Privacy Policy

1. Introduction

Seedio Ltd. ("Seedio," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile application, and services (collectively, the "Platform").

Please read this Privacy Policy carefully. By accessing or using our Platform, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy. If you do not agree with our policies and practices, please do not use our Platform.

This Privacy Policy applies to all users of our Platform, including investors, property owners, partners, and visitors.

2. Information We Collect

We collect several types of information from and about users of our Platform, including:

Personal Information

Personal information is data that can be used to identify you directly or indirectly. We may collect the following personal information:

• Identity Information: Full name, date of birth, nationality, gender, passport or ID details, photographs, and signatures.
• Contact Information: Email address, telephone number, postal address, and country of residence.
• Financial Information: Bank account details, payment card details, income information, source of funds, and investment history.
• Professional Information: Occupation, employer details, business sector, and professional qualifications.
• Family Information: Information about your spouse, children, or dependents when relevant to immigration applications.

Non-Personal Information

We also collect non-personal information, which does not directly identify you:

• Usage Data: Information about how you use our Platform, including browsing patterns, pages visited, features used, and time spent.
• Device Information: IP address, browser type, operating system, device information, and mobile network information.
• Location Data: General geographic location based on IP address or more precise location if you enable location services.

How We Collect Information

We collect information in the following ways:

• Direct Collection: Information you provide when you register for an account, complete a profile, communicate with us, submit an application, or use our services.
• Automated Collection: Information collected automatically through cookies and similar technologies when you use our Platform.
• Third-Party Sources: Information from business partners, identity verification services, credit reference agencies, public databases, and social media platforms.

3. How We Use Your Information

We use your information for various purposes, including to:

Purpose	Examples	Legal Basis (EU/EEA Users)
Provide our Services	Process investments, facilitate immigration applications, manage accounts	Performance of a contract
Comply with Legal Obligations	Due diligence, AML checks, tax reporting, regulatory compliance	Legal obligation
Improve our Platform	Analyze usage, enhance functionality, troubleshoot issues	Legitimate interests
Communicate with You	Respond to inquiries, provide updates, send notifications	Performance of a contract / Legitimate interests
Marketing	Send newsletters, promotions, investment opportunities	Consent / Legitimate interests
Protect Rights and Safety	Detect fraud, prevent misuse, ensure security	Legitimate interests

Automated Decision-Making

We may use automated processes to evaluate your eligibility for certain investment migration programs or to verify your identity. You have the right to request human intervention, express your point of view, and contest the decision if you are subject to automated decision-making.

4. Information Sharing and Disclosure

We may share your information with the following categories of recipients:

Service Providers

We share information with trusted third-party service providers who perform services on our behalf, including:

• Payment processors and financial institutions
• Identity verification services
• Legal advisors and immigration consultants
• Property developers and real estate agencies
• Cloud storage providers and IT service providers
• Marketing and analytics companies

All service providers are contractually required to use your information only for the provision of their services to us and in compliance with this Privacy Policy.

Government Authorities

We may disclose your information to government authorities, including:

• Immigration and citizenship departments
• Tax authorities
• Regulatory bodies and law enforcement agencies

Such disclosures may be required to process immigration applications, comply with legal obligations, or respond to legal processes.

Business Transfers

If Seedio is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your information through our Platform.

With Your Consent

We may share your information with third parties when you have given us your consent to do so.

Aggregated or De-identified Data

We may share aggregated or de-identified information, which cannot reasonably be used to identify you, with third parties for research, marketing, analytics, and other purposes.

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities on our Platform.

Types of Cookies We Use

• Essential Cookies: Necessary for the Platform to function properly.
• Analytical/Performance Cookies: Allow us to recognize and count visitors and see how they move around our Platform.
• Functionality Cookies: Remember your preferences and settings.
• Targeting Cookies: Record your visit to our Platform, the pages you have visited, and the links you have followed.

Your Cookie Choices

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or accept cookies and to delete cookies. However, if you disable cookies, some parts of our Platform may not function properly.

Third-Party Tracking

We use third-party services, such as Google Analytics, to help us analyze how our Platform is used. These services may use cookies and other tracking technologies to collect information about your use of our Platform.

6. Data Security

We take the security of your information seriously and implement appropriate technical and organizational measures to protect your information from unauthorized access, disclosure, alteration, and destruction.

Our security measures include:

• Encryption of sensitive data in transit and at rest
• Access controls and authentication mechanisms
• Regular security assessments and audits
• Staff training on data protection and security
• Physical security measures for our offices and data centers

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

7. Data Retention

We retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you
• Our legal obligations under applicable laws
• Relevant statutes of limitations
• The existence of ongoing or potential legal claims

When we no longer need to use your information, we will securely delete or anonymize it so that it can no longer be associated with you.

8. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information. These may include:

For EEA, UK, and Similar Jurisdictions

• Right to Access: Request a copy of your personal information.
• Right to Rectification: Correct inaccurate or incomplete information.
• Right to Erasure: Request deletion of your personal information in certain circumstances.
• Right to Restrict Processing: Limit how we use your personal information.
• Right to Data Portability: Receive your information in a structured, commonly used format.
• Right to Object: Object to processing based on legitimate interests or for direct marketing.
• Right to Withdraw Consent: Withdraw previously given consent for data processing.

For California Residents

The California Consumer Privacy Act (CCPA) provides additional rights, including:

• Right to know what personal information is being collected
• Right to know whether personal information is sold or disclosed
• Right to say no to the sale of personal information
• Right to access your personal information
• Right to equal service and price

How to Exercise Your Rights

To exercise your rights, please contact us using the information provided in the "Contact Us" section. We may need to verify your identity before responding to your request.

Marketing Communications

You can opt out of receiving marketing communications from us by following the unsubscribe instructions included in each marketing email or by contacting us directly.

9. International Data Transfers

Seedio operates globally, and your information may be transferred to and processed in countries other than the country in which you reside. These countries may have data protection laws that are different from those in your country.

When we transfer your information to other countries, we will ensure that:

• The transfer is to a country that has been deemed to provide an adequate level of protection
• We have implemented appropriate safeguards, such as standard contractual clauses
• You have given explicit consent to the transfer
• The transfer is necessary for the performance of a contract or for pre-contractual measures

By using our Platform, you consent to the transfer of your information to countries outside your country of residence, including the United States, which may have different data protection rules than those of your country.

10. Children's Privacy

Our Platform is not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the updated Privacy Policy on this page and updating the "Last Updated" date.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information. Your continued use of our Platform after any changes to this Privacy Policy constitutes your acceptance of the changes.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Seedio Ltd.
Attn: Data Protection Officer
123 Syntagma Square
Athens, 10563
Greece

Email: privacy@seedio.com
Phone: +30 210 1234567

For EU/EEA residents: You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information infringes data protection laws.