Privacy Policy

Last updated: 1st January 2026

Data Controller Information

NobleElysium B.V. is the data controller for the personal information we collect and process. Our contact details are:

Data Collection

We collect personal data in various ways when you interact with our website and services. The data we collect includes information you provide directly to us and information collected automatically through your use of our website and services.

Information You Provide

• Contact Information: Name, email address, phone number, and postal address when you contact us or request information
• Communication Data: Messages, enquiries, and other communications you send to us
• Business Information: Details about your investment interests, financial requirements, and business needs
• Marketing Preferences: Your preferences regarding marketing communications and newsletters

Information Collected Automatically

• Technical Data: IP address, browser type, operating system, and device information
• Usage Data: Pages visited, time spent on pages, and interaction with website features
• Cookie Data: Information collected through cookies and similar tracking technologies
• Location Data: General location information based on IP address

How We Use Your Information

We use your personal data for various purposes based on legitimate business interests, contractual necessity, or your consent. How we use your information depends on the services you use and your interactions with us.

Primary Uses

• Service Provision: To provide real estate investment services and respond to your enquiries
• Communication: To communicate with you about our services, updates, and your account
• Customer Support: To provide technical support and customer service
• Legal Compliance: To comply with legal obligations and regulatory requirements

Secondary Uses

• Marketing: To send you marketing communications about our services (with your consent)
• Analytics: To analyse website usage and improve our services
• Security: To protect our website and services from fraud and security threats
• Business Development: To develop new services and improve existing ones

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

For detailed information about the cookies we use and how to manage them, please see our Cookie Policy.

Data Sharing and Disclosure

We do not sell your personal data to third parties. We may share your information in the following circumstances:

• Service Providers: With trusted third-party service providers who assist us in operating our business
• Legal Requirements: When required by law, regulation, or legal process
• Business Transfers: In connection with a merger, acquisition, or sale of business assets
• Consent: When you have given explicit consent for specific sharing

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. The retention period varies depending on the type of data and the purpose for which it is processed.

• Contact Information: Retained for up to 7 years after last contact
• Marketing Data: Retained until you withdraw consent or for 3 years of inactivity
• Technical Data: Typically retained for 26 months for analytics purposes
• Legal Records: Retained as required by applicable laws and regulations

Your Rights

Under GDPR and applicable data protection laws, you have several rights regarding your personal data. These rights may be subject to certain limitations and exceptions.

• Access: Right to request access to your personal data and information about how we process it
• Rectification: Right to request correction of inaccurate or incomplete personal data
• Erasure: Right to request deletion of your personal data in certain circumstances
• Portability: Right to receive your personal data in a structured, machine-readable format
• Restriction: Right to request restriction of processing in certain circumstances
• Objection: Right to object to processing based on legitimate interests or for marketing purposes
• Withdraw Consent: Right to withdraw consent where processing is based on consent

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication procedures
• Staff training on data protection and security
• Incident response and breach notification procedures

International Data Transfers

As we operate primarily within the European Union, your personal data is generally processed within the EU/EEA. If we transfer data outside the EU/EEA, we ensure appropriate safeguards are in place, such as adequacy decisions, standard contractual clauses, or other approved transfer mechanisms.

Children's Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete such information promptly.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date.

Contact Information

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us using the following information:

You also have the right to lodge a complaint with the relevant data protection authority if you believe we have not handled your personal data in accordance with applicable laws.