Privacy Policy
KIRCHA SM-REIF PRIVACY POLICY
Any information provided by you while accessing or using the Kircha website (“Website”) or mobile application (“Application”) — both collectively referred to as the “Platform” — shall be handled in accordance with this Privacy Policy (“Privacy Policy”). For the purpose of this document, all other capitalized or uncapitalized terms not specifically defined herein shall have the meaning assigned to them under our Terms and Conditions. This Privacy Policy is issued in accordance with the directives of the Ethiopian Capital Market Authority (ECMA) and the Information Network Security Administration (INSA), and aligns with the standards of the ECMA Regulatory Sandbox Program, under which Kircha SM-REIF currently operates.
1. Applicability & Type of Information Collected
Please read this policy carefully. If you do not agree with our policies or the manner in which we collect and process your information (“Information”), which may include your name, nationality, date of birth, telephone number, email address, IP address, physical address, financial information, or any other data and/or documents submitted by you, you should immediately stop accessing the Platform. Your continued access or use of the Platform shall constitute your acceptance of this Privacy Policy. This policy does not apply to, nor does Kircha Real Estate Investment Fund (Kircha SM-REIF) take any responsibility for, information collected by any third party through any links, integrations, or advertisements on the Platform.
2. Nature and Manner of Collecting Information
During your use of the Platform, Kircha may collect various types of information directly or through authorized third parties. You understand that such information may be collected through your interaction and usage patterns on the Platform. Cookies — text files placed on your device — may be used to collect standard internet log data and visitor behavior information. We may use third-party cookies subject to the terms of those third parties, over which Kircha has no control once you leave the Platform. Advertisements or external links appearing on the Platform may be managed by third-party advertisers who may use cookies or automated tracking technologies to collect web behavioral data. Kircha does not control or assume responsibility for these third-party technologies or their data practices.
3. Purpose and Use of Information Collected
Any information shared on the Platform may be used for purposes based on legitimate business interests, fulfillment of contractual obligations, compliance with applicable Ethiopian laws and regulations, or your consent. Indicative purposes
include: i. Verifying your identity and conducting Know Your Customer (KYC) checks; ii. Creating and maintaining user accounts; iii. Providing access to investment opportunities and related services as per the Terms and Conditions; iv. Sending administrative or transactional communications; v. Informing you about new products, services, or promotional offers that may interest you; vi. Meeting regulatory and compliance requirements of the Ethiopian Capital Market Authority (ECMA), Information Network Security Administration (INSA), or other competent authorities; vii. Data collection, testing, and analysis for compliance and evaluation under the ECMA Regulatory Sandbox Program, ensuring that all information gathered during this phase is treated as confidential and used solely for regulatory and operational testing purposes; viii. Other purposes ancillary to the above. If your consent is required for processing, you may withdraw it at any time by contacting us through the details provided in Clause 7 below. However, withdrawal of consent will not affect the lawfulness of prior data processing and may impact your ability to access certain Platform features or services.
4. Disclosure of Information
Except as otherwise stated herein, Kircha will not disclose your personally identifiable information to any third party without your express consent. In compliance with Ethiopian laws and regulatory requirements, Kircha may share your information with: - Its employees, affiliates, and authorized service providers; - Regulatory bodies such as ECMA, INSA, or financial institutions involved in transaction processing; - Partner banks acting as Trustee or Custodian for Kircha SM-REIF; - Other authorized entities when required by law or under judicial orders. Such disclosures will be made on a “need-to-know” basis and only to the extent necessary for legitimate business or regulatory purposes.
5. Communication and Unsubscription
By accepting this Privacy Policy, you consent to receive communications, including SMS, WhatsApp messages, emails, or phone calls from Kircha and/or its authorized representatives regarding updates, investment opportunities, and promotional offers, even if your number is registered under a do-not-disturb list. You may unsubscribe or opt-out from receiving such communications at any time by following the instructions provided in those communications or by contacting us directly.
6. Data Security & Retention
Kircha is committed to maintaining your data in a secure and confidential manner. Information may be stored or processed on servers located within or outside Ethiopia, in compliance with applicable laws and INSA cybersecurity standards. Kircha ensures that all data collected during the ECMA Sandbox testing phase is handled in accordance with the data protection and confidentiality standards outlined by ECMA and INSA. While we employ reasonable safeguards to protect your data from unauthorized access, alteration, or disclosure, Kircha does not guarantee absolute security. Your data will be retained only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, to comply with sandbox reporting obligations, or as otherwise required by law.
7. Contact Us
If you wish to access, correct, or delete your personal information, restrict its processing, or exercise any other rights available under applicable data protection laws, please contact: Data Protection Officer (DPO) Kircha SM-REIF Email: support@kircha.et Website: www.kircha.et Address: Addis Ababa, Ethiopia Kircha will review and respond to all requests in accordance with applicable data protection and privacy regulations, as well as the guidelines of the ECMA Sandbox Program.
