In short: We only collect what we need to run your account and manage your holdings. We never sell your data. You can ask to see, correct, or delete it at any time by contacting your account manager.
01 Who we are
Horizon Real Estate ("Horizon", "we", "our", "us") is a private property share management firm. We operate a members-only platform through which verified holders acquire, track, and manage share positions in properties under our management.
For the purposes of applicable data protection law, Horizon is the data controller for the personal information described in this policy.
02 What we collect
We collect information in three ways: what you give us directly, what we generate while you use the platform, and what we receive from the entities you interact with on our behalf.
Information you provide
- Identity and contact details — full name, email address, phone number, country of residence.
- Verification information — proof of identity documents, proof of address, and any supporting documentation required by our onboarding team before you are issued a Holder ID.
- Payment information — bank account details, crypto wallet addresses, and any payment proof you upload when making a deposit or requesting a withdrawal.
- Correspondence — emails, chat messages, and notes you send to your account manager.
- Site visit details — dates, times, guest counts, and the contact phone number you provide when booking a visitation.
Information we generate
- Holder ID and PIN data — your unique 10-digit Holder ID, and a securely hashed version of your PIN. We never store your PIN in plain text.
- Account activity — login timestamps, IP addresses, device user agents, and audit log entries recording every meaningful action taken on your account.
- Holdings and transactions — every share acquisition, sale, deposit, and withdrawal associated with your account, along with the valuations, dividends, and profit movements attached to them.
- Notifications and communications — records of notices we send you and whether they have been read.
Information from third parties
- Property managers — reports and updates about the physical assets you hold shares in.
- Payment rails — confirmations from banks, crypto networks, or digital wallet providers that funds have arrived or left.
03 How we use your information
We use your personal information strictly for the purposes below:
- To onboard and verify you — so only legitimate holders can participate in the platform.
- To operate your account — tracking your holdings, processing share acquisitions and sales, and crediting or debiting your wallet.
- To process deposits and withdrawals — including reviewing proof of payment and confirming payouts to your nominated bank, crypto, or digital wallet destination.
- To publish performance data — so holders see daily share value movements, log book entries, and project reports.
- To arrange site visitations — confirming visits with the site manager and contacting you with the schedule.
- To maintain security — detecting and preventing fraudulent, unauthorised, or abusive activity.
- To comply with the law — retaining records where we are legally required to do so.
- To communicate with you — sending service notices, changes to this policy, or important holder announcements.
We do not use your information for advertising, profiling for marketing purposes, or automated decision-making that affects your rights.
04 Legal basis for processing
Where data protection law requires us to identify a legal basis for processing, we rely on:
- Contract — processing necessary to perform our agreement with you as a holder.
- Legal obligation — processing necessary to comply with applicable financial, anti-fraud, and record-keeping laws.
- Legitimate interests — processing necessary to operate the platform securely and efficiently, without overriding your rights.
- Consent — where we ask you specifically, for example to be contacted about a new listing.
06 How long we keep it
We keep your personal information only for as long as it is needed for the purposes in this policy, or for as long as the law requires.
- Account data — retained for the lifetime of your account and for a reasonable period after closure to resolve disputes and meet record-keeping obligations.
- Financial records — retained for the minimum period required by applicable financial record-keeping laws.
- Audit logs — retained for security and integrity purposes, typically for at least two years.
- Marketing consent — retained until you withdraw it.
07 How we protect your data
We apply industry-standard security practices to protect your information. These include:
- Encrypted connections (HTTPS) for all traffic between your browser and our servers.
- Passwords stored only as salted bcrypt hashes — never in plain text.
- PINs stored only as salted bcrypt hashes, separate from passwords.
- Session tokens bound to a browser fingerprint and rotated on sensitive actions.
- Rate limiting on login, PIN entry, and every action that moves money.
- Full audit logging of account activity, reviewable by our team.
- Access controls restricting staff access to personal information to a need-to-know basis.
No system is perfectly secure. If we ever become aware of a breach affecting your personal information, we will notify you and the relevant authorities as required by law.
08 Your rights
Subject to applicable law, you have the right to:
- Access — request a copy of the personal information we hold about you.
- Correct — ask us to fix any information that is inaccurate or out of date.
- Delete — ask us to delete your personal information where there is no overriding legal reason for us to keep it.
- Restrict — ask us to limit how we use your information in certain circumstances.
- Object — object to processing based on our legitimate interests.
- Portability — request your data in a structured, commonly used format.
- Withdraw consent — where we rely on consent, withdraw it at any time without affecting prior lawful processing.
- Complain — lodge a complaint with your local data protection authority.
To exercise any of these rights, contact your account manager or write to us using the details in section 12. We will respond within the timeframe required by applicable law.
10 Children
The Horizon platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, please contact us and we will delete it.
11 Changes to this policy
We may update this policy from time to time. When we do, we will update the "Last updated" date at the top of this page. If the changes are significant, we will notify you through the platform or by email before they take effect.
Continuing to use the platform after a change takes effect means you accept the updated policy. If you do not agree with a change, you should contact your account manager.
12 Contact us
If you have any questions about this policy or how we handle your personal information, please contact:
Horizon Real Estate
Available on request