Privacy notice

Applies to FP fractionaire, operated by [FP to confirm: legal entity name].

Who is responsible

[FP to confirm: legal entity name] is responsible for the personal data described here. Contact the privacy team at [FP to confirm: privacy email].

What we collect

Wallet and sign-in data: your wallet address, the sign-in method you used (thirdweb or reID) and, for reID, your reID user id and access tokens, which we store encrypted.
Contact data: the email address you choose to add, and a display name if you set one.
Verification data: your verification status and level, your Sumsub applicant id, the review decision and any reviewer comment. Your identity documents and selfies are collected and held by Sumsub, not by us.
Transaction data: your orders, payment token, amounts, transaction hashes and holdings. Transactions on INFRA Network are public by design.
Technical data: IP address and request details, used for rate limiting and security. When our staff act on your account, the action is written to an internal audit log.

Why we use it

To create and secure your account.
To complete verification before you buy.
To process purchases and show your portfolio.
To send service emails: welcome, verification status and purchase confirmations.
To meet legal, accounting and regulatory duties.

[FP to confirm: legal basis for each purpose]

Sumsub, for identity and business verification.
thirdweb and reID, which provide wallet sign-in and, for reID, purchase approval.
Supabase, which hosts our database and file storage. [FP to confirm: hosting region for production data]
Resend, which delivers our emails.
INFRA Network: your wallet address, each purchase and the token you receive are written to a public blockchain.

We do not sell your personal data.

Public blockchain records

Records on INFRA Network are public and permanent. We cannot change or delete them, including after you close your account.

How long we keep it

[FP to confirm: retention periods for account, verification and transaction records]

Cookies and browser storage

We use a strictly necessary session cookie to keep you signed in, and a short-lived cookie that protects the reID sign-in exchange. We do not use advertising or analytics cookies. The Sumsub verification widget and the thirdweb wallet widget may keep their own data in your browser while you use them.

Your rights

You can ask to access, correct or delete your personal data, or object to how we use it, by writing to [FP to confirm: privacy email]. Some records must be kept by law, and blockchain records cannot be deleted. [FP to confirm: supervisory authority and how to complain to it]