Privacy Policy

1 WHO WE ARE

Ashco Investment Limited is a licensed real estate investment and property sales company. We operate an online platform that facilitates property listings, reservations, purchase agreements, payment management, KYC verification, and corporate membership programmes.

For the purposes of applicable data protection legislation, Ashco Investment Limited is the Data Controller responsible for your personal data.

Contact Details:
Ashco Investment Limited — Data Protection Office
Email: privacy@ashcoinvest.com
Address: As listed on our official correspondence

2 INFORMATION WE COLLECT

We collect personal information in the following categories:

2.1 Information You Provide Directly

• Account Registration: Full legal name, email address, phone number, password, and account type (individual or corporate)
• KYC Verification: Government-issued identification documents (national ID, passport), proof of residential address, photographs, and any supplementary documents required for identity verification
• Purchase & Reservation Information: Property preferences, reservation details, purchase agreements, and related correspondence
• Payment Information: Bank account details, mobile money numbers, and transaction references. We do not store full card numbers on our servers — card transactions are processed through PCI-DSS compliant third-party payment gateways
• Corporate Membership: Business name, registration details, designated contact persons, and membership tier selection
• Communication: Any messages, enquiries, complaints, or feedback you send to us via our contact form, email, or live chat
• Survey Responses: Answers provided through our investment interest survey or any other questionnaires on our platform

2.2 Information We Collect Automatically

When you visit our website or use our platform, we may automatically collect:

• Device Information: IP address, browser type and version, operating system, device identifiers
• Usage Data: Pages visited, time spent on pages, links clicked, referring URLs, and navigation paths
• Cookies and Tracking Technologies: Session cookies, persistent cookies, and similar tracking tools as described in our Cookie Policy
• Transaction Logs: Records of reservations made, payments processed, contracts executed, and platform activity

2.3 Information From Third Parties

We may receive personal information about you from:

• Identity Verification Providers: Third-party KYC and AML compliance services that assist in verifying your identity documents
• Payment Processors: Transaction confirmation and fraud detection information from payment gateway providers
• Referral Partners: Basic contact information where you have been referred to us by an authorised partner or agent
• Publicly Available Sources: Publicly accessible government or company registries, where relevant for due diligence purposes

3 HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

3.1 To Provide and Manage Our Services

• Creating and managing your account on our platform
• Processing property reservations and purchase transactions
• Generating, executing, and managing purchase agreements and contracts
• Processing and tracking payments and payment plans
• Providing access to your member dashboard and portal features

3.2 To Comply With Legal and Regulatory Obligations

• Conducting KYC and AML checks as required by applicable law
• Maintaining records of transactions for the periods required by financial and property regulations
• Responding to lawful requests from government authorities, courts, or regulators
• Reporting obligations under anti-money laundering legislation

3.3 To Communicate With You

• Sending confirmations, receipts, invoices, and contract notifications
• Notifying you of payment due dates, overdue balances, or account alerts
• Responding to your enquiries, complaints, and support requests
• Sending important updates about changes to our Services, Terms, or this Privacy Policy

3.4 To Improve Our Platform and Services

• Analysing usage patterns to improve website functionality and user experience
• Conducting internal research and analytics
• Testing new features and platform updates
• Identifying and resolving technical issues

3.5 For Marketing and Promotional Purposes

• Sending you information about new property listings, investment opportunities, and company news, where you have consented to receive such communications
• Personalising content and recommendations based on your expressed preferences and activity on the platform

You may opt out of marketing communications at any time by clicking the unsubscribe link in any email or by contacting us directly.

3.6 For Security and Fraud Prevention

• Monitoring for suspicious activity, unauthorised access, and fraudulent transactions
• Verifying the identity of users attempting to access sensitive account features
• Maintaining audit logs of platform activity for security purposes
• Protecting the rights, property, and safety of Ashco Investment, our clients, and the public

4 LEGAL BASIS FOR PROCESSING

We process your personal data on the following legal grounds:

• Performance of a Contract: Processing is necessary to fulfil our obligations under your Purchase Agreement, Membership Agreement, or any reservation you have made with us
• Legal Obligation: Processing is required to comply with our obligations under applicable AML, KYC, tax, and property law
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights
• Consent: Where we rely on your consent — such as for marketing communications or optional cookies — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal

5 HOW WE SHARE YOUR INFORMATION

We do not sell your personal data. We may share your information with the following categories of recipients:

5.1 Service Providers and Processors

We engage trusted third-party companies to provide services on our behalf, including:

• Cloud hosting and data storage providers
• Payment gateway and transaction processing providers
• Identity verification and KYC compliance platforms
• Email and SMS communication service providers
• PDF generation and document management services
• Customer support software providers

All service providers are contractually bound to process your data only on our instructions and to implement appropriate security measures.

5.2 Legal and Regulatory Authorities

We may disclose your personal data to government agencies, regulators, law enforcement bodies, or courts where we are required to do so by law or where such disclosure is necessary to protect the rights, safety, or property of Ashco Investment, our clients, or the public.

5.3 Professional Advisers

We may share your information with lawyers, accountants, auditors, and other professional advisers where necessary in connection with the provision of our Services or in the defence of legal claims.

5.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business assets, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and the choices available to you.

5.5 With Your Consent

We may share your information with other parties where you have provided explicit consent for us to do so.

6 DATA RETENTION

We retain your personal data for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

Specific retention periods include:

• Account Data: Retained for the duration of your account and for a period of seven (7) years following account closure, in accordance with applicable record-keeping obligations
• KYC Documents: Retained for a minimum of five (5) years following the completion of a transaction, as required by anti-money laundering regulations
• Transaction and Payment Records: Retained for seven (7) years for tax and financial reporting purposes
• Contract Documents: Retained for the duration of any applicable limitation period under property and contract law
• Marketing Preferences: Retained until you withdraw consent or opt out of communications
• Website Usage Logs: Retained for up to twelve (12) months for security and analytics purposes

When personal data is no longer required, we will securely delete or anonymise it in accordance with our data disposal procedures.

7 YOUR RIGHTS

Depending on your jurisdiction and applicable data protection law, you may have the following rights in relation to your personal data:

7.1 Right of Access

You have the right to request a copy of the personal data we hold about you, along with information about how it is being used.

7.2 Right to Rectification

You have the right to request correction of any inaccurate or incomplete personal data we hold about you.

7.3 Right to Erasure

You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to our legal obligations to retain certain data.

7.4 Right to Restrict Processing

You have the right to request that we limit the processing of your personal data in certain circumstances, for example where you contest the accuracy of the data or object to its processing.

7.5 Right to Data Portability

Where processing is based on your consent or on a contract, you have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format.

7.6 Right to Object

You have the right to object to the processing of your personal data where we rely on legitimate interests as our legal basis, or where your data is used for direct marketing purposes.

7.7 Right to Withdraw Consent

Where we rely on your consent to process your data, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

7.8 How to Exercise Your Rights

To exercise any of the above rights, please submit a written request to our Data Protection Officer at privacy@ashcoinvest.com. We will respond to all verified requests within thirty (30) days. We may require you to verify your identity before processing any data subject request.

8 COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse website traffic, and personalise content. Cookies are small text files stored on your device when you visit our website.

We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the website to function correctly and to maintain your session. These cannot be disabled
• Performance Cookies: Collect anonymous data about how visitors use our website, helping us improve functionality
• Functionality Cookies: Remember your preferences and settings to provide a more personalised experience
• Marketing Cookies: Used to deliver relevant advertisements and track the effectiveness of our marketing campaigns, where you have consented

You may manage your cookie preferences through your browser settings or our cookie consent tool. Please note that disabling certain cookies may affect the functionality of our platform. For more details, please refer to our full Cookie Policy.

9 DATA SECURITY

Ashco Investment implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption of data in transit using SSL/TLS protocols
• Secure storage of sensitive documents and KYC data
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Regular security audits and platform vulnerability assessments
• Secure deletion procedures for data that is no longer required
• Staff training on data protection obligations and best practices

While we take every reasonable precaution to protect your data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security and encourage you to use strong, unique passwords and to notify us immediately of any suspected unauthorised access to your account.

10 INTERNATIONAL DATA TRANSFERS

Ashco Investment primarily operates within Kenya. Where your personal data is transferred to or processed in a country outside your jurisdiction, we will ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection law. This may include the use of standard contractual clauses or transfers to countries recognised as providing an adequate level of data protection.

11 CHILDREN'S PRIVACY

Our Services are not directed at individuals under the age of eighteen (18). We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a minor, we will take prompt steps to delete that information. If you believe we may have collected data from a child, please contact us immediately at privacy@ashcoinvest.com.

12 LINKS TO THIRD-PARTY WEBSITES

Our platform may contain links to third-party websites, payment portals, and external services. This Privacy Policy applies solely to information collected by Ashco Investment and does not cover the privacy practices of any third-party website. We strongly encourage you to review the privacy policies of any third-party sites you visit. We accept no responsibility or liability for the privacy practices of third-party websites.

13 CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or amend this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other factors. Any material changes will be communicated to you via email or through a prominent notice on our platform prior to the change taking effect. The updated policy will be published on this page with a revised effective date. Your continued use of our Services following the publication of any changes constitutes your acceptance of the updated Privacy Policy.

Effective Date: 1 January 2025 | Last Updated: 21 March 2026
Ashco Investment Limited reserves all rights not expressly granted herein.