Privacy policy

The controller of your personal data is MALI ZANZIBAR LLC, 30 N Gould St, Suite #69784, Sheridan, WY 82801, USA. Contact: contact@mali-zanzibar.com.

Because we are based outside the European Union and offer participations to people in the EU, the EU General Data Protection Regulation (GDPR) applies to how we handle your data. Our representative in the EU is: to be named.

Waitlist. Your email address and, if you choose to give it, an indicative budget range. We use it only to tell you about funding rounds and only after you have confirmed your address by clicking the link in our confirmation email.

Your account. Your email address. There is no password: each time you sign in, we email you a one-time code. We store when your account was created and when you last signed in.

Reserving participations. Your full legal name, date of birth, country of residence, your confirmation that you are not a US person and when you gave it, your typed signature, and the details of each reservation: the property, the number of participations, the price and fee, the payment method you chose, the payment reference, and when you told us that you sent your transfer. We need this to enter into and administer the participation agreement with you.

Sanctions screening. As a US company we may not accept money from people on the US sanctions list (OFAC). When you reserve participations, we compare your name and year of birth with that list and keep a record of the check and its result. The comparison runs on our own servers; your data is not sent to the US authorities. A possible match is never decided automatically: it means a person at MALI reviews your details before your reservation is accepted.

Payments. When your bank transfer arrives, we receive the information your bank sends with it, typically your name, account number and the payment reference. We use it to match the payment to your reservation.

Contact form. Your name, email address, the topic you choose and your message. We receive them as an email and use them only to reply to you.

Using the website. Our hosting provider processes technical data such as your IP address, browser type and the pages you request, so that the site can be delivered and protected against misuse.

Consent (Art. 6(1)(a)) for the waitlist. You can withdraw it at any time with the unsubscribe link in every email.

Contract (Art. 6(1)(b)) for your account, your sign-in codes, your reservations and the administration of your participations, including the checks that you are at least 18 and not a US person.

Legitimate interests (Art. 6(1)(f)) for answering messages you send us through the contact form; for sanctions screening, because US sanctions law binds us and we must not accept funds from sanctioned persons; for keeping records that prove we did so; and for operating and securing the website.

Legal obligation (Art. 6(1)(c)) where EU or member-state law requires us to keep or disclose records.

We use these service providers. Each processes your data only on our instructions under a data processing agreement.

• Supabase, Inc. (USA): database and sign-in. Your account and investment data are stored in Frankfurt, Germany.
• Brevo (Sendinblue SAS) (France): sending our emails, including sign-in codes, waitlist emails and messages from the contact form.
• Vercel Inc. (USA): hosting the website. Our server functions run in Frankfurt, Germany; static pages may be delivered from the server closest to you.

We also share data with our banks, with professional advisers bound by confidentiality, and with authorities where the law requires it. We do not sell personal data and we do not use it for advertising.

MALI is a US company, so the data you give us is processed by us in the United States. Where our service providers process data outside the EU, the transfer is covered by the EU–US Data Privacy Framework where the provider is certified, or otherwise by the European Commission’s standard contractual clauses. You can ask us for a copy of the relevant safeguards at contact@mali-zanzibar.com.

Waitlist: until you unsubscribe. Account: for as long as you have one; you can ask us to close it at any time unless you hold participations. Reservations and participations: for as long as you hold participations and afterwards for as long as tax, accounting and commercial law require. Sanctions screening records: for as long as US sanctions recordkeeping rules require. Contact form messages: for as long as we need them to deal with your request. Technical data: for a short period in our hosting provider’s logs.

We set no tracking or advertising cookies and use no analytics tools. When you sign in, we set a cookie that keeps you signed in; it is strictly necessary for your account to work and is removed when you sign out. Our fonts are hosted on our own servers, so loading the site does not contact third parties such as Google.

Our emails load the MALI logo from our own server. Your email program may therefore tell us that an email was opened. We do not track this.

Data is transmitted encrypted. Access to investor data is restricted at database level, so that each investor can only read their own records, and changes are made only by our servers.

You may ask for access to your data, for correction, deletion, restriction or a copy in a portable format, and you may object to processing based on legitimate interests or withdraw your consent at any time. Email contact@mali-zanzibar.com. You also have the right to complain to a data protection authority, in particular in the EU country where you live.

Participations are only available to people aged 18 or over. We do not knowingly collect data from children.

If we change how we handle your data, we update this page and the date at the top. Material changes we tell you about by email.