Privacy Policy

Section 1: Types of Data We Collect

To comply with legal, regulatory, and operational requirements, Tribe Tokenisation FZE collects specific data from both individual and institutional clients. This data is gathered to facilitate our tokenized real estate investment services, ensure compliance with applicable laws, and maintain the integrity of our operations.

Individual Clients

Tribe collects the following personal data from individual clients:

• Full legal name
• Identification document details, including type and number
• Gender, date of birth, and place of birth
• Nationality and residential address
• Country or state of residence
• Financial information, including net wealth and sources of wealth or income
• Purpose of account opening and intended investment objectives
• Contact details, including phone number and email address
• Bank account information and blockchain wallet addresses (XRPL)
• Investment preferences and risk tolerance
• Any additional information or documentation requested by our compliance team to meet regulatory obligations

Institutional Clients

For institutional clients, the following data is collected:

• Legal entity name and registered business name
• Incorporation or registration details, including jurisdiction and date of establishment
• Contact person information for communication purposes
• Details of related parties and authorized representatives
• Asset and financial information relevant to the entity's operations
• Investment mandate and authorization documents
• Any additional information or documentation required for verification and due diligence purposes

Personal data refers to any information that can identify an individual directly or indirectly. This includes, but is not limited to, identifiers such as names, addresses, and identification numbers. It does not include data that has been anonymized or aggregated to the extent that the individual's identity can no longer be determined.

Tribe Tokenisation FZE is committed to ensuring that all collected data is handled responsibly, securely, and in compliance with applicable privacy and data protection regulations, including UAE Federal Decree-Law No. (45) of 2021 and VARA requirements.

Section 2: Data Protection Practices

Tribe collects various types of personal data to provide our tokenized real estate investment services, meet legal obligations, and enhance user experiences.

Data Collected During Account Creation

• Username and authentication credentials
• Email address and phone number for verification
• Identity verification documents
• Financial information for investment suitability assessment

Data Collected During Investment Activities

• Investment amount and preferences
• Transaction history and block ownership records
• Blockchain wallet addresses (XRPL)
• Banking details for fund transfers
• Investment risk profile and objectives

Data Collected from Communication

• Email correspondence
• Support ticket information
• Phone call records (if applicable)
• Chat transcripts from our platform

Data from Platform Usage

• Login times and frequency
• Pages viewed and features used
• Investment properties browsed
• Transaction attempts and completions

Data from Third-Party Sources

• Identity verification services
• Credit reference agencies
• Dubai Land Department (DLD) for property verification
• Banking partners for payment processing
• Blockchain networks for transaction verification

Data for Regulatory Compliance

• Source of funds documentation
• Politically Exposed Person (PEP) status
• Sanctions screening results
• Transaction monitoring data
• Risk assessment information

Sensitive Personal Data

For identity verification, we may collect biometric data such as facial images, which constitutes Sensitive Personal Data. This is collected only with explicit consent or as required by law and used solely for verification purposes.

Failure to Provide Data

If you fail to provide required personal data, we may be unable to open or maintain your account, process your investments, comply with legal obligations, or provide customer support. We will inform you of the implications when requesting such data.

Section 3: How We Use Your Data

Tribe is committed to using personal data responsibly to deliver secure, compliant, and innovative tokenized real estate investment services. Your data is utilized for:

Legal Compliance

We use personal data to comply with Know Your Customer (KYC) requirements, Anti-Money Laundering (AML) regulations, Counter-Terrorism Financing (CTF) laws, VARA regulatory requirements, Dubai Land Department regulations, and tax reporting obligations. This includes verifying identities, assessing transaction legitimacy, monitoring for suspicious activities, and maintaining required records.

Service Provision

Personal data enables us to create and manage your investment account, process property token purchases and sales, facilitate fractional property ownership, execute blockchain transactions, distribute rental income dividends, provide property management updates, enable secondary market trading, and support Community Tenant programs.

Communication

We use your data to send transaction confirmations, provide investment updates and property reports, deliver security alerts and notifications, respond to customer inquiries, share platform updates and new features, and communicate voting opportunities for property decisions.

Security

Your data helps us detect and prevent fraudulent activities, monitor unusual account behavior, implement two-factor authentication, protect against unauthorized access, conduct security audits, and respond to security incidents.

Performance Monitoring

We analyze data to improve platform functionality, optimize user experience, identify technical issues, understand investment patterns, enhance property selection algorithms, and develop new features based on user needs.

Marketing

With your consent, we may use data to share new investment opportunities, provide market insights and educational content, announce platform features and updates, send newsletters and promotional offers, and invite participation in surveys or events. You can opt-out of marketing communications at any time while continuing to receive essential service messages.

Section 4: Sharing Your Data

Tribe is committed to protecting your personal data and shares it only when necessary and lawful. We do not sell your data to third parties.

With Your Consent

We share data with third parties only when you provide explicit consent, such as sharing investment achievements on social media, participating in referral programs, or authorizing specific third-party integrations.

Legal Obligations

We may disclose data to comply with court orders and legal proceedings, regulatory requests from VARA, DLD, or other authorities, law enforcement investigations, tax reporting requirements, and anti-money laundering obligations.

Protecting Rights

Data may be shared to investigate security breaches or fraud, enforce our terms and conditions, protect Tribe's intellectual property, defend against legal claims, and safeguard user and platform security.

Service Providers

We share data with trusted partners including CTRL ALT Solutions DMCC (tokenization services), banking partners for payment processing, identity verification providers, property management companies, IT infrastructure and security providers, and professional advisors (lawyers, auditors). All service providers are bound by strict confidentiality agreements and data protection standards.

Section 5: Data Storage, Transfers and Retention

Data Transfers

Your personal data may be transferred internationally for blockchain network operations, global compliance screening, cloud storage and backup, and cross-border investment facilitation. Safeguards include data encryption during transfer and storage, contractual clauses requiring equivalent protection, compliance with international data protection frameworks, and regular security assessments of data processors.

Data Storage and Security

Tribe implements comprehensive security measures including end-to-end encryption for sensitive data, secure blockchain integration (XRPL), multi-factor authentication, regular security updates and patches, intrusion detection systems, role-based access controls, regular security training for staff, incident response procedures, data protection impact assessments, secure data center facilities, and backup and disaster recovery systems.

Data Retention

We retain personal data according to legal requirements (typically 5–7 years for financial records), regulatory obligations under VARA and AML laws, active account status, and ongoing legal proceedings or disputes. When data is no longer needed, it is securely deleted from active systems, anonymized for statistical purposes, or archived with restricted access where legally required.

Incident Response

In case of a data breach, affected users will be notified within 72 hours, VARA will be notified within 24 hours, remedial actions will be implemented immediately, and a detailed report will be provided to authorities.

Section 6: Other Useful Information

Your Rights

Under applicable data protection laws, you have the right to access your personal data, correct inaccurate information, request deletion (subject to legal requirements), object to certain processing, restrict processing in specific circumstances, data portability for information you provided, and withdraw consent for optional processing. To exercise these rights, contact privacy@mytribe.ae.

Marketing Communications

We may send you information about new property investment opportunities, platform features and updates, educational content about real estate investment, and market insights and analysis. To opt-out of marketing emails, click the unsubscribe link or email support@mytribe.ae. Essential service communications cannot be opted out of.

Third-Party Links

Our platform may contain links to external websites. We are not responsible for their privacy practices. Please review their policies before sharing personal information.

Data Controller

Tribe Tokenisation FZE is the data controller for your personal information. Contact our Data Protection Officer at privacy@mytribe.ae, or write to us at: 440, Level 3, The Offices, Dubai, United Arab Emirates.

Children's Privacy

Our services are for individuals 18 years and older. We do not knowingly collect data from minors. If you believe a minor has provided us data, please contact support@mytribe.ae immediately.

International Users

If you access our services from outside the UAE, you consent to data transfer to the UAE and processing under UAE laws.

Contact Information

For privacy-related inquiries: privacy@mytribe.ae. For general support: support@mytribe.ae. If your concerns are not adequately addressed, you may contact the relevant data protection authority.

Policy Updates

This Privacy Policy is effective as of 31/07/2025 and will be reviewed regularly. Material changes will be communicated via email notification to registered users, platform announcements, and website banners. Your continued use of our services after updates constitutes acceptance of the revised policy.