Privacy Policy

1. Who We Are

We are a referral-only, membership-based financial services platform, serving an exclusive clientele via invitation only. We collect, store, and use your data to deliver tailored financial strategies, concierge-level services, and curated wealth planning.

2. Eligibility & Scope

Membership is by invitation or referral only. This Privacy Policy applies exclusively to members and prospective members who join our platform through a referral.

3. Information We Collect

We collect sensitive categories of data, including (but not limited to):

● Identity & Government‑issued IDs (e.g. passport, Emirates ID)

● Financial & Asset Data (e.g., bank statements, net worth verification)

● Biometric or Verification Data (if applicable)

● Behavioral Preferences (VIP event preferences, concierge usage)

● Communications (emails, calls, meeting notes)

4. Purposes of Processing & Legal Basis

We process your personal information for:

● Eligibility verification, credential validation via referral

● Delivering bespoke financial services and concierge benefits

● Fraud prevention, AML/KYC compliance, and risk profiling

● Client communication, relationship management, event invitations

● Statutory or regulatory obligations (audit, licensing)

5. Data Sharing

We may share your data with:

● Trusted partners or gatekeepers, e.g., regulatory bodies, secure wealth custodians

● Luxury or concierge providers, under strict NDA terms

● Affiliated firms or auditors only when legally mandated

We never sell or rent your personal data for marketing.

6. Data Retention

We retain data only as long as necessary:

● For regulatory reasons (e.g., anti‑money laundering, KYC), typically 7+ years Wikipedia +14 Fund Solutions +14 Century Wealth +14.

● During active membership or referral evaluation.

● Longer retention may occur in litigation, compliance, or investigation under legal obligations.

7. Security Measures

We deploy robust protection such as:

● AES‑256 encryption at rest and in transit

● Access controls & role-based restrictions

● Annual audits, internal/external security reviews

● Employee training, compliance oversight, and incident response plans

8. Your Rights

Depending on your jurisdiction, you may:

● Access, correct, restrict processing, or request deletion (right of erasure)

● Object to profiling or marketing-based processing

● Withdraw consent (where processing is consent‑based)

● Data portability upon request

● File complaints with supervisory authorities (e.g., DIFC DPA, ICO, GDPR entities)

9. Consent & Notifications

● We obtain explicit consent before collecting sensitive or biometric data.

● You may opt out of marketing communications at any time (but not security-related alerts).

● We will notify you in the event of material changes to this Privacy Policy.

10. International Transfers

Your data may be stored or processed outside your home location:

● Within DIFC-based servers, if applicable

● Offshore secure vaults or trusted financial partners

● Encrypted global cloud infrastructure under strict controls

11. Policy Updates

We reserve the right to update this Privacy & Data Policy as necessary—for legal or operational reasons. Continued membership or use of our services after any update implies acceptance of the revised terms.

Regulatory Compliance