and processed in the United Kingdom or other countries where our servers or service providers are located. By using the Website and Marketplace, you consent to such transfers. For users in the European Economic Area (EEA), we ensure adequate protection for data transfers in compliance with GDPR.
8. Retention of Data
We retain your information as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. When your information is no longer needed, we securely delete or anonymize it.
9. Third-Party Links
Our Website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. Please review their privacy policies before providing personal information.
10. Updates to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes by posting the updated policy on our Website with the "Effective Date." Your continued use of the Website and Marketplace constitutes acceptance of the updated Privacy Policy.
11. Contact Information
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:
RealHub Marketplace Ltd
Address: Dalton House, 60 Windsor Road, Merton Abbey, London, Greater London, SW19 2RR, United Kingdom
Email: privacy@realhub.com
Company Number: 16080017