Privacy Policy
Effective Date: January 2025
Version: 1.0
1. Introduction
21estate SHA ("Company," "we," "our," or "us") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, store, and safeguard your personal information when you use our shareholder platform.
As an Albanian joint-stock company operating in the investment sector (real estate, capital markets, and private equity), we are subject to both Albanian data protection legislation and, where applicable, the EU General Data Protection Regulation (GDPR).
2. Data Controller
21estate SHA
Rr. Pjetër Bogdani, Nd. 10, Hyrja 5, K. 7, Ap. 29
1019 Tiranë, Albania
Email: info@21estate.al
3. Categories of Personal Data We Collect
3.1 Identity Information
Full legal name, date of birth, place of birthNational ID number or passport detailsNationality and citizenship statusParent names (as required by Albanian law)Photograph for profile verification3.2 Contact Information
Email addressMobile and/or landline phone numberResidential address3.3 Financial Information
Bank account details (IBAN, bank name)Investment amounts and share ownership recordsCash account balance and transaction historySource of funds documentation3.4 Technical Information
IP address and device identifiersBrowser type and versionLogin timestamps, session data, and activity logs
4. Purposes of Data Processing
We process your personal data for the following purposes:
Shareholder Registry Management — Maintaining accurate records of share ownership, processing share transfers, and managing the electronic share registryCash Account Administration — Managing your cash account, processing deposits, and facilitating share conversionsLegal and Regulatory Compliance — Fulfilling obligations under Albanian corporate law, tax regulations, and anti-money laundering (AML) requirementsPlatform Access and Security — Providing secure access to your shareholder dashboard and protecting against unauthorized accessShareholder Communications — Sending notices about meetings, dividends, company updates, and investment reports
5. Legal Basis for Processing
We process your personal data under the following legal bases:
Contractual Necessity — Processing required to fulfill our obligations to you as a shareholderLegal Obligation — Processing mandated by Albanian law, including corporate registers, tax reporting, and AML complianceLegitimate Interests — Processing necessary for our legitimate business operations, provided it does not override your rightsConsent — Where you have provided explicit consent for specific processing activities
6. Data Retention
We retain your personal data for the duration of your shareholder status and for a minimum of 10 years following the termination of that status, as required by Albanian corporate and tax legislation.
7. Your Data Protection Rights
Under applicable data protection laws, you have the right to:
Access — Request a copy of your personal dataRectification — Correct inaccurate or incomplete dataErasure — Request deletion of your data (subject to legal retention requirements)Restriction — Limit processing in certain circumstancesData Portability — Receive your data in a structured, machine-readable formatObjection — Object to processing based on legitimate interestsWithdraw Consent — Revoke consent at any time without affecting prior processingTo exercise these rights, contact us at info@21estate.al. We will respond within 30 days.
8. Data Security Measures
We implement robust technical and organizational measures to protect your data:
Encryption of data in transit (TLS) and at restMulti-factor authentication (including TOTP)Role-based access controlsRegular security assessments and monitoringStaff training on data protection
9. Contact Us
For questions, concerns, or to exercise your rights:
21estate SHA
Rr. Pjetër Bogdani, Nd. 10, Hyrja 5, K. 7, Ap. 29
1019 Tiranë, Albania
Email: info@21estate.al