Agora Privacy Policy

Last Revised: November 15, 2021

Agora Real Estate Technologies Ltd. and its affiliates (“Agora”, “we”, “us”, “us”) respect the privacy of individuals whose information we collect. This privacy policy (the “Privacy Policy”) applies to the Personal Information (defined below) we collect and use in the operation of our website, available at https://www.agorareal.com/ (the “Website”) and in the management of our business, including the provision of our proprietary software platform for management of investment related information and activities (the “Platform”). We provide this Privacy Policy in order to enable you to understand how we collect and process your Personal Information, who we share it with, how we protect it, how long we keep it and your choices with respect to your Personal Information.  

Who are we? 

Agora is a technology company providing information technology and other services to the real estate investment industry. Our customers are investment funds, investment houses, financial institutions and other bodies who manage investments (“Customers”). Our Customers use our Platform to manage investment related information and to provide access to the Platform to their customers who are legal entities (“End-Customers”) in order for such End Customers to view their investments and related information, and to perform various actions related to their investments. 

Whose Personal Information do we process?

We process Personal Information of individuals who browse our Website (“Visitors”).

We also process the Personal Information of individuals who use our Platform and related support, maintenance and other services (the “Services”). You may use our Services if you are either:

In this privacy policy, we describe our privacy practices when obtaining, processing or using Personal Information, in the provision of our Website and Platform and in the provision of our Services. Please read this Privacy Policy carefully, so you can fully understand our practices and your rights in relation to Personal Information. You are under no legal obligation to provide us with any information. If you object to the processing of your Personal Information as described in this Policy, please do not use our Website and/or Platform. 

For more information on the collection and use of your Personal Information by the Customer and End-Customer, please refer to their respective websites and policies. 

Table of Contents  

  1. Definitions
  2. Personal Information we collect 
  3. How we collect Personal Information
  4. The purposes of the collection of Personal Information and legal basis 
  5. Sharing Personal Information
  6. International Data Transfers
  7. Retention and Deletion of Personal Information
  8. Log Files
  9. Analytical Tools 
  10. Information Security 
  11. Minors
  12. Third Party Services
  13. Your Rights
  14. Specific Provisions Applicable Under California Privacy Law
  15. Changes to the Privacy Policy
  16. How to Contact us

1. Definitions

                  “Applicable Laws” means any privacy and data protection laws applicable to our Services including the GDPR, CCPA; each to the extent applicable to the processing of Personal Information conducted by us.

                    “CCPA” means the California Consumer Privacy Act 2018.

                  “GDPR” means the General Data Protection Regulation (EU) 679/2016.

                   “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any natural person or that relates to, describes or can be associated with an identified or identifiable natural person.

                   “Non-Personal Information” means information which does not enable identification of an individual, such as aggregated information about the use of our Website, Platform and services. We may use Non-Personal Information and/or disclose it to third parties without restrictions (for example, in order to improve our Website, Platform and services and enhance your experience with them).

                  “Users” means both Admin Users and End Users. The terms “controller”, “processor”, and “processing” shall have the meanings ascribed to these terms and similar terms in the Applicable Laws.

2. Personal Information we collect

                      2.1 Personal Information we collect about Visitors

                     2.2 Personal Information we collect about Admin Users on the Platform

                     2.3 Personal Information we collect about End Users on the Platform

                     2.4 Agora only processes Personal Information of Users on the Platform as a processor, on behalf of its Customers and in accordance with the Customer's instructions, the terms of the Agreements of such Customers with Agora and our Terms of Use. Users may find more information on the processing of their Personal Information by the Customer/End Customer (investment firm) on their respective websites and policies. 

                      2.5 Non-Personal Information we collect about Visitors and Users

3. How we collect Personal Information 

                     3.1 We collect Personal Information of Visitors as follows: 

                    3.2 We collect Personal Information of Admin Users as follows:

                     3.3 We collect Personal Information of End Users as follows:

4. The purposes of the collection of Personal Information 

                            4.1 Non-Personal Information is collected in order to:   

                           4.2 Personal Information is collected in order to: 

                                             4.2.1 Provide, customize and improve the Website and Services, including to:

                                             4.2.2 Marketing the Services

                                               4.2.3 Corresponding with You

                                               4.2.4 Meeting Legal Requirements and Enforcing Legal Terms

                           4.3 For GDPR-protected individuals, please be informed we conduct each of these activities subject to one of the legal bases such as consent, legitimate interest, fulfilment of a legal obligation. For more information on the specific legal basis for a processing activity, please contact us at: contact@agorareal.com.

5. Sharing Personal Information with third parties

                          5.1 Sharing with the Customer/End Customer and with third parties at their instructions:

                          5.2 Payment providers: 

                          5.3 Third Parties' websites: While using the Website you may encounter links to third party websites. In addition, third parties may provide their own services through the Website. Please be advised that such third party websites and services are independent from the Website, and we assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites and services. We encourage you to carefully read the privacy policies and the terms of use or service of such third party websites and services.

                          5.4 In addition, we may share Personal Information with third parties in the following cases: 

6. International Data Transfers 

                        6.1 We transfer information collected about you, including Personal Information across borders and from your country or jurisdiction to other countries or jurisdictions around the world, in accordance with Applicable Laws, for the purposes listed in Section ‎5 above. If you are an Israeli-based individual by using the Platform, you consent to the transfer of your Personal Information outside of Israel. If you require information about such transfers, please contact us at contact@agorareal.com

                         6.2 With respect to transfers of Personal Information of EU-based individuals:

                         6.3 Internal transfers: Transfers to affiliated entities within our group will be covered by an internal processing agreement entered into by us and our affiliates (an intra-group agreement) which contractually obliges each party to ensure that Personal Information receives an adequate and consistent level of protection wherever it is transferred to. 

7. Retention and Deletion of Personal Information

                        7.1 We will retain or delete your Personal Information as permitted or required by Applicable Laws or as determined in our contract with the Customer/End-Customer.

                       7.2 For more information about your rights relating to your Personal Information, please see Section 12 below. 

                       7.3 To the maximum extent permitted by law, aggregated, de-identified and/or anonymous information derived from your use of the Services may remain on our servers indefinitely and used without restrictions.

8. Log Files

                      8.1 We use log files. We use such information to administer the Website, track users’ movement around the Website, and gather demographic information, resolve technical issues. 

9. Cookies and Analytical Tools

                      9.1 Cookies. We use Cookies (define below) to enhance your User experience, understand your usage of the Website and Services and to perform analytics, we use Cookies. Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. Agora uses cookies, web beacons and similar technologies (“Cookies”). Cookies may also be set by other websites or services that run content on the page you are visiting. The provision of your data via Cookies is voluntary except for those Cookies that Agora places on your device because it is necessary for the performance of the Website or Services. Agora uses “session cookies” and “persistent cookies”. Session Cookies are temporary Cookies that remain on your device until you leave the Website or Services. A persistent Cookie may remain on your device for much longer until you manually delete it.

                       9.2 Use. Cookies can contain information about your browser type, search preferences, data relating to which pages of the Website that you have visited and the date and time of your use. We use Cookies to enable and support security features, prevent fraud, and protect your data from unauthorized access. To enable features and help us provide you with personalized content. To analyze how you use the Website and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how you reached the Website.  You can access our full cookie policy here: www.agorareal.com/cookie-policy.

                        9.3 We use the following cookies on the Website:

10. Information Security 

                            10.1 We have implemented appropriate technical, organizational and security measures designed to protect your Personal Information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

11. Minors

                           11.1 The Services are not available for minors under the age of 18, and therefore Agora does not knowingly collect or process any Personal Information of minors under such age. We encourage parents and guardians to monitor their children’s use of the Internet.

12 Your Rights

                            12.1 If you are a Visitor, and you would like to access, delete, correct or object to the processing of any of your Personal Information processed by us, you may submit a request by sending an email to contact@agorareal.com. Your email should include adequate details of your request. 

                           12.2 According to Applicable Laws, the business which controls your Personal Information and provides it to us is the Customer/End-Customer, as applicable. Agora is a service provider to those entities, acting as a processor/subprocessor; and therefore is not authorized to make any decisions regarding changing or deleting your Personal Information. In particular, we shall comply with a request relating to the access/modification/deletion or any other request relating to your Personal Information, if we are instructed to do so by the Customer/End Customer or other entity which is the controller of the Personal Information in order to comply with a valid request.

                           12.3 If for any reason you wish to delete or modify your Personal Information, please send us an e-mail with adequate detail of your request to contact@agorareal.com, and we will forward your request to the Customer/End Customer; and also provide you with their contact details. We will make reasonable efforts to comply with the lawful instructions of the Customer/End Customer in relation to your requests regarding your Personal Information.

                           12.4 Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

                           12.5 In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

13. Specific Provisions Applicable Under California Privacy Law

                           13.1 California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to contact@agorareal.com. Please note that we are only required to respond to one request per customer each year.

                          13.2 Using an authorized agent. You may submit an application through someone holding a formal Power of Attorney. Otherwise, you may submit a request using an authorized agent only if (1) you provide the authorized agent with written permission to make a request and (2) you verify your own identity directly with us. We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

                          13.3 Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  We do not respond to or honor DNT signals transmitted by web browsers, but we may allow third parties, such as analytics tools providers, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

                           13.4 Deletion Of Content From California Residents: If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Information you have publicly posted. To remove, please send an email to contact@agorareal.com. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

14. Changes to the Privacy Policy 

                          14.1 The terms of this Privacy Policy will govern the use of the Services and any information collected therein. Agora reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the Services.

                         14.2 Changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Services and on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

15. How to Contact us

                        15.1 If you have questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: contact@agorareal.com and we will make an effort to reply within a reasonable time.

You can start using Agora today!