1. Who We Are
AUNGSHA is a company incorporated under the laws of Bangladesh, operating a real estate share ownership platform ('Platform') called Aungsha that connects retail buyers with carefully selected real estate opportunities. Our registered address is in Dhaka, Bangladesh.
For questions or concerns regarding this Privacy Policy or the handling of your personal data, please contact our Data Protection Officer at: privacy@aungsha. com
2. Information We Collect
2.1 Information You Provide
- Full legal name, date of birth, and national ID (NID) or passport number
- Contact details: email address, mobile number, and residential address
- Financial information: bank account details, mobile banking (bKash/Nagad/Rocket) account information, tax identification number (TIN) if relevant
- Purchase preferences, risk tolerance declarations, and self-certification of financial literacy
- Photographs and supporting KYC (Know Your Customer) documents as required by Bangladesh Bank guidelines
- Communications you send to our support team, including feedback and queries
2.2 Information Collected Automatically
- Device identifiers, IP address, browser type, and operating system
- Usage data: pages visited, features accessed, time spent, click-stream data, and search queries within the Platform
- Transaction data: purchase amounts, property holdings history, and payment logs
- Location data (with your permission) to comply with jurisdiction restrictions and to personalize experience
- Cookies and similar tracking technologies (see Section 9)
2.3 Information from Third Parties
- Identity verification data from government databases, as permitted under relevant Bangladeshi law
- Credit and financial history from authorized credit bureaus (where relevant)
- Data from social login providers (Google, Facebook) if you choose to connect your account
- Real estate developer and property verification data from partner agencies
3. Legal Basis for Processing
We process your personal data on the following legal bases:
- Contractual necessity: to provide the purchase services you signed up for, including processing transactions and managing your property holdings.
- Legal obligation: to comply with the Bangladesh Bank's guidelines on digital financial services, Bangladesh Securities and Exchange Commission (BSEC) regulations, anti-money laundering (AML) laws, and tax reporting requirements.
- Legitimate interests: to prevent fraud, improve platform security, conduct analytics, and develop new product features.
- Consent: for marketing communications, the use of non-essential cookies, and sharing data with affiliate partners. You may withdraw consent at any time.
4. How We Use Your Information
4.1 Platform Operations
- Creating and managing your investor account and profile
- Processing your purchase transactions and maintaining accurate property holdings records
- Verifying your identity and performing KYC/AML checks as required by law
- Communicating with you regarding your account, purchases, and any regulatory matters
- Distributing purchase returns, dividends, or proceeds from property sales
4.2 Compliance and Legal
- Complying with relevant Bangladeshi financial regulations and reporting obligations
- Responding to lawful requests from regulatory authorities, courts, or law enforcement
- Detecting, investigating, and preventing fraudulent transactions or security breaches
4.3 Product Improvement and Marketing
- Analyzing platform usage to improve user experience and develop new features
- Sending you personalized purchase recommendations and property listings (with consent)
- Conducting surveys and research to understand market needs (with consent)
- Sending newsletters, promotional materials, and platform updates (with consent and opt-out)
5. Sharing Your Information
We do not sell your personal data. We may share your information with:
- Regulatory Authorities: Bangladesh Bank, BSEC, National Board of Revenue (NBR), or any other government body as required by law.
- Identity Verification Partners: Third-party KYC service providers to verify your identity and conduct AML screening.
- Payment Processors: Banks and mobile financial service providers (e. g., bKash, Nagad) for processing purchase payments and returns.
- Real Estate Developers: Only the information necessary to facilitate your specific purchase (e. g., your investor registration number for property title purposes). We do not share financial details beyond what is required.
- Technology Providers: Cloud hosting, analytics, cybersecurity, and customer support tools-all bound by data processing agreements ensuring equivalent protection standards.
- Professional Advisors: Legal, accounting, or audit firms, subject to professional confidentiality obligations.
- Business Transfers: In the event of a merger, acquisition, or asset sale, your data may be transferred to the successor entity, and you will be notified in advance.
6. Data Retention
We retain your personal data for as long as your account remains active and for a period of seven (7) years following account closure or the last transaction, in accordance with Bangladeshi financial record-keeping laws. KYC documents may be retained for up to ten (10) years as required by AML regulations. After the relevant retention period, we will securely delete or anonymize your personal data.
7. Data Security
We implement industry-standard technical and organizational security measures to protect your personal data, including:
No system is completely immune to risk. In the event of a data breach materially affecting your rights, we will notify you and relevant authorities in accordance with relevant law.
- 256-bit SSL/TLS encryption for all data in transit
- AES-256 encryption for data stored at rest
- Multi-factor authentication (MFA) for account access
- Role-based access controls limiting employee access to personal data
- Regular security audits, penetration testing, and vulnerability assessments
- Incident response procedures and mandatory breach notification protocols
8. Your Rights
As a user of the Aungsha Platform, you have the following rights regarding your personal data:
To exercise any of these rights, please submit a request to privacy@aungsha. com. We will respond within thirty (30) calendar days.
- Right of Access: Request a copy of the personal data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure: Request deletion of your data, subject to our legal retention obligations.
- Right to Restriction: Request that we limit the processing of your data in certain circumstances.
- Right to Data Portability: Request a machine-readable copy of your data.
- Right to Object: Object to the processing of your data for marketing purposes or based on our legitimate interests.
- Right to Withdraw Consent: Withdraw any previously given consent at any time, without affecting the lawfulness of prior processing.
9. Cookies and Tracking
We use cookies and similar technologies to enhance your experience on our Platform. We use:
You can manage your cookie preferences through your account settings or browser settings. Disabling certain cookies may affect Platform functionality.
- Essential Cookies: Required for the Platform to function (cannot be disabled).
- Analytics Cookies: Help us understand how users interact with the Platform (can be disabled).
- Marketing Cookies: Used to deliver relevant content and track campaign effectiveness (requires your consent).
10. Children's Privacy
The Aungsha Platform is intended exclusively for users who are 18 years of age or older. We do not knowingly collect personal data from individuals under 18. If we discover that a minor has registered, we will promptly delete their account and associated data.
11. Cross-Border Data Transfers
Your data is primarily stored on servers located within Bangladesh. Where we use international cloud or service providers, we ensure that appropriate safeguards are in place, including contractual clauses providing equivalent data protection standards. We will always comply with relevant Bangladeshi laws governing international data transfers.
12. Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email and/or through a prominent in-app notification at least fourteen (14) days before the changes take effect. Your continued use of the Platform after the effective date means your acceptance of the revised policy.