Privacy Policy

Last Updated: October 11, 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 12, 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.
  • Messaging Data: The content of the messages and attachments you exchange; information about your conversations, such as their participants, when messages are sent, delivered and read, and reactions; and your messaging settings, such as read receipts, online presence, and who can message you. For end-to-end encrypted conversations, we store your public encryption keys and the devices you register, but we cannot read the content (see Section 8). For business accounts, we keep a record of each time an administrator views a member's conversations (see Section 8.3).
  • 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.
  • Imported Contacts Data: When you choose to import contacts — from your Google Contacts, by uploading a CSV file, or by entering email addresses manually — we collect the name, email address, and (where available via Google) profile photo of the individuals you identify, solely to help you determine who is already on the Platform and to send an invitation to the contacts you select. Data received from Google is subject to the additional commitments in Section 5.

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, for non-essential cookies and analytics, or for importing your Google Contacts — 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. On the same basis, and in the interest of the people you have corresponded with, we keep the messages you have sent available to the other participants of a conversation, including after your account is closed (see Section 8.4). 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.

Data received from Google APIs, including Google Contacts, is used only for the purposes described in Section 5 and is excluded from the analytics, AI-assisted matching, profiling, and marketing purposes listed above.

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 12. Some of this processing, such as content moderation, post classification, translation, and optional writing assistance, is performed by third-party AI providers acting as our processors (currently OpenAI, Google Cloud Vision, and Google Cloud Translation), as listed in our Sub-Processors List. We use these providers only through their business APIs, under terms that do not permit them to use our data to train their models, and we have disabled data sharing for model training where the provider offers that option. We do not use self-hosted or offline AI models.

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;
  • Artificial intelligence providers (content moderation, classification, translation, and writing assistance).

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.

Within the Platform. Messages are shared with the participants of the conversation in which they are sent. Conversations held through a business account may also be viewed by that account's authorized administrators, as described in Section 8.3.

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. Data received from Google APIs is disclosed only as permitted in Section 5.

5. Social Login and Google User Data

5.1 Social Login (Google and LinkedIn)

When you choose to authenticate using Google or LinkedIn, we receive only the profile information you have authorized those platforms to share. When you sign in with Google, we request the openid, email (userinfo.email), and profile (userinfo.profile) scopes, which provide your name, email address, and profile image. 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, creating and linking your account, and displaying your name and image on your profile, and is handled in accordance with this Policy.

5.2 Google Contacts Import

Data we access. Only if you choose "Import from Google Contacts," we request read-only access to your Google Contacts through the Google People API using the contacts.readonly scope. Through this access we retrieve your contacts' names, email addresses, and profile photos. We do not request or retrieve any other contact fields, and we never create, modify, or delete anything in your Google Contacts.

How we use it. We use this data solely to provide the contacts import feature you requested: to display your contacts to you, to show which of them are already members of the Platform, and to send a Platform invitation to the specific contacts you select. We do not send invitations to contacts you have not selected, and we do not contact your imported contacts for any other purpose.

One-time access. The Google access token obtained for the import is used only to complete that single import. It is not stored or reused, and there is no background synchronization with your Google account. A new import requires you to authorize access again.

Storage and protection. Contact entries with a valid email address are stored as contact records linked to your account only, and are not visible to other users. They are protected by the security measures described in Section 10, including encryption in transit and at rest and role-based access controls.

Sharing. We do not sell Google user data, and we do not share or transfer it to third parties, except (a) to service providers that host and operate the Platform on our behalf under data processing agreements and solely to provide this feature, (b) where necessary to comply with applicable law or to protect against fraud, abuse, or security threats, or (c) as part of a merger, acquisition, or sale of assets, with notice to you.

Restrictions on use. We do not use Google user data to serve advertisements, including retargeting, personalized, or interest-based advertising. We do not use it to build user profiles, for analytics, or for AI-assisted matching or recommendations. We do not use, transfer, or sell Google user data, whether raw, aggregated, anonymized, or derived, to create, train, or improve any artificial intelligence or machine learning model, including foundational or generalized models, whether our own or a third party's. Google user data is never sent to any AI or machine learning service, including the AI providers listed in our Sub-Processors List. We do not allow humans to read this data unless you have given us your express consent to do so for specific data, it is necessary for security purposes such as investigating abuse, it is necessary to comply with applicable law, or the data has been aggregated and anonymized for internal operations.

Retention and deletion. Imported contact records are retained until you remove them from your contact list, until the individual registers on the Platform, or until your own account is deleted, whichever occurs first. You can delete imported contacts at any time from your contact list on the Platform, or ask us to delete them by contacting support@invest.lease. If you are not a Platform user but believe your contact information was imported by another user and would like it removed, you may contact us at the same address.

Revoking access. You can revoke invest.lease's access to your Google account at any time from your Google Account permissions page at https://myaccount.google.com/permissions. Revoking access does not delete contact records already imported; you can delete those as described above.

5.3 Google API Services User Data Policy

invest.lease's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

6. Cookies and Tracking Technologies

We use cookies, pixel tags, local storage, and similar technologies to operate the Platform, remember your choices, understand how the Platform is used, and measure our marketing. Apart from strictly necessary technologies, none of these are activated until you consent to the corresponding category. Data received from Google APIs is never used by or shared with the analytics or advertising technologies described in this section. We categorize them as follows:

  • Necessary: Required for the Platform to function correctly and securely. These support secure authentication, session management, security and fraud prevention, network management, and remembering your cookie consent choice. This category also includes error reporting used to detect and fix faults, which records the technical details of an error rather than your activity. Necessary technologies are exempt from consent and cannot be disabled; without them the Platform cannot be delivered to you, including keeping you signed in.
  • Functional: Enable optional enhancements and personalization, such as remembering non-essential preferences or activating optional third-party features including embedded content, maps, video services, and social sharing. If you do not allow these, some optional functionality may not work as intended.
  • Analytics: Help us understand how visitors interact with the Platform — pages visited, traffic sources, engagement, performance, and usage patterns — through providers including Google Analytics, Vercel Analytics, and Vercel Speed Insights. This category also includes session replay: with your consent, a sample of sessions is recorded by Sentry so that we can reconstruct how a page behaved, including page views, clicks, scrolling, navigation, and other interactions with the interface. Text you enter and media displayed to you are masked in these recordings. Session replay is never enabled unless you consent to Analytics.
  • Advertising: Used to measure our campaigns, understand advertising effectiveness, and provide more relevant advertising based on your interactions with the Platform, through providers such as the LinkedIn Insight Tag. These are only activated with your explicit consent.

When you first visit the Platform we ask you to accept all optional categories, reject them, or choose each one individually. Rejecting is as straightforward as accepting, and no optional technology is loaded before you choose. Your choice is stored in a first-party cookie for approximately six months, after which we ask again. We will also ask again if the purposes described in this section materially change.

You can review or change your choice at any time by selecting Cookie Settings in the Platform menu, or through your browser settings. When you withdraw consent for a category we stop the corresponding activity and delete the related first-party cookies and local storage where technically possible; information already collected while your consent was in effect is handled as described in this Policy. Withdrawing consent for Functional, Analytics, or Advertising 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.
  • Imported Contacts Data: Retained until you remove the contact, until the individual registers on the Platform, or until your account is deleted, whichever occurs first, as described in Section 5.2. Google access tokens used for importing are not retained.
  • Billing and Transaction Records: Retained for a minimum of 7 years to comply with tax and accounting obligations.
  • Communications and Messages: Retained for as long as the conversation exists for at least one of its participants, including after your account is closed, because the other participants continue to rely on it (see Section 8.4). Content kept only for a business account's records, namely messages deleted for everyone and earlier versions of edited messages (see Section 8.3), is deleted 5 years after the message was deleted or edited, or within 90 days of the closure of the business account, whichever occurs first. Records of administrators viewing members' conversations are retained for 5 years.
  • 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. Messaging and Conversations

This section explains how the messages you exchange on the Platform are protected, who can see them, and what happens to them over time. It supplements Sections 1, 4 and 7.

8.1 Encryption

  • End-to-end encrypted conversations: Direct conversations between two personal accounts are end-to-end encrypted. Their content, including attachments, can be read only on the participants' devices; invest.lease cannot read it and stores it solely to deliver it. To make this possible, we store your public encryption keys and the devices you register for encrypted messaging. We still process the information needed to deliver these messages, such as the participants and when messages are sent, delivered and read.
  • Server-encrypted conversations: Group conversations, and any conversation that includes a business account, are encrypted in transit and at rest with keys managed by invest.lease. Our systems process their content to deliver it, to let participants search their conversations, and to provide the business account features described in Section 8.3.

8.2 Participants and Your Choices

  • What participants see: Messages are delivered to, and stored for, every participant of the conversation. Depending on your messaging settings, other participants may also see when you are online or were last active and when you have read their messages, and they may see when you are typing. You can manage read receipts, online presence, and who can message you in your messaging settings.
  • Deleting and editing: You can delete a message for yourself at any time; it remains visible to the other participants. You can delete a message for everyone, or edit it, within 5 minutes of sending it.
  • Clearing, deleting and leaving: Clearing a conversation, deleting it from your list where this option is available, or leaving a group affects your own view only; the other participants keep their copies. Once a conversation contains messages, it is never deleted for all of its participants.

8.3 Business Accounts

When you use the Platform as a member of a company's business account, the conversations you hold through that business account form part of the company's records:

  • Access by administrators: Where the company's subscription includes this feature, the account's super administrators, and members to whom the company has given this permission, may view the conversations held through its business account, in read-only mode. They cannot send, edit or delete messages, or take any other action on your behalf. The conversations of the account's super administrators cannot be viewed in this way. Each access is recorded.
  • Kept records: To preserve the company's records, a message sent through the business account that is deleted for everyone, and the earlier versions of an edited message, remain stored and visible to these administrators, although they are no longer shown in the conversation. Messages a member deletes or clears from their own view also remain visible to them.
  • Your personal account: Conversations held through your personal account are never visible to the administrators of a business account.
  • Corresponding with a business account: If you exchange messages with a business account, those messages also form part of that company's records and may be viewed by its authorized administrators as described above.
  • Responsibility: The company holding the business account decides whether and why its members' conversations are viewed. For this viewing, the company acts as controller and is responsible for informing its members and for having a lawful basis, while invest.lease processes the data on its behalf.

8.4 When an Account Is Closed

Messages you have sent remain part of the conversations of the people you sent them to, who continue to rely on them. When your account is deleted, we delete your personal information, and your messages are shown in their conversations as sent by a deleted user, without your name or photo. Conversations in which no other participant remains are deleted. Messages that form part of a business account's records are kept for that company as set out in Section 7.

9. 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.

10. Security

We implement administrative, technical, and physical safeguards designed to protect your personal information, including data received from Google APIs, against unauthorized access, disclosure, alteration, and destruction. These measures include end-to-end and at-rest encryption, encryption in transit (TLS), 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.

11. 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.

12. 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.

Messages. Messages you have sent also form part of the conversations of the people you sent them to. When we act on a request to erase your data or to delete your account, we delete your personal information, but your messages remain visible to the other participants and are shown as sent by a deleted user (see Section 8.4). We cannot provide the content of end-to-end encrypted messages, which we are unable to read. Requests concerning conversations held through a business account should be addressed to the company holding that account, which is responsible for them; we will assist it in responding.

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.

13. 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.

14. 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. We will not use data received from Google APIs for a new purpose without first notifying you and, where required, obtaining your consent.

15. 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.