Noblelesse - Fractional Real Estate Investment

1. Who we are

Noblelesse ("Noblelesse", "we", "us", "our") operates a technology marketplace that enables users to discover and subscribe to fractional real-estate opportunities (the "Platform"). For most activities described below, Noblelesse is the data controller of your personal data. Some processing is carried out by our service providers as processors (e.g., KYC, payments, escrow, analytics).

This Policy explains what we collect, why we collect it, how we use it, with whom we share it, how long we keep it, and the rights you have.

This Privacy Policy is read together with our Terms & Conditions, Cookie Notice, and any property Offering Documents. If there is a conflict about the handling of personal data, this Privacy Policy prevails (unless an Offering Document is more specific and lawful).

2. What we collect

2.1 Data you provide to us

Identity & profile: full name, date of birth, nationality, contact details, residential address, username.
KYC/AML: passport/ID, proof of address, source-of-funds/wealth information, bank statements (where required), sanctions/PEP screening results.
Financial & transactions: payments you make/receive, selected currency, funded deals, payout preferences.
Communications & support: emails, calls, chat messages, support tickets, survey responses; we may record/monitor some communications where permitted by law to ensure compliance and quality.
Marketing preferences: subscriptions, opt-ins/opt-outs.

2.2 Data collected automatically

Device & usage: IP address, device identifiers, OS/browser type/version, language, time zone, clickstream, pages viewed, session duration, referral URLs, performance metrics; collected via cookies, SDKs and similar technologies (see Section 9 – Cookies).

2.3 Data from third parties

Verification/KYC providers (identity checks, sanctions/PEP screening)
Payment and escrow partners (funding, settlements, chargebacks)
Analytics & fraud-prevention vendors (abuse prevention, product analytics)
Open sources/regulators (sanctions, court orders)

We do not intentionally collect sensitive categories (e.g., health, religion), except where such data appears incidentally on KYC documents and is processed only for verification or compliance.

3. Why we use your data (purposes & legal bases)

We process personal data only where we have a lawful basis under applicable law (Qatar Financial Centre Data Protection Regulations):

Contract: to register your account, process your funding/payouts, provide Platform functionality, and service your investments.

Legal obligation: to perform KYC/AML/CTF, verify identity, respond to lawful requests, maintain statutory records.

Legitimate interests:

• Platform safety, fraud prevention, and secure access

• Product analytics and service improvement

• Non-intrusive marketing about Platform features (with opt-out at any time)

Consent (where required): certain marketing communications, cookies/SDK categories, or optional features; you can withdraw consent any time.

Automated decisions/profiling

We use analytics and automated checks to protect the Platform and meet compliance duties. Where an automated decision produces legal or similarly significant effects, you may request human review (subject to law).

8. Your privacy rights

Depending on where you live (QFC DPR and other laws), you may have the right to:

Access your data

Rectify inaccurate or incomplete data

Erase data (subject to legal holds)

Restrict processing

Object to processing (including certain marketing)

Portability (receive certain data in a portable format)

Withdraw consent at any time (where processing is based on consent)

Not be subject to certain automated decisions

We will respond within the timelines set by applicable law. To exercise rights, see Section 16 – Contact us.

14. QFC disclosures

Noblelesse is a company registered in the Qatar Financial Centre (QFC) and complies with the QFC Data Protection Regulations (DPR), as amended in 2021, and the QFC Data Protection Rules.

We process your personal data in accordance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality, as set out in the QFC DPR.

International transfers of personal data are carried out with appropriate safeguards as described in Section 5.

Privacy Policy