Privacy Policy

Last Updated: July 10, 2026

This Privacy Policy ("Policy") describes how invest.lease ("Company," "we," "us," or "our") collects, uses, discloses, and safeguards personal information in connection with your access to and use of the invest.lease platform (the "Platform"). This Policy applies to all users, including those who register via email or authenticate through a third-party social login provider such as Google or LinkedIn. By accessing or using the Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. This Policy forms part of our Terms of Service.

Data Controller

The controller responsible for your personal data is invest.lease S.C.A., a société en commandite par actions with registered office at 31 Boulevard Prince Henri, L-1724 Luxembourg, Grand Duchy of Luxembourg, represented by its general partner FUNDREAL Capital Partners S.à r.l. (the "Controller"). You may contact the Controller in relation to any data protection matter, including to exercise the rights set out in Section 11, at support@invest.lease.

1. Information We Collect

We collect personal information in the following categories:

  • Profile and Identity Data: Full name, contact details (email address, phone number), professional credentials, skills, educational background, work experience, and language preferences provided during registration or profile setup.
  • Professional Focus Data ("CRE Focus"): Your self-declared commercial real estate focus, including your Specialisation, Sector focus, Regional focus, and Strategy focus, provided during profile setup and used to support discovery, networking, and matching.
  • Social Login Data: When you authenticate via Google or LinkedIn, we receive limited profile information — including your name, email address, and profile image — as authorized by you through your settings on that platform.
  • User-Generated Content: Posts, comments, requirements, messages, and digital business cards you create or share on the Platform.
  • Transaction and Billing Data: Subscription details, invoices, and payment records processed through our payment providers (Stripe and Paddle). We do not store full payment card details directly.
  • Usage and Technical Data: Device type, browser information, operating system, IP address, session duration, clickstream data, and feature interaction logs collected through cookies and similar tracking technologies.

2. Legal Bases for Processing (GDPR)

Where the General Data Protection Regulation (GDPR) or UK GDPR applies, we are required to identify a lawful basis for each processing activity. We rely on the following legal bases:

  • Performance of a Contract (Article 6(1)(b)): Processing your profile data, communications, requirements, and billing information is necessary to deliver the Platform services you have subscribed to and to fulfil our contractual obligations to you.
  • Consent (Article 6(1)(a)): Where we rely on your consent — such as for marketing communications via Mailchimp or for non-essential cookies and analytics — you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
  • Legitimate Interests (Article 6(1)(f)): We process usage and technical data, conduct fraud detection, perform security monitoring, and improve the Platform on the basis of our legitimate interests in operating a secure and functional service. We have assessed that these interests are not overridden by your rights and freedoms. You have the right to object to processing based on legitimate interests at any time.
  • Legal Obligation (Article 6(1)(c)): We may process and retain certain data where required to comply with applicable law, including tax, accounting, anti-money laundering, and regulatory obligations.

3. How We Use Your Information

We process personal information for the following purposes:

  • To deliver, operate, and continuously improve the Platform and its modules, including Connectivity & Messaging, Profiles & Company Pages, Social Feed, Search, Requirements, and Analytics;
  • To facilitate professional networking, secure communications, and company page engagement among CRE professionals;
  • To power AI-assisted matching and discovery across member requirements and profiles;
  • To generate market analytics and transaction insights;
  • To process payments, manage billing cycles, and administer subscription accounts;
  • To detect, investigate, and prevent fraudulent activity, policy violations, and security incidents;
  • To comply with applicable legal obligations and respond to lawful requests from regulatory or governmental authorities.

Automated Processing and Profiling. We use automated processing, including AI-assisted classification and matching, to organize content and to suggest relevant members, companies, requirements, and market signals. This processing draws on information such as your profile, your CRE Focus (Specialisation, Sector focus, Regional focus, and Strategy focus), your requirements, and your activity on the Platform. The CRE Focus and profile classifications shown on your profile are based on the information you provide and select yourself. This processing is used to improve discovery, relevance, and networking. It does not produce legal effects concerning you or similarly significantly affect you, and we do not make decisions that produce such effects based solely on automated processing without human involvement. You may object to processing carried out on the basis of our legitimate interests, correct your information at any time, and control the visibility of your profile through your settings, as described in Sections 2 and 11.

4. Disclosure of Information

We do not sell, rent, or trade personal information to third parties. We may share information with trusted service providers who process data on our behalf under contractual data processing agreements. These providers fall into the following categories:

  • Infrastructure and hosting providers;
  • Real-time communications providers (notifications, video, and voice);
  • Analytics and monitoring providers;
  • Marketing and communications providers;
  • Payment processing providers.

A current list of the specific sub-processors we engage, together with their function and processing location, is available in our Sub-Processors List, which we update from time to time.

We may also disclose personal information where required by law, court order, or regulatory authority, or where necessary to protect the rights, property, or safety of invest.lease, its users, or the public.

5. Social Login (Google & LinkedIn)

When you choose to authenticate using Google or LinkedIn, we receive only the profile information you have authorized those platforms to share. We do not access your passwords or any data beyond what is necessary for account creation and authentication. Information received through social login is used exclusively for the purpose of verifying your identity and linking your account, and is handled in accordance with this Policy.

6. Cookies and Tracking Technologies

We use cookies, pixel tags, and similar technologies to support Platform functionality, personalize your experience, and gather aggregated usage analytics. We categorize cookies as follows:

  • Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled without impairing core functionality.
  • Analytics Cookies: Used to understand how users interact with the Platform — including pages visited, session duration, and feature usage — through providers such as Google Analytics and Vercel Analytics. These are only set with your consent where required by law.
  • Marketing and Preference Cookies: Used to deliver relevant communications and remember your preferences. These are only activated with your explicit consent.

You may manage your cookie preferences at any time through our cookie consent banner or your browser settings. Disabling strictly necessary cookies will impair your ability to use the Platform, including remaining logged in. Withdrawing consent for analytics or marketing cookies will not affect your access to core features.

7. Data Retention

We retain personal information for as long as your account remains active or as otherwise required to fulfill the purposes described in this Policy. The following general retention periods apply:

  • Account and Profile Data: Retained for the duration of your account and deleted within 90 days of account closure, unless a longer period is required by law.
  • Billing and Transaction Records: Retained for a minimum of 7 years to comply with tax and accounting obligations.
  • Communications and Messages: Retained for the duration of your account. End-to-end encrypted messages are not accessible to invest.lease and are stored solely for delivery purposes.
  • Usage and Technical Logs: Retained for up to 12 months for security monitoring and performance analysis.

Where retention is no longer required or legally justified, we will securely delete or irreversibly anonymize the data.

8. International Data Transfers

invest.lease stores and processes your personal data within the European Economic Area. Certain of our sub-processors (Section 4) may process limited personal data outside the European Economic Area, including in the United States. Where such transfers occur, we apply appropriate safeguards — such as Standard Contractual Clauses approved by the European Commission — to ensure an adequate level of data protection consistent with applicable law.

9. Security

We implement administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These measures include end-to-end and at-rest encryption, role-based access controls, continuous monitoring, and periodic security reviews. Notwithstanding these measures, no data transmission or storage system is entirely secure. Users are encouraged to exercise care when sharing sensitive information and to use strong, unique credentials for their accounts.

10. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, invest.lease will notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach, in accordance with our obligations under GDPR Article 33. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay, describing the nature of the breach, the data affected, the likely consequences, and the measures we have taken or propose to take to address it. In the event of a breach, you may contact us at support@invest.lease.

11. Your Privacy Rights

Subject to applicable law, you may have the right to:

  • Access: Request a copy of the personal information we hold about you;
  • Rectification: Request correction of inaccurate or incomplete data;
  • Erasure: Request deletion of your personal information, subject to legal retention requirements;
  • Restriction: Request that we limit the processing of your data in certain circumstances;
  • Portability: Request a structured, machine-readable copy of your data where technically feasible;
  • Objection: Object to processing based on legitimate interests or for direct marketing purposes;
  • Withdraw Consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

Residents of the European Union and United Kingdom may exercise these rights under the General Data Protection Regulation (GDPR) or UK GDPR. To submit a privacy request, please contact us at support@invest.lease. We will respond within 30 days, or such shorter period as required by applicable law. We may need to verify your identity before processing your request.

You also have the right to lodge a complaint with a data protection supervisory authority. invest.lease's lead supervisory authority is the Commission nationale pour la protection des données (CNPD) in Luxembourg (www.cnpd.public.lu). You may also lodge a complaint with the supervisory authority in your country of residence or place of work.

12. Children's Privacy

The Platform is intended exclusively for use by individuals aged 18 and over. We do not knowingly collect or solicit personal information from anyone under the age of 18. If we become aware that we have inadvertently collected data from a person under 18, we will take prompt steps to delete that information. If you believe a person under 18 has provided us with personal information, please contact us immediately at support@invest.lease.

13. Changes to This Policy

We reserve the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or Platform features. In the event of a material change, we will provide advance notice via a prominent Platform notification or email to the address associated with your account. Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms.

14. Contact

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our privacy team at support@invest.lease.