Privacy Policy

1. Accountability

Golden Fraction is responsible for personal information under its control.

• Privacy Officer: Ms Victoria Alessandro
• Email: legal@goldenfraction.com
• Mailing address: 11199 Polo Club Rd, Wellington, FL 33414, United States

If Golden Fraction is acting only as a service provider for a Developer, some information may be controlled by that Developer. In that case, the Developer’s privacy policy may also apply.

2. Information We Collect

Depending on your use of the Platform, we may collect:

Golden Fraction should not collect or store full bank-account or payment-card information.

3. Purposes of Collection and Use

We may use personal information to:

• Create and administer accounts;
• Provide Platform services;
• Facilitate communications with Developers and authorized service providers;
• Provide project updates;
• Process documents and electronic signatures;
• Conduct identity, eligibility, fraud, sanctions, and compliance checks;
• Respond to inquiries;
• Send service communications;
• Send marketing communications where permitted;
• Improve and secure the Platform;
• Analyze usage;
• Maintain records;
• Establish, exercise, or defend legal claims;
• Comply with legal, tax, regulatory, court, and law-enforcement requirements; and
• Complete a business transaction, such as a merger, financing, or sale.

4. Consent and Legal Authority

We collect, use, and disclose personal information with consent or as otherwise permitted or required by law. You may withdraw consent to optional uses, such as marketing, by using the unsubscribe function or contacting legal@goldenfraction.com. Withdrawal may not affect processing required for legal, security, contractual, or operational purposes.

5. Disclosure of Personal Information

We may disclose personal information to:

• Developers and project sponsors;
• Their lawyers, title companies, escrow providers, trustees, accountants, brokers, and administrators;
• Identity-verification, compliance, hosting, analytics, communications, customer-support, and electronic-signature providers;
• Payment or banking providers, where applicable;
• Professional advisers;
• Affiliates and corporate service providers;
• Regulators, government agencies, courts, law enforcement, and tax authorities where required or permitted; and
• A purchaser, investor, lender, or successor in connection with a corporate transaction.

We do not sell personal information for money.

6. International Processing

Our service providers or transaction counterparties may be located in Canada, the United States, or other countries. Personal information processed outside Canada may be subject to the laws of that jurisdiction and may be accessible to courts, law enforcement, or national-security authorities.

Countries where information may be processed:

• Canada
• United States

7. Retention

We retain personal information only as long as reasonably necessary for the purposes described in this Policy, contractual requirements, legal obligations, dispute resolution, fraud prevention, and recordkeeping.

8. Safeguards

We use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including, where applicable:

• Access controls;
• Encryption in transit and at rest;
• Authentication controls;
• Logging and monitoring;
• Staff confidentiality obligations;
• Vendor due diligence;
• Backups and disaster recovery; and
• Incident-response procedures.

No method of transmission or storage is completely secure.

9. Cookies

We use cookies and similar technologies for:

• Essential Platform functions;
• Authentication;
• Preferences;
• Analytics;
• Security; and
• Marketing, where permitted.

10. Your Rights

Subject to applicable law, you may request:

• Access to personal information;
• Correction of inaccurate information;
• Information about collection and use;
• Withdrawal of consent;
• Deletion or disposal;
• Restriction or objection to certain processing;
• Portability, where applicable; or
• Review of a complaint or privacy decision.

11. Children

The Platform is not directed to children under 18. We do not knowingly collect personal information from children contrary to applicable law.

12. Marketing

You may unsubscribe from promotional communications at any time. You may continue to receive transactional, legal, security, and service-related messages.

13. Breach Notification

If a privacy incident creates a real risk of significant harm or triggers another notification requirement, we will respond and provide notifications as required by applicable law.

14. Changes

We may update this Policy from time to time. The revised version will be posted with a new effective date. Material changes will be communicated where required.