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Privacy Policy

Last updated 18 August 2026

How personal information is collected, used, shared and protected when you use the CREAssets platform — whether as a sponsor administering an investment programme or as an investor invited to one.

To be completed by counsel

The factual sections below describe what this software actually does with personal information. The statutory sections — legal basis, individual rights, retention periods, international transfer mechanism and the identity of the controller — must be completed and the whole reviewed by counsel before this policy is presented as binding.

Nothing here claims a certification, a privacy framework membership or an adequacy decision. Do not add one that does not exist.

Contents

  1. Scope and roles
  2. Information collected
  3. Where it comes from
  4. How it is used
  5. Legal basis
  6. Who it is shared with
  7. Information investors share with sponsors
  8. How long it is kept
  9. Security
  10. Your rights and choices
  11. Communications
  12. Cookies and tracking
  13. International transfers
  14. Children
  15. Google user data
  16. Changes to this policy
  17. Contact

1. Scope and roles

This policy covers personal information handled through the CREAssets platform and the operator’s website.

Two roles matter throughout. For information a sponsor loads into its own workspace — its investors, their contact details, their subscription and KYC records — the sponsor decides what is collected and why, and the operator handles it on the sponsor’s instructions. For account and billing information, and for the operation and security of the platform itself, the operator decides.

To be completed by counsel

Name the controller and processor for each role in the jurisdictions served (GDPR/UK GDPR controller vs processor; CCPA/CPRA business vs service provider), and state whether a data processing addendum is offered and where it can be found.

2. Information collected

The platform collects the following categories.

  • Account information — name, email address, password credentials (stored hashed), profile photo, two-factor authentication secrets and recovery codes (stored encrypted), and the organisation and role you belong to.
  • Investor profile information — name, contact details, mailing address, investment entity details, and the tax identification numbers required for tax reporting.
  • Verification information — identity verification (KYC) records and accreditation or qualification evidence, including documents you or a sponsor upload and the status returned by a verification provider.
  • Financial information — commitments, contributions, capital-call obligations, distributions, capital-account balances, and connected bank account details. Bank credentials themselves are entered with the bank-verification provider and are not received by the platform.
  • Documents — subscription agreements, signed documents and signature audit trails, K-1s and other tax forms, and any file uploaded to a deal, data room or investor record.
  • Communications — messages, notices and emails sent through the platform, delivery and open status where tracking is enabled, and support correspondence.
  • Usage and device information — log-in events, IP address, browser and device type, pages and documents viewed (including data-room view logs shown to the sponsor), and audit-log entries recording significant actions.

3. Where it comes from

Directly from you; from a sponsor who invites you or maintains your investor record; from verification, bank, payment and e-signature providers acting on an instruction; and automatically from your use of the platform.

4. How it is used

  • to provide the platform and the features you or a sponsor use;
  • to run investor onboarding, verification, subscription, capital-call and distribution workflows;
  • to produce statements, notices, reports and tax documents, and to deliver them;
  • to authenticate users, prevent fraud and unauthorised access, and maintain the audit trail;
  • to provide support, and to send service and transactional messages;
  • to meet legal, tax, anti-money-laundering and record-keeping obligations;
  • to maintain, secure and improve the platform, including diagnosing faults.

Personal information is not sold. It is not used to advertise to a sponsor’s investors.

To be completed by counsel

If aggregated or de-identified data is used for product analytics or benchmarking, say so explicitly here and describe the de-identification standard. Silence on this point is the most common gap in a policy of this kind.

5. Legal basis

To be completed by counsel

Counsel must map each purpose in section 4 to a lawful basis for jurisdictions requiring one (contract, legal obligation, legitimate interests, consent), and record the legitimate-interests assessments.

6. Who it is shared with

  • The sponsor whose programme you invest in, and its authorised users, including any co-sponsor granted access — subject to the access boundaries the sponsor configures.
  • Service providers acting on instructions: cloud hosting and storage, email delivery, identity and accreditation verification, bank verification, payment providers, e-signature, and error monitoring.
  • Integrations you connect, such as accounting exports or automation tools, which receive the data those integrations carry.
  • Professional advisers, auditors and authorities where required by law or legal process.
  • A successor in a merger, acquisition or sale of assets, subject to this policy.

To be completed by counsel

Publish the current sub-processor list (or link to it), state how changes are notified, and confirm each provider is under a written data-processing agreement.

7. Information investors share with sponsors

If you are an investor, the sponsor who invited you controls your investor record. Questions about why particular information was requested, how long the sponsor keeps it, or requests to correct or delete it should go to that sponsor in the first instance. The operator will assist a sponsor in responding.

8. How long it is kept

Information is kept for as long as an account or investor record is active, and afterwards for the periods required by tax, securities and anti-money-laundering law and for the resolution of disputes. Audit-log entries and completed signature records are retained as evidence of what occurred.

To be completed by counsel

Insert the specific retention periods per category.

This note previously said to reconcile them with “the export window and deletion timetable in section 14 of the Terms of Service”. There is no longer any such window or timetable — that clause was removed on 2026-08-25 because nobody could perform it (owner decision, Q-40; the reasoning is in the CounselNote at Terms section 14). So there is currently nothing to reconcile against, and this note is not waiting on the Terms.

When a data-return clause is eventually drafted, the reconciliation duty returns and the two documents must not give different numbers.

9. Security

Safeguards include encryption of data in transit, encryption at rest of two-factor secrets, hashed password and recovery-code storage, role-based access control scoped to a single organisation’s workspace, optional and enforceable two-factor authentication, and an audit log of significant actions.

No system is completely secure. Choose a strong, unique password, enable two-factor authentication, and tell us promptly about any suspected unauthorised access.

To be completed by counsel

Add the breach notification commitment — who is told, within what period, and by what means — required by applicable law and customer contracts. Do not name a certification (SOC 2, ISO 27001) unless it has been obtained; if it has, give its scope and date.

10. Your rights and choices

You can review and update your account details in the platform, control your notification preferences, and export data available to you through the platform’s export features.

To be completed by counsel

Counsel must set out the statutory rights that apply (access, correction, deletion, portability, restriction, objection, opt-out of sale/sharing, non-discrimination), how a request is made and verified, the response deadline, and the appeal or complaint route including the relevant supervisory authority.

11. Communications

Transactional and service messages — capital-call notices, distribution notices, security alerts, document availability — are part of the service and are sent while your account or investor record is active. Marketing messages from a sponsor can be declined at any time using the preference controls or the unsubscribe link in the message.

12. Cookies and tracking

The platform uses cookies that are necessary for it to work, including maintaining your signed-in session and protecting against cross-site request forgery.

To be completed by counsel

Enumerate every cookie and similar technology actually set — including any analytics or email open/click tracking — with its purpose and lifetime, and state whether a consent banner is required in the jurisdictions served.

13. International transfers

To be completed by counsel

State where data is hosted and processed, which providers process it outside that region, and the transfer mechanism relied on (standard contractual clauses, adequacy, or another). Do not assert a framework certification the operator does not hold.

14. Children

The platform is intended for business and investment use by adults. It is not directed to children and does not knowingly collect their personal information.

15. Google user data

You can sign in with Google, and a sponsor can connect a Google account so the platform can send email as that account, keep the sponsor’s investor conversations in step with their mailbox, and read calendar availability to book meetings. Signing in uses only your name, email address and profile picture. A connected account additionally grants the Gmail and Calendar permissions shown on Google’s consent screen, and nothing else.

Information received from Google APIs is used only to provide those features to the person who connected the account. It is not sold, not used for advertising, not used to train artificial intelligence models, and not transferred to anyone except as needed to provide the feature, to comply with law, or with your consent. People do not read it except with your permission, for security, or as the law requires. Disconnecting the account in the platform, or revoking access at myaccount.google.com, stops further access.

CREAssets’ use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

16. Changes to this policy

This policy may be updated. Material changes will be notified in the platform or by email before they take effect, and the “last updated” date above will change.

17. Contact

Privacy questions should be sent to the operator using the contact details published on the operator’s website. Investors should contact the sponsor who maintains their investor record for questions about that record; see the Terms of Service for how the two relationships differ.

To be completed by counsel

Insert the privacy contact address, the data protection officer or EU/ UK representative where one is required, and the postal address for written requests.