Legal & Compliance
Your privacy is fundamental to how we build and operate our products. This document explains exactly what we collect, why, and how you remain in control.
We believe privacy is a right, not a privilege. We never sell your data, and we never will.
§ 01
Frazer Capital is operated by Global Properties Gambia ("we", "us", "our"), the data controller responsible for your personal information under this policy.
We collect information you provide directly when you create an account and use Frazer Capital. This includes your name, email address, phone number, postal address, and profile photo, as well as account credentials managed through email-and-password, Sign in with Apple, or Google sign-in.
To meet legal and regulatory obligations, we collect identity verification data during onboarding, including government-issued identification, a selfie, and related verification results (such as verification status, risk level, and anti-money-laundering screening outcome). This identity verification is performed by our verification provider, Persona, on our behalf.
We collect financial and investment information generated through your use of the app, including the amounts you invest, your proof-of-payment documents, your ownership percentage in a building, accrued rental earnings, payout records, and withdrawal requests.
We also collect information automatically when you use the app, including device information, app and crash logs, an approximate IP-based location, and a push-notification token used to deliver alerts.
§ 02
We use your information to create and secure your account; verify your identity and assess eligibility to invest; process and record your investments, earnings, payouts, and withdrawals; and provide the benefits associated with your ownership tier, such as partner discounts and office-day bookings.
We also use your information to send transactional notifications (for example, investment approval, payout, withdrawal, and booking status), to respond to support requests, to detect and prevent fraud and abuse, and to comply with financial, tax, and anti-money-laundering laws.
We do not use your information to sell or trade it, and we do not use it for third-party advertising.
§ 03
Before you can invest, you must complete identity verification. This process is operated by Persona (withpersona.com), an independent identity-verification provider, through a secure flow launched from the app.
Persona collects and processes the identification documents and biometric selfie you submit in order to confirm your identity and screen for compliance risks. We receive the outcome of this process, including your verification status, an assigned risk level, and your anti-money-laundering screening result, which we retain to satisfy our regulatory obligations. Persona's handling of your data is governed by Persona's own privacy policy.
§ 04
Frazer Capital facilitates fractional real-estate investment. Payments for investments are made outside the app through real-world financial channels, and you upload proof of payment for an administrator to verify. We do not collect or store full card or bank credentials within the app.
We retain records of your investments, ownership percentages, accrued rental income, payouts, and withdrawals. These records are kept for as long as required by applicable financial, tax, and anti-money-laundering regulations, even after you close your account.
§ 06
We protect your information using encryption in transit, restricted access controls, and secure cloud infrastructure. On your device, your authenticated session is stored in the operating system's secure keystore and may be protected by Face ID, Touch ID, or your device passcode.
Despite our efforts, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach affecting your personal information, we will notify you and the relevant authorities as required by law.
§ 07
We retain your personal information for as long as your account is active and as needed to provide the service. Identity-verification results and financial records are retained for longer periods where we are legally required to keep them, such as under anti-money-laundering and tax laws.
When information is no longer required, we delete it or anonymize it. You may request deletion of your account, subject to records we are legally obligated to retain.
§ 08
Depending on your jurisdiction, you have the right to access, correct, or delete the personal information we hold about you, to object to or restrict certain processing, and to request a copy of your information in a portable format. You can update much of your profile information directly in the app, and you can disable push notifications at any time in your device settings.
To exercise your rights, contact us at privacy@frazercapitals.com. We will respond within the timeframe required by applicable law. Please note that certain information may be retained where we have a legal obligation or legitimate business reason to do so.
§ 09
Frazer Capital is a financial product intended only for adults. The app is not directed to anyone under the age of 18, and we do not knowingly collect personal information from minors.
If we learn that we have collected personal information from a person under 18, we will delete that information promptly. If you believe a minor has provided us with personal information, please contact us.
§ 10
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will update the "Last Revised" date above and, where appropriate, notify you in the app or by email.
If you have questions about this policy or how we handle your information, contact Global Properties Gambia at privacy@frazercapitals.com.