Privacy Policy

This privacy policy ("Privacy Policy") forms an integral part of FB Funds ApS, CVR no. 40431934 ("Fundbricks") Terms of Use and concerns the processing of personal data in the company. The Privacy Policy describes how Fundbricks collects, processes and protects your personal data. It applies from the time it is published on fundbricks.com. Updates to the Privacy Policy will be published on fundbricks.com and Investors will be notified by email in the event of major changes to the Privacy Policy.

Personal data means any information that can directly or indirectly help to identify a natural person, but not information that is anonymized or aggregated in such a way that it cannot (even with the help of other information) identify a specific natural person.

The definitions used in the Privacy Policy have the same meaning as in the Terms of Use, unless the context indicates otherwise.

1. Data controller

Fundbricks is the data controller and thus responsible for the processing of personal data that takes place via the Platform and within the framework of the services provided for in the Terms of Use and is responsible for ensuring that the processing takes place in accordance with the principles set out in the Privacy Policy

2. What personal data does Fundbricks process

When you create an account via Fundbricks platforms and accept the Terms of Use, you agree to share some of your personal information with FundBricks and thereby authorize the information to be transferred and stored on our servers in Denmark or in other countries within or outside the EU/EEA.

2.1 Information provided by the Investor to Fundbricks

Fundbricks collects and stores the information provided in connection with registration on the Platform and which you provide when using the Platform, such as when making an Investment or using other services or tools that Fundbricks makes available or which may be made available. The information includes, for example, the following:

• Information provided to Fundbricks when registering as a user on the Platform, consisting of e-mail address and, in certain cases, telephone or mobile phone number, first and last name.
• If an Investment is made through the Platform, information is provided on your social security number, financial information in the form of bank account number and, if applicable, your registered address
• Information on your use of the Platform, including information on completed or canceled reservations, completion of Investments and other activities that can be attributed to your account on the Platform
• Information on whether you have made payment for Investments made and what payments you have received in the form of distribution, amortization, interest or repayment of an Investment
• Documentation necessary for Fundbricks to comply with its anti-money laundering and terrorist financing prevention measures. For example, you may be required to confirm your registered address, verify your identity and answer questions through Fundbricks' "know-your-customer" form.
• Documentation that Fundbricks otherwise requests in the event that doubts arise as to whether the Terms of Use are being complied with.

2.2 Information that Fundbricks collects automatically

When you use the Platform, other services provided by Fundbricks, click on links in newsletters from Fundbricks or on the Platform, information is automatically collected and sent from your computer, mobile phone or other device used to make use of the Platform. The information can only be attributed to the specific Investor if the Platform is used by a registered Investor. The information consists of connection information, statistics on page views, IP address, traffic to and from the Platform, advertising information, URL and standard information from weblogs.

2.3 Information obtained from third parties

Fundbricks may need to obtain additional information about you from third parties, such as data providers, and add this to the information that Fundbricks processes about you. The information may include credit information, information from courts or authorities. Information is only collected to the extent that it is permitted under applicable law.

3. Use of personal data

3.1 Purpose of the processing

Fundbricks processes your personal data for the purpose of providing you with access to the Platform, managing the daily business needs, for monitoring and analysis purposes, to offer you the opportunity to use Fundbricks services and tools, to provide you with customer service and allow you to receive relevant information from Fundbricks, including offers of new Investments and for marketing purposes. The lawful basis for Fundbricks' processing of your personal data is Fundbricks' legitimate interest and to enable Fundbricks to fulfill the agreement that the Terms of Use constitute between Fundbricks and the Investor, and the agreement - in the event that an Investment is made - under which Fundbricks acts as a management agent, to fulfill the agreement with the Real Estate Companies offering Investments and to fulfill legal obligations.

By accepting Fundbricks' Terms of Use, and thus the Privacy Policy, you authorize Fundbricks to process your personal data for the following purposes:

• Provide Investor access to the Platform, provide customer service, provide information about Investor's account, manage Investor's membership in the Investor Network, enable the implementation of Investments and otherwise provide access to the tools and services that Fundbricks offers or may offer.
• Sending information about the Investments marketed on the Platform, relevant information about previous Investments, informing about updates of the Platform, the Terms of Use and Privacy Policy or Fundbrick's services
• To manage, maintain, develop and secure the technical functionality of the Platform in order to provide you with a safe and efficient experience of the Platform and its associated services
• To monitor that the Platform is not used in violation of the Terms of Use and to protect the rights of Fundbricks or others under the Terms of Use, e.g. to prevent, detect and investigate security incidents, potentially prohibited or other illegal activities.
• Use cookies or other tracking technologies to provide the Services and/or work with other third parties such as advertising or analytics companies to provide the Services.
• Market FundBrick's products and services or the products of FundBrick's selected partners in the real estate industry and offer information about the web platforms and/or services of FundBrick's group companies, if any, by e-mail or otherwise.
• Conducting statistics, market and customer analysis, and general business and methodology development
• Enable the financing or transfer of all or part of Fundbricks or its business
• Carry out checks against EU sanctions lists, UN sanctions lists, PEP lists, etc. and fulfill other obligations arising from laws, regulations or internal rules.

4. Termination of our processing of personal data

If you do not wish to receive offers of Investments or marketing from Fundbricks, you can contact Fundbricks at hello@fundbricks.com and object to the processing. If you withdraw your consent to the processing of personal data or the publication of the information for the purposes specified in the Privacy Policy, it may result in Fundbricks not being able to provide you with access to the Platform, the services or the customer service that Fundbricks offers in accordance with this Privacy Policy and the Terms of Use.

5. Disclosure of personal data

Fundbricks does not sell or disclose your personal data to third parties for marketing purposes (exercising what is stated in point 3 above) without your explicit consent. Fundbricks discloses your personal information to fulfill legal obligations and maintain adopted policies. Your personal data will only be disclosed in accordance with applicable laws and regulations.

In order to fulfill its obligations under the Terms of Use and for the purposes described above in section 3, Fundbricks may share your personal data with

• Any future affiliates of Fundbricks for the purpose of providing the same content and services, to detect and prevent violations of Fundbricks' policies, to provide guidance on the affiliates' products, websites, tools or services, and to comply with applicable laws.
• Subcontractors that Fundbricks uses to operate the business, including, but not limited to IT suppliers, cloud service providers, any loan agents representing the Investor in an Investment, payment institutions or other companies for handling incoming and outgoing payments in connection with Investments, sending updates about ongoing Investments, or other mailings to the Investor and for the operation of the Platform.
• Regulatory authorities, law enforcement authorities, other governmental authorities or appropriate third parties, in connection with answering questions and investigating potential criminal offenses, or other activities that may result in liability for Fundbricks or you. To the extent permitted by applicable law, Fundbricks will disclose information that is relevant and necessary for any investigation, such as, for example, name, social security number, e-mail address and IP address.
• Information about the Investor to other Investors/potentially other company if Fundbricks is to be sold to or merged with such company.

If your personal data will be used or disclosed for purposes other than those set out in the Privacy Policy, Fundbricks will inform you of this.

6. cookies etc.

When you visit or use the Platform or other tools or services, such as e.g. email, FundBricks and its suppliers may use cookies, web beacons and similar technology to store information in order to create a faster and safer experience for you. For more information on what cookies Fundbricks uses, please see Fundbricks cookie policy, which you can find here: https://www.fundbricks.com/legal/cookies

7. Access, review and amendment of personal data

Your password is the key to your account and should consist of unique numbers, letters and symbols. You must not disclose your password to any outside party. You are responsible for all activity that occurs through your account and must inform Fundbricks immediately if your password has fallen into the wrong hands or if you have reasonable grounds to suspect this.

You can review and change certain personal data in the account settings on the Platform and must update as soon as possible, or alternatively notify Fundbricks customer service that your personal data needs to be changed or is incorrect. FundBricks will then fulfill the rights you have under the law in relation to the possibility to request correction or deletion of your personal data.

8. Transfer of personal data to third countries

Fundbricks stores and processes your personal data on FundBricks servers in Denmark and in other countries within or outside the EU/EEA. FundBricks undertakes to provide adequate protection when your personal data is transferred to third countries outside the EU. You agree that your personal data may be processed and transferred to a country outside the EEA.

Fundbricks uses physical, technical and organizational security measures that are appropriate to the amount and sensitivity of the personal data processed, in order to prevent unauthorized processing, including but not limited to unauthorized access, acquisition and use of, or loss, erasure or other damage to your personal data. Some examples of security measures used by FundBricks are encryption and anonymization of data, as well as requiring identification to access personal data.

9. Termination of your account and retention of personal data

Upon your request, Fundbricks may close your account and, as soon as possible, delete your personal data. The deletion of data is done in accordance with applicable law. Fundbricks may also close user accounts that are used in violation of the Terms of Use.

Personal data attributable to a closed account will usually be deleted or anonymized after the account has been closed. However, Fundbricks may need to retain personal data attributable to closed or inactive accounts in the following cases:

• Fundbricks has a legitimate business interest and it is not prohibited by law
• If the Investor has invested in a Real Estate Investment which has not been repaid and the information is necessary to complete the repayment to the Investor.
• handling disputes and/or ensuring compliance with the Fundbricks Terms of Use
• If Fundbricks is required by law to store the personal data, e.g. for compliance with anti-money laundering legislation.
• In order to take other measures permitted by law

Whatever the circumstances, your personal data will be handled securely and only for as long as necessary to fulfill any of the purposes described in the Privacy Policy

10. Your rights

10.1 The right of access

You are entitled at any time to request information about, among other things, what information we have registered about you, what purpose the registration serves, what categories of personal data and recipients of information there may be, as well as information about where the information originates.

You have the right to receive a copy of the personal data we process about you. If you would like a copy of your personal data, please send a written request to hello@fundbricks.com. You may be asked to provide proof that you are who you say you are.

10.2 The right to rectification

You have the right to have inaccurate personal data about yourself rectified by us. If you become aware that there is an error in the information we hold about you, you are encouraged to contact us in writing so that the information can be corrected.

Information that we have collected in connection with your registration on the Platform can be corrected by you via the log-in to your user profile.

10.3 The right to erasure

In certain cases, you have the right to have all or some of your personal data erased by us, for example if you withdraw your consent and we have no other legal basis to continue processing. To the extent that continued processing of your data is necessary, e.g. for compliance with our legal obligations or for the establishment, exercise or defense of legal claims, we are not obliged to erase your personal data.

10.4 The right to restrict processing to storage

In certain cases, you have the right to restrict the processing of your personal data to storage only, for example if you believe that the data we process about you is inaccurate.

10.5 The right to data portability

In certain cases, you have the right to receive personal data that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit this data to another controller.

10.6 The right to object

You have the right to object at any time to our processing of your personal data for direct marketing purposes, including the profiling carried out to target our direct marketing.

You also have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data carried out by us on the basis of our legitimate interests.

10.7 The right to withdraw consent

You have the right to withdraw at any time any consent you have given us for a given processing of personal data. If you wish to withdraw your consent, please contact us at hello@fundbricks.com.

11. Contact details

If you have any questions or want to know more about what personal data we process about you, you can contact us at hello@fundbricks.com. If you want to complain about FundBrick's processing of your personal data, you can complain to the Danish Data Protection Agency. You can find the Data Inspectorate's contact information at https://www.datatilsynet.dk

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