Effective date: 1 May 2026 · Last updated: 12 May 2026
1. Data controller
ERAM Real Estate Sh.P.K., a company organised under the laws of the Republic of Kosovo, Business No. (NUI) 812052025, registered 13/06/2023, with registered office at Rruga Agim Ramadani, Nr. 2, 10000 Prishtina, Kosovo ("ERAM", "we", "us") is the controller of your personal data.
For data-protection enquiries: [email protected].
2. Personal data we collect
- Identification: name, date of birth, nationality, government ID (for investor onboarding via the Investors Portal).
- Contact: email, phone, postal address, country of residence.
- Financial: source-of-funds declaration, banking instructions, investment history within ERAM.
- Technical: IP address, browser type, device, cookies (see Cookie Policy).
- Inquiry content: information you provide via contact forms or direct email.
3. Purposes and legal bases
- Responding to inquiries (legitimate interest / consent).
- KYC / AML compliance (legal obligation).
- Performance of subscription contracts (contractual necessity).
- Investor reporting and tax filings (legal obligation).
- Marketing communications, where you have opted in (consent).
- Security, fraud prevention, and platform integrity (legitimate interest).
4. Recipients
We share personal data with: our statutory auditor; legal and tax advisors; KYC/AML service providers; custodian and escrow bank; cloud and IT service providers; and competent authorities where required by law.
5. International transfers
Some service providers may be located outside Kosovo, including within the EU/EEA. Where transfers occur, we rely on appropriate safeguards consistent with EU GDPR principles.
6. Retention
We retain personal data only for as long as necessary for the purposes set out above, then archive or delete it in accordance with applicable law. KYC and investor records are retained for the legally required period after the end of the investor relationship.
7. Your rights
Subject to applicable law, you have the right to access, rectify, erase, restrict, or object to the processing of your personal data, and to data portability. Where processing is based on consent, you may withdraw consent at any time. To exercise your rights, contact us at [email protected].
8. Security
We apply technical and organisational measures appropriate to the sensitivity of the data, including encryption in transit, access controls, and regular security review of the Investors Portal.
9. Updates
We may update this Policy from time to time. Material changes will be notified through the website and, for investors, via the Investors Portal.