PRIVACY POLICY

1. Introduction

1.1. This Privacy Policy sets out how PropEarnly (“we”, “us”, or “our”) collects, uses, discloses, and protects your personal data when you use our platform. PropEarnly is the trading name of Diffstone Property Limited, a company incorporated in England and Wales (Company Number: 12726327) with its registered office at 14th Floor, The Plaza, Old Hall St, Liverpool, L3 9QJ, United Kingdom.

1.2. By using our services, you acknowledge and agree to the terms of this Privacy Policy. If you do not agree, please refrain from using our platform.

1.3. We are committed to protecting your privacy and ensuring compliance with applicable data protection laws, including the UK Data Protection Act 2018, UK General Data Protection Regulation (UK GDPR), and other relevant regulations. PropEarnly is the Data Controller responsible for processing your personal data. If you have any concerns about how your data is handled, you may contact our Data Protection Officer (DPO) at privacy@propearnly.com.

1.4. Who this Policy applies to

This Privacy Policy applies to:

Investors who use PropEarnly to invest in UK real estate from Africa.

Visitors to our website www.propearnly.com.

Business partners or other third parties engaging with PropEarnly.

1.5. Third-Party Links

Our website may contain links to third-party websites, services, or applications. We do not control these third-party platforms and are not responsible for their privacy policies. We encourage you to review their privacy policies separately.

1.6 We process your personal data under the following legal bases:

Performance of Contract – To provide investment services you sign up for.

Legal Obligation – To meet compliance, KYC, and AML regulations.

Legitimate Interests – To improve our platform and ensure security.

2. Collection of Users' Information

2.1. PropEarnly collects information from Users through registration forms, cookies, third-party analytics tools, and other lawful means. This includes personal details provided during registration and investment processes.

2.2. We collect the following categories of personal data:

Identity Data (e.g., full name, date of birth, nationality, government-issued ID, residency status)

Contact Data (e.g., address, email, phone number)

Financial Data (e.g., source of funds, bank account details, tax residency)

Transaction Data (e.g., investment history, payments, withdrawals)

Technical Data (e.g., IP address, browser type, device information, login activity)

Marketing and Communication Data (e.g., preferences for receiving updates, promotional material)

2.3. Where required by applicable regulations, PropEarnly may collect Know Your Customer (KYC) and Anti-Money Laundering (AML) documentation, including but not limited to, proof of identity, proof of address, credit and risk assessments, and verification of funds.

2.4 We may also collect information from:

Publicly available sources (e.g., Companies House, credit bureaus).

Partner financial institutions for transaction verification.

Law enforcement and fraud prevention databases.

3. Use of Collected Information

3.1. PropEarnly uses collected personal data to:

Provide, manage and improve the Services.

Process investment transactions.

Conduct identity verification and compliance checks.

Prevent fraud, financial crime, and unauthorised access.

Contact Users regarding platform updates and investment opportunities.

Conduct market research and enhance user experience.

3.2. We do not sell, rent, or trade Users' personal data.

3.3 We may use automated decision-making tools to assess risks, conduct AML checks, and approve transactions. You have the right to request human intervention in any decision affecting you.

4. Third-Party Data Sharing

4.1. PropEarnly may share personal data with:

Regulatory authorities and law enforcement agencies where required by law.

Third-party service providers (e.g., cloud storage providers, payment processors, fraud detection services) to enable service delivery.

Legal and financial advisers in cases of dispute resolution, regulatory compliance, or business audits.

4.2. All third parties with whom we share data are contractually bound to protect Users' data in accordance with UK and international data protection regulations.

4.3 We do not share personal data with third-party marketers without your explicit consent. You can opt-in or opt-out at any time through your account settings.

5. Data Security & Protection

5.1. We implement industry-standard security measures to protect Users' personal data from unauthorised access, alteration, disclosure, or destruction.

5.2. In the event of a data breach, affected Users will be promptly notified in accordance with legal requirements.

6. Retention of Personal Data

6.1. Personal data is retained for as long as necessary to fulfil the purposes outlined in this Privacy Policy.

6.2. Regulatory obligations may require PropEarnly to retain certain data for a minimum of six (6) years after an investment relationship ends.

6.3. If a User requests deletion of their data, PropEarnly will comply unless retention is legally required.

6.4 Dormant Accounts: If you do not access your account for 24 months, we may retain data for regulatory compliance but deactivate your account for security reasons.

7. International Data Transfers

7.1. As a platform serving African investors, PropEarnly may process data in jurisdictions outside Africa. Data transfers comply with UK GDPR and other relevant international standards.

7.2. Where data is transferred outside the United Kingdom, we ensure adequate data protection measures, such as Standard Contractual Clauses (SCCs) or similar safeguards.

7.3 y using our services, you explicitly consent to the transfer of your personal data outside the UK. You can withdraw this consent by contacting privacy@propearnly.com.

8. User Rights

Users have the right to:

Access their personal data.

Request correction of inaccurate data.

Request deletion of data where permissible.

Object to processing for direct marketing purposes.

Withdraw consent where applicable.

You have the right to request a copy of your data in a structured, machine-readable format for transfer to another service provider. To exercise these rights, Users may contact privacy@propearnly.com.

9. Cookies & Online Tracking

9.1. PropEarnly uses cookies to enhance website functionality and analyse usage patterns. Users may manage cookie settings via their browser preferences.

9.2 We use third-party analytics tools (e.g., Google Analytics) to improve user experience. These tools may track website activity and collect IP addresses.

COOKIE POLICY

1. Introduction

This Cookie Policy explains how PropEarnly ("we", "us", or "our") uses cookies and similar technologies to enhance your experience when visiting our website www.propearnly.com (the "Website").

Cookies help us understand how users interact with our platform, improve functionality, and provide a secure, personalised, and efficient investment experience.

By using the Website, you consent to the use of cookies as described in this Policy unless you disable them through your Cookie Preferences or browser settings.

2. What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They store and retrieve information about your browsing preferences, allowing websites to function properly and securely.

Cookies can be:

First-party cookies – Set directly by PropEarnly.

Third-party cookies – Set by trusted service providers like Google, Brevo, and StartButton.

3. Types of Cookies We Use

We use four types of cookies: Necessary, Functional, Analytical & Performance, and Marketing & Advertising. The table below outlines their purposes.

3.1 Necessary Cookies

These cookies are essential for the Website to function properly. They enable security, fraud prevention, and user authentication. You cannot disable these cookies, as they are required for core functionalities.

3.2 Functionality Cookies

These cookies remember user preferences and enhance the user experience.

3.3 Analytical & Performance Cookies

These cookies help us measure how visitors use our Website, allowing us to improve usability and performance.

3.4 Marketing & Advertising Cookies

These cookies track browsing habits to deliver relevant investment offers. If you disable them, you may still see ads, but they will be less relevant to your interests.

4. Managing Your Cookie Preferences

You have control over which cookies are stored on your device. You can:

Customise settings in our Cookie Consent Manager (available at first visit or via site footer).

Adjust browser settings to block or delete cookies.

Opt out of tracking via Google Analytics: Google Opt-Out.

Disable targeted advertising via Your Online Choices.

We also respect Global Privacy Control (GPC) and Do Not Track (DNT) settings where applicable.

5. How Long Do We Store Cookies?

Cookies expire at different intervals:

Session cookies – Expire when you close your browser.

Persistent cookies – Stored for up to 24 months, unless deleted manually.

6. Third-Party Services & Compliance

We work with trusted third-party service providers for security, payments, and analytics. These providers may place cookies on our Website:

All partners must comply with UK GDPR, ICO, and FCA regulations on data protection.

7. Changes to This Policy

We may update this Cookie Policy periodically. When significant changes occur, we will:

Send an email notification to registered users.

Display an updated cookie banner on our Website.

For legal compliance, we also review changes in UK and EU cookie regulations and update our practices accordingly.

10. Underage Users

10.1. PropEarnly does not knowingly collect data from individuals under 18 years of age. Users must be at least 18 years old to invest on our platform.

10.2 If we discover that an under-18 user has provided personal data, we will delete it immediately. If you believe a minor has submitted data, contact us at privacy@propearnly.com.

11. Corporate Changes

11.1. In the event of a merger, acquisition, or sale of assets, Users' data may be transferred as part of business restructuring. If such changes occur, Users will be informed in advance.

12. Contact Information

For inquiries regarding this Privacy Policy, please contact:

Privacy Team, PropEarnly

14th Floor, The Plaza, Old Hall St, Liverpool, L3 9QJ

Email: privacy@propearnly.com

This Privacy Policy was last updated on [6th February 2025].

13. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If you wish to exercise any of the rights set out above, please email us at help@propearnly.com.