Updated 17 February 2025

DigiShares, Inc. Privacy Policy

At DigiShares, Inc. (hereinafter, “DigiShares”), we recognize the importance of maintaining the confidentiality and security of the personal information (“Personal Information”) you entrust to us. DigiShares and its affiliated entities (collectively, “DigiShares”) are dedicated to safeguarding the privacy of Personal Information related to individuals, including users of Realestate.exchange (“REX”), clients, employees, agents, job applicants, and others who interact with or are associated with DigiShares. To this end, we have implemented robust policies and practices designed to protect your Personal Information. By opening an account with DigiShares or using our site, products, services, and applications, you consent to the collection, use, creation and disclosure of your Personal Information in accordance with this privacy policy (“Privacy Policy” or “Policy”). We encourage you to review this Policy carefully.

This Policy is grounded in data protection principles common to the jurisdictions in which we operate. It is intended to outline DigiShares’ data protection practices and provide guidance to clients, prospective clients, job applicants, website visitors, and other third-parties about DigiShares’ privacy policies applicable to them.

This Policy applies specifically to those who provide Personal Information to DigiShares, including REX, or who visit or use DigiShares’ websites and software applications in connection to REX.

This Policy is also subject to the conditions laid out in our General Platform Terms & Conditions, which users of REX must accept in order to open an account with REX and use the services provided by REX. 

Responsibility for Your Personal Information

DigiShares is responsible for the Personal Information collected as described in this Policy. 

Categories of Personal Information

DigiShares collects Personal Information directly from you, which may include:

• Information provided during the account application process or use of DigiShares’ website applications and REX (e.g., name, email address, phone number, date of birth, biometric data, etc.).
• Shareholder data resulting from activities conducted through DigiShares systems (e.g., use of REX services).
• Data collected through cookies and similar technologies (once implemented).
• Records of your consents to / acceptance of agreements and policies via REX, including those of third-party integrations. 
• Details provided when applying for employment opportunities (e.g., resume information, name, and contact details).
• Information that you provide to us when you write to us (including by email).
• Information that you provide to us when we speak to you by telephone. We may make and keep a record of the information you share with us.
• Information that you provide to us by completing surveys.
• Details of transactions you carry out when using REX and of the fulfillment of your orders.
• Information obtained by us from third-parties in accordance with this Privacy Policy, such as information collected from social media channels.
• As is true of most web sites, we may gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We may use this information, to analyze trends, to administer our site, to track users’ movements around our site and to gather demographic information about our user base as a whole.

Purposes for Using Personal Information

DigiShares may use your Personal Information for the following purposes (“Permitted Purposes”):

• To provide services as per your agreements with DigiShares, including, but not limited to, administrative, record-keeping, and compliance processes.
• To address requests or inquiries and other services available on our platforms.
• To enforce agreements and protect property or legal rights.
• To manage recruitment processes for job applicants.
• To comply with legal and regulatory requirements applicable in the jurisdictions where DigiShares operates.
• To communicate with you about features, services, or functionality that may interest you.
• To conduct internal monitoring for security, compliance, or investigative purposes, using tools such as, but not limited to, electronic communication recording, and data aggregation.
• To analyze and enhance our products and services through market research and statistical studies.
• To prevent and detect fraud, money laundering, terrorism, and other criminal activities.
• To monitor and analyze our operations, business activities, and legitimate interests.

In some cases, with your explicit consent, DigiShares may process your Personal Information to:

• Provide updates about DigiShares services, products, and technologies.
• Conduct surveys, marketing campaigns, and promotional activities.
• Personalize communications and interactions based on your preferences.

Where legally required, DigiShares will only engage in marketing activities with your explicit consent and will offer you the option to opt out of such communications at any time.

Legal Grounds for Processing Personal Information

Depending on the context, DigiShares processes Personal Information on the following legal grounds:

• Contractual necessity: To fulfill DigiShares’ obligations and your requests in accordance with agreements between you and DigiShares.
• Legal obligations: To comply with applicable laws and regulations.
• Legitimate interests: To advance DigiShares’ operational, business, or legal objectives without overriding your fundamental rights.
• Consent: When required by law or for specific processing activities.

Sharing Personal Information

DigiShares may share your Personal Information, as provided by you when opening an account, including your shareholdings, under the following circumstances:

• Within the DigiShares Entities: For service delivery, administrative purposes, and compliance with legal obligations.
• With third-party service providers: To support operations, including cloud services, fraud prevention, and marketing. DigiShares ensures these providers adhere to confidentiality agreements and use Personal Information solely for authorized purposes.
• With financial institutions and regulatory bodies: For fraud prevention, crime detection, and compliance.
• With third-parties integrated with REX in which the users on REX have entered into separate agreements with said third-parties: To facilitate the users use of the third-party services. 
• For employment application processing: To facilitate recruitment procedures.
• With legal and regulatory authorities: To comply with legal requirements or resolve disputes.
• With external advisors, consultants or legal partners: For optimizing our service delivery and operations and to improve compliance.

Personal Information may also be shared in aggregated or anonymized formats for statistical or research purposes.

Your Obligations

In the event that you share Personal Information to us about someone else, you must make sure that you are legally authorized and entitled to share said Personal Information, which will be subject to this Privacy Policy.

You are responsible for the accuracy and correctness of the Personal Information that you provide. DigiShares is not responsible for the accuracy and correctness of the Personal Information, nor is DigiShares responsible for updating your Personal Information. If you wish to update your Personal Information, please let us know by writing an email to [email protected].

Securing Personal Information

DigiShares employs appropriate technical and organizational measures to safeguard Personal Information in compliance with legal requirements. Data may be stored on DigiShares’ IT systems, contractor systems, or in physical records. While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical and sufficient.

In Case of a Security or Privacy Breach: DigiShares takes commercially reasonable measures to safeguard your Personal Information. However, no system is completely secure, and we cannot guarantee absolute protection against unauthorized access or data breaches. In the unlikely event of a security or privacy breach, DigiShares will:

• Promptly investigate the incident and notify affected individuals as required by applicable laws.
• Take appropriate steps to mitigate the impact and prevent further breaches.
• Provide guidance to impacted individuals on how to protect themselves, if applicable.

Limitation of Liability: To the extent permitted by law, DigiShares shall not be held liable for any damages, losses, or liabilities resulting from unauthorized access, use, disclosure, or destruction of Personal Information caused by third parties, unforeseen circumstances, or events beyond DigiShares’ control. Our liability for any breach shall be limited to the extent outlined in the General Platform Terms & Conditions.

Retention of Personal Information

Personal Information may be retained for as long as it is required to meet legal, regulatory, and business obligations. Retention periods may be extended for litigation, investigations, or regulatory requirements.

Your Rights

Under applicable laws, individuals may:

• Request access to or correction of their Personal Information.
• Request deletion or restriction of Personal Information under certain conditions.
• Object to processing or withdraw consent where processing is based on consent.
• Request data portability where applicable.

To exercise these rights, contact DigiShares at [email protected]. DigiShares may request proof of identity to process requests and reserves the right to charge reasonable fees for excessive or unfounded requests. 

In the event that there is a dispute between you and DigiShares regarding this Privacy Policy, which cannot be resolved between you and DigiShares, please refer to our General Platform Terms & Conditions to review the Disputes Procedure, which this Privacy Policy is subject to.

Cookies and Tracking Technologies

Technologies such as: cookies, beacons, tags and scripts may be implemented and used by DigiShares Inc and our partners, including marketing partners affiliates, or analytics service providers and business process service providers. These technologies will, if implemented, be used in analyzing trends, administering our site, tracking users’ movements around our site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

If implemented, we may use cookies to estimate our audience size and usage pattern; to store information about your preferences, and so allow us to customize our site according to your individual interests; to speed up your searches; and to recognize you when you return to our site. Users will be able to control the use of cookies at the individual browser level. If you reject cookies, you will still be able to use our site, but your ability to use some features or areas of our site may be limited. 

No Personal Information of Children under The Age of 18

As users of REX must be 18 years of age in order to sign up, no personal information of children under the age of 18 will be collected in connection to REX.

Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our site / REX prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

For questions or feedback about this Privacy Policy, contact DigiShares at [email protected].