Privacy Policy

This Privacy Policy explains how BrickFinance Group OÜ (“BrickFinance”, “we”, “us”, “our”) processes personal data of users who visit the Website or use the Platform. BrickFinance acts as the controller of personal data in accordance with Regulation (EU) 2016/679 (“GDPR”).

1. DEFINITIONS

“User”: A natural person, or a legal person acting through its authorised representative, who visits the Website, registers a User Account, undergoes Verification, or uses Platform functionalities.
“Platform”: The online environment operated by BrickFinance enabling Users to access Funding Rounds and conclude Loan Agreements.
“Loan-Managing Account”: The internal accounting structure used by BrickFinance to record User balances.
“Verification”: The identification and checks performed under AML/CTF legislation.

2. CATEGORIES OF PERSONAL DATA WE PROCESS

2.1 Data provided during registration

Name, email address, password, and country of residence.

2.2 Data provided during Verification

(Required to comply with AML/CTF laws)

Identification document data, Nationality, and Address.
Personal identification number / date of birth.
Verification photos/videos and sanctions/PEP screening results.
Source of funds information (where required).

2.3 Transaction and Platform usage data

Loan-Managing Account balances and Funding Rounds subscribed.
Loan Agreements concluded, repayments, and interest accruals.
History of interactions with the Platform, logs, and timestamps.

2.4 Technical data

IP address, browser and device information, login/security logs, and cookie data.

3. PURPOSES AND LEGAL BASES

Purpose	Legal basis	Description
User registration and access	Contract (GDPR 6(1)(b))	To create and manage the User Account.
Verification (AML/KYC)	Legal obligation (6(1)(c))	To comply with AML/CTF laws and prevent fraud.
Performance of Loan Agreements	Contract (6(1)(b))	To conclude and service Loan Agreements.
Operation of Account	Contract (6(1)(b))	Internal recording of balances and repayments.
Communication	Legitimate interest (6(1)(f))	Operational notifications and Platform updates.
Marketing (optional)	Consent (6(1)(a))	Newsletters if User opts in.
Security & Analytics	Legitimate interest / Consent	Securing Website and performance analysis.

We do not perform automated decision-making or profiling in the sense of GDPR Article 22.

4. DATA OBTAINED FROM THIRD PARTIES

We may receive data from Verification service providers, Payment service providers, and Public databases. These are used strictly for compliance and prevention of unlawful activity.

5. DISCLOSURE OF PERSONAL DATA

We share data with IT/hosting providers, legal advisors, and authorities where legally required. Personal data is never sold to third parties.

6. RETENTION OF PERSONAL DATA

Registration data: As long as the User Account is active.
Verification data: 5 years after the business relationship ends.
Transaction data: Duration of contract + statutory retention periods.

7. USER RIGHTS

Users have the right to access, rectification, erasure, and data portability. To exercise these rights, contact: info@brickfinance.eu

8. CONTACT

BrickFinance Group OÜ
E-mail: info@brickfinance.eu