1. WHAT INFORMATION WE COLLECT

We collect various types of information about you to provide and improve our services, including:

1.1. Information You Provide Directly To Us:

• Account Registration & Profile Data: When you create an account, we collect your full name, email address, phone number, physical address, username, and password.
• Identity Verification (KYC/AML): To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations, and to secure our Platform, we collect sensitive information, including but not limited to:
  • Copies of government-issued identification (e.g., CNIC, Passport).
  • Date of birth, nationality, gender.
  • Photographic identification (e.g., a selfie).
  • Proof of address (e.g., utility bill).
  • Profession/occupation, source of funds.
• Financial & Transaction Data: When you make a purchase, list fractions, or conduct transactions, we collect:
  • Bank account details, payment card details (processed securely via third-party payment gateways, we do not store full card numbers).
  • Transaction history, payment amounts, installment schedules.
  • Details of your fractional real estate investments and portfolio on the Platform.
• Communications: When you communicate with us (e.g., customer support inquiries, feedback, emails), we collect the content of those communications.
• From Partner Platforms: If you sign up or access our services through a Partner Platform (e.g., Project Portal’s Front End), that Partner Platform may share your registration, profile, and transaction data with us as necessary to enable us to provide the backend services and process transactions.

1.2. Information We Collect Automatically:

When you access and use the Platform, we may automatically collect certain information about your device and usage:

• Device Information: Your IP address, device type, operating system, browser type, unique device identifiers, and mobile network information.
• Usage Data: Information about how you interact with the Platform, including the pages you visit, features you use, the time and date of your visits, the time spent on those pages, and referring/exit pages.
• Location Information: General location information derived from your IP address.
• Cookies and Tracking Technologies: We use cookies and similar tracking technologies to track activity on our Platform and hold certain information. For more details, see Section 7.

2. HOW WE USE YOUR INFORMATION

We use the information we collect for various purposes, including:

2.1. To Provide and Manage Our Services:

• To create, maintain, and manage your account on the SNAPL Portal.
• To facilitate your purchases, listings, and transfers of fractional real estate units.
• To process your transactions and payments securely.
• To provide customer support and respond to your inquiries.
• To deliver important notices, updates, and communications regarding your account or transactions.

2.2. For Security and Compliance:

• To perform KYC and AML checks, prevent fraud, and detect suspicious activities.
• To comply with all applicable legal, regulatory, and statutory obligations (including those related to financial transactions and data protection in Pakistan).
• To enforce our Terms of Service and other policies.

2.3. To Improve and Personalize the Platform:

• To analyze how users interact with our Platform, identify trends, and improve functionality.
• To personalize your experience on the Platform and offer content or features relevant to you.
• To develop new products, services, and features.

2.4. For Communication and Marketing (with consent where required):

• To send you newsletters, promotional offers, or information about new listings or services that may be of interest to you.
• To send you marketing communications where we have your consent or a legitimate interest to do so. You can opt-out of marketing communications at any time.

3. HOW WE SHARE YOUR INFORMATION

We may share your personal information with third parties in the following circumstances:

3.1. With Partner Platforms:

As SNAPL provides the backend technology, we share your relevant personal and transaction data with the Partner Platform (e.g., Project Portal’s Front End) through which you accessed our services. This is essential for the Partner Platform to manage its listings, provide support, and fulfill its obligations to you as per its own terms.

3.2. With Service Providers:

We engage third-party service providers to perform functions on our behalf, such as:

• Payment processing providers (e.g., JazzCash, credit/debit card processors).
• Cloud hosting and data storage providers.
• KYC/AML verification service providers.
• Analytics providers.
• Customer support tools.

These service providers have access to personal information only to perform their functions and are contractually obligated to protect it.

3.3. For Legal and Regulatory Reasons:

We may disclose your information if required to do so by law, or in response to valid requests by public authorities (e.g., a court order, subpoena, or government agency request) or to comply with applicable data protection, AML, and other financial regulations in Pakistan.

3.4. For Business Transfers:

In the event of a merger, acquisition, restructuring, bankruptcy, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction.

3.5. With Your Consent:

We may share your information with any other third party when we have your explicit consent to do so.

3.6. With Affiliates:

We may share your information with our subsidiaries, parent companies, and other affiliates, provided they adhere to this Privacy Policy.

4. DATA SECURITY

We implement reasonable technical and organizational measures to protect your personal information from unauthorized access, use, alteration, and disclosure. These measures include:

• Encryption: Using encryption for data in transit and at rest where appropriate.
• Access Controls: Implementing strict access controls and authentication mechanisms to limit access to personal data.
• Firewalls: Using firewalls and other network security measures.
• Regular Audits: Conducting regular security audits and vulnerability assessments.
• Password Encryption: Storing passwords in encrypted, one-way hashed formats, meaning they cannot be retrieved in plain text.

While we strive to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security. You are also responsible for maintaining the confidentiality of your account password and for any activities that occur under your account.

5. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. This includes retaining data to comply with our legal, accounting, or reporting obligations, resolve disputes, and enforce our agreements. For instance, financial and AML regulations in Pakistan may require us to retain certain transaction and identity verification data for a minimum period after an account is closed.

6. YOUR PRIVACY RIGHTS

Subject to applicable laws, you may have the following rights regarding your personal information:

• Right to Access: You have the right to request a copy of the personal information we hold about you.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.
• Right to Erasure (Right to Be Forgotten): You may request that we delete your personal information, subject to certain legal obligations (e.g., we cannot delete data required for ongoing transactions, AML compliance, or legal retention periods).

To exercise any of these rights, please contact us using the contact information provided in Section 12. We may need to verify your identity before fulfilling your request.

7. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies (like web beacons and pixels) to enhance your experience on our Platform.

Cookies:

Small data files placed on your device. We use cookies for:

• Essential functionality: To enable core features and secure your session.
• Analytics: To understand how users interact with our Platform (e.g., Google Analytics).
• Preferences: To remember your settings and preferences.

Your Choices:

Most web browsers are set to accept cookies by default. You can usually modify your browser settings to decline cookies or alert you when cookies are being sent. However, disabling essential cookies may affect the functionality of the Platform.

8. THIRD-PARTY LINKS

Our Platform may contain links to websites or services operated by third parties. This Privacy Policy does not apply to those third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. We are not responsible for the privacy practices or content of such third-party websites.

9. CHILDREN'S PRIVACY

Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete that information as quickly as possible.

10. INTERNATIONAL DATA TRANSFERS

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. For instance, our cloud service providers may host data outside Pakistan.

We take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy and that appropriate safeguards are in place, such as standard contractual clauses or reliance on the service provider's certified data protection measures.

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top, and by email or prominent notice on the Platform. Your continued use of the Platform after the effective date of the revised Privacy Policy constitutes your acceptance of the updated terms.

12. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data handling practices, please contact our Data Protection Officer at:

• Gatwala Chowk, Canal Expressway, Sheikhupura Road, Faisalabad
• info@gchf.pk
• +92 341 1111 237
• www.gchf.pk

13. GOVERNING LAW

This Privacy Policy shall be governed by and construed in accordance with the laws of Pakistan.