Privacy Policy
Last updated: 14 July 2026 · Version 1.0
This Policy explains how Asset Class Limited, incorporated in Ireland with registered office at Workhub, 51 Bracken Road, Sandyford, Dublin 18, D18CV48 (“Asset Class”, “we”, “us”), handles personal data in connection with the Asset Class mobile application (the “App”), wherever in the world you use it.
1. Two roles
Fund managers as controllers; Asset Class as processor. Your investment data — identity and contact details, KYC/AML documentation, subscriptions, commitments, capital accounts, transactions, and fund documents — is controlled by the fund manager that invited you to the App (“Fund Manager”). We process it on their documented instructions under a data processing agreement. For questions or rights requests about this data, contact your Fund Manager; their privacy notice applies, and we will assist them as the law requires.
Asset Class as controller. We control only the limited data needed to operate and secure the App itself, described below.
2. Data we collect as controller
Account and sign-in data: email/username, tenant identifier, authentication tokens, and sign-in timestamps. Biometric sign-in happens entirely on your device; we never receive biometric data.
Device and technical data: device model, OS and app version, language, time zone, IP address, and a pseudonymous device identifier derived using a keyed cryptographic hash, used solely to recognise trusted devices, route you to the correct Fund Manager environment, and detect suspicious sign-ins.
Push notification tokens issued by Apple or Google if you enable notifications, plus your notification preferences.
Diagnostics: crash logs and performance data. Support: correspondence if you contact us.
We do not collect advertising identifiers, serve advertising, sell personal data, track you across other apps, or use your data for profiling or automated decisions with legal effect.
3. Why we process it
We process this data to provide and administer the App (performance of our contract with you); to secure it, prevent fraud, and fix faults (our legitimate interests, balanced against yours); to send push notifications (your consent, withdrawable at any time in the App or device settings); and to meet legal obligations. Where your local law requires a different or additional basis, we rely on the closest equivalent it provides.
4. Sharing
We share personal data only with: the Fund Manager whose environment you access and its fund administrator; service providers under contract — cloud hosting (e.g., Amazon Web Services, Salesforce), push notification services (Apple, Google), and diagnostics providers (if any); professional advisers and prospective purchasers in a corporate transaction, under confidentiality; and courts, regulators, or law enforcement where legally required. Never for advertising.
5. International transfers
We are based in Ireland and store data primarily in the EU, though some storage and processing may take place in the United States and other countries where our service providers operate. Because the App is available worldwide, data may be transferred to countries other than yours. Wherever the law of your country restricts such transfers, we use recognised safeguards — such as the European Commission’s Standard Contractual Clauses, the EU–US Data Privacy Framework for certified recipients, or the equivalent mechanism under your local law — plus supplementary measures where needed. Contact us for a copy of the relevant safeguards.
6. Retention and security
Upon account deactivation or contract termination, we delete or anonymise account and device data within 60 days, except where retention for a longer period is required to comply with applicable law, to meet regulatory obligations, or to establish, exercise, or defend legal claims. Push tokens are deleted when you disable notifications or sign out; diagnostics are retained for up to 12 months; and support correspondence for up to 24 months. We protect data with encryption in transit and at rest, managed cryptographic keys, OAuth-based authentication, tenant isolation, least-privilege access, and monitoring. If a breach affects you, we will notify you and the relevant authorities where the law requires.
7. Your rights
Depending on where you live, you may have the right to access, correct, delete, or receive a copy of your personal data; to restrict or object to processing; to withdraw consent; and to opt out of the sale or sharing of personal data or targeted advertising (we do neither). We honour these rights for everyone who uses the App, wherever local law grants them, and we will not discriminate against you for exercising them.
To exercise a right, email privacy@assetclass.com. We may need to verify your identity, and where your Fund Manager controls the data concerned we will forward your request to them. We respond within the timeframe your local law requires (for example, one month under the GDPR, 45 days under most US state laws, 30 days under the Australian Privacy Act).
You may also complain to your local data protection authority — including the Irish Data Protection Commission (dataprotection.ie), our lead supervisory authority in the EU, or the Office of the Australian Information Commissioner (oaic.gov.au).
8. Cookies, local storage, and tracking
As a mobile application, the App does not use browser cookies. It may store small amounts of data locally on your device (such as authentication tokens and notification preferences) solely to operate the App. We do not use advertising trackers, cross-app tracking SDKs, or any technology to track your activity outside the App.
9. Children
The App is for investors aged 18 and over. We do not knowingly collect personal data from anyone under 18 and will delete any such data promptly on notice.
10. Changes to this Policy
We may update this Policy from time to time. The current version is always available at assetclass.com/legal/privacy. Material changes will be flagged in the App before they take effect.
Contact
Data controller (section 2 data): Asset Class Limited, Workhub, 51 Bracken Road, Sandyford, Dublin 18, D18CV48, Ireland
Privacy contact: privacy@assetclass.com
