1. Introduction & Scope
This Privacy Policy applies to the Fractur platform, marketplace, referral tools, API integrations, and all associated services provided by Fractur Technologies LTD ("Fractur", "we", "our", or "us").
As a provider of real-world asset infrastructure, we are committed to data protection across asset-owner onboarding, issuance records, partner integrations and asset-servicing workflows.
2. Data We Collect
To facilitate secure, legally compliant asset tokenisation, Fractur collects specific categories of data during the onboarding, verification, and asset lifecycle phases.
2.1 Developer, Broker & Partner Data
- Corporate entity documents, RERA licence details where applicable, ultimate beneficial ownership (UBO) structures, and SPV registration details.
- Real estate asset documentation, including Land Registry title deeds, valuations, and yield historicals.
- Authorised signatory identity data, referral attribution records, and payout information required for KYB, broker onboarding, and partner workflows.
2.2 Authorised User & Holder Data
- Personal identification data required for Anti-Money Laundering (AML) and Know Your Customer (KYC) clearance.
- Wallet addresses (e.g., ERC-20 compatible addresses) used for holding and interacting with digital asset units.
- Source of funds declarations and accreditation status verification.
3. Blockchain & Immutable Data
Note on Blockchain Permanence: Due to the inherent nature of Distributed Ledger Technology (DLT), certain transactional data published to the blockchain cannot be deleted or altered.
Fractur uses digital records and permissioned workflows to support the rights defined by each product. While we strive to keep personal data off-chain, the following information will be permanently recorded on public or consortium ledgers:
- Cryptographic wallet addresses (which are pseudonymous).
- Transaction timestamps, token transfer amounts, and contract execution hashes.
- On-chain identity registry hashes (which do not expose raw personal data, but verify whitelist status).
4. How We Use Your Data
We process your information strictly for the execution of our platform services and compliance mandates:
- Legal Structuring: To coordinate compliant SPVs and property-level documentation.
- Regulatory Compliance: To perform KYC/AML gating, wallet screening, and jurisdictional sanctions controls.
- Asset Lifecycle Management: To facilitate distributions, asset-owner reporting, holder records and permitted-transfer workflows.
- Security Auditing: To monitor platform integrity and prevent unauthorised access attempts.
5. Third-Party Disclosures
To execute these services, limited data sharing with trusted third-party regulated partners is required:
- Legal Counsel & Registries: Data required to file SPVs and synchronise with entities such as the Dubai Land Department (DLD) or equivalent bodies.
- KYC/AML Providers: Tier-1 identity verification vendors who process compliance checks on our behalf.
- Licensed Partners: Authorised identity, custody, banking and payment partners involved in the relevant product workflows.
We do not sell, rent, or trade your personal, broker, partner, or property data to marketing agencies or unauthorised data brokers.
6. Security & Infrastructure
Our platform architecture is designed to meet strict safeguards for asset-owner, authorised user, holder and partner data. We implement robust technical measures including:
- Protection of data in transit and at rest.
- Strict role-based access control (RBAC) for internal system administration.
- Security reviews and independent testing as part of the applicable operating programme.
7. User & Partner Rights
Depending on your jurisdiction, you maintain specific rights regarding your off-chain data, including:
- The right to access and export a copy of your verified data.
- The right to request rectification of inaccurate corporate or personal records.
- The right to request deletion of off-chain data (subject to mandatory AML/KYC data retention laws, typically 5-10 years).
8. Contact Compliance
For data privacy inquiries, deletion requests, or questions regarding our Web3 compliance architecture, please contact our legal team directly.