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In This Document
Instruction
Please read this Privacy Policy carefully. It explains how and why Global Citizenship Partners Limited collects, uses, and protects your personal data when you visit our website at globalcitizenshippartners.com (the ‘Website’) or engage us to provide citizenship by investment advisory services.
Who We Are
Please read this Privacy Policy carefully. It explains how and why Global Citizenship Partners Limited collects, uses, and protects your personal data when you visit our website at globalcitizenshippartners.com (the ‘Website’) or engage us to provide citizenship by investment advisory services.
For the purposes of applicable data protection law, including the General Data Protection Regulation (EU) 2016/679 (‘GDPR’) and the UK GDPR, Global Citizenship Partners Limited is the data controller responsible for your personal data.
Registered Company Details
A — The Personal Data We Collect
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1. Information You Provide Directly
When you contact us, submit an enquiry, or engage our services, we collect the following categories of personal data:
Contact and identity information: your name, salutation, nationality, country of residence, email address, and telephone number.
Enquiry information: details of the programme or service you are interested in, your family situation, investment budget range, and primary motivation for seeking alternative citizenship.
Marketing preferences: your consent preferences regarding communications from us.
Application-related information: where you engage our services, we will collect additional information required to prepare and submit a citizenship application on your behalf. This includes copies of identity documents (passport, national ID card), police certificates, financial documentation, and other materials as required by the relevant government programme. We will provide a separate privacy notice at the point of engagement covering this extended data processing.
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2. Information We Collect Automatically
When you visit our Website, we automatically collect certain technical data, including:
Your IP address and general geographic location.
Browser type, version, and device type.
Pages visited, time spent on pages, and navigation paths through the Website.
Referring URLs and clickstream data.
This data is collected through cookies and similar technologies. Please refer to our Cookie Policy for full details.
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3. Information From Third Parties
We may receive information about you from third-party sources in the following circumstances:
From referral partners, introducers, or professional advisors who recommend our services to you.
From publicly available sources and compliance databases, where we are required to conduct due diligence checks prior to onboarding you as a client.
From analytics providers, as described in our Cookie Policy.
B — How We Use Your Personal Data
We use your personal data for the following purposes:
Consent: Where you have given explicit consent, specifically in relation to receiving marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.
To assess your eligibility for citizenship by investment programmes and to provide tailored advisory recommendations.
To prepare, submit, and manage your citizenship application on your behalf, where you engage our services.
To conduct pre-engagement due diligence and Know Your Customer (KYC) checks as required by applicable law and programme regulations
To send you marketing communications where you have consented to receive them, or where we have a legitimate interest in keeping you informed of programme developments relevant to your enquiry.
To administer and improve our Website.
To comply with legal and regulatory obligations.
C — Legal Basis for Processing
We process your personal data on the following legal bases under the GDPR:
Contractual necessity: Where processing is required to perform our advisory services under a contract with you, or to take steps at your request prior to entering into a contract.
Legitimate interests: Where processing is necessary for our legitimate business interests, including responding to enquiries, conducting due diligence, maintaining our client relationships, and improving our Website — provided these interests are not overridden by your rights and interests.
Legal obligation: Where processing is required to comply with applicable law, including anti-money laundering regulations, KYC obligations, and programme-specific agent requirements.
Consent: Where you have given explicit consent, specifically in relation to receiving marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.
D — Marketing Communications
We will send you marketing communications — including programme updates, news, and event invitations — only where you have consented to receive them, or where we have an existing client relationship and a legitimate interest in keeping you informed.
You may opt out of marketing communications at any time by clicking the unsubscribe link in any email we send, or by contacting us at: privacy@globalcitizenshippartners.com Opting out of marketing will not affect our ability to communicate with you in relation to an active service engagement.
E. Disclosure of Your Personal Data
We may share your personal data with the following categories of recipients:
Government bodies and programme administrators: We are required to share your personal data with the Citizenship by Investment Unit (Antigua and Barbuda) and/or the Nauru Program Office as part of the application process. We share only what is necessary for the programme application.
Professional service providers: Where necessary to deliver our services, we may share data with legal advisors, compliance professionals, document certification services, and banking institutions.
Technology and service providers: We work with third-party providers for website hosting, analytics, CRM, and email communication. These providers act as data processors and are required to handle your data securely and in accordance with our instructions.
Referral partners and introducers: Where you have been referred to us, we may confirm to the referring party that we have made contact, but we will not share detailed personal or application information without your consent.
We do not sell, rent, or otherwise transfer your personal data to third parties for their own marketing or commercial purposes.
F — International Data Transfers
Given the international nature of our services, your personal data may be transferred to and processed in countries outside your country of residence, including Antigua and Barbuda, Nauru, and the countries where our professional partners and technology providers operate.
Where we transfer personal data outside the European Economic Area (EEA) or the United Kingdom, we ensure that appropriate safeguards are in place, including the use of standard contractual clauses approved by the European Commission, or other legally recognised transfer mechanisms. We will provide further information on the specific safeguards applicable to any transfer upon request.
G — Data Security
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, destruction, or alteration. These measures include:
Transport Layer Security (TLS) encryption for all data transmitted between your device and our Website.
Secure server environments protected by firewalls and access controls.
Restricted access to personal data, limited to staff members with a legitimate need to process it.
Confidentiality obligations for all staff with access to client data.
No method of electronic transmission is completely secure. While we take all reasonable steps to protect your data, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by applicable law.
H — Data Retention
We retain your personal data only for as long as is necessary for the purposes for which it was collected, or as required by law. Our standard retention periods are as follows:
Enquiry data where no engagement follows: up to 24 months from the date of last contact.
Client application data: up to 10 years from the completion or termination of our services, to enable us to fulfil legal obligations including anti-money laundering record-keeping requirements and to defend potential legal claims.
Website analytics data: as determined by our analytics providers, and for no longer than 26 months.
After the applicable retention period, personal data is securely deleted or anonymised.
I — Your Rights as a Data Subject
Subject to applicable law, you have the following rights in relation to your personal data:
Right of access: You may request a copy of the personal data we hold about you.
Right to rectification: You may request that inaccurate or incomplete personal data be corrected.
Right to erasure: You may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other legal basis applies.
Right to restriction: You may request that we restrict our processing of your data in certain circumstances.
Right to data portability: You have the right to receive your personal data in a structured, machine-readable format and to transmit it to another data controller.
Right to withdraw consent: Where we rely on your consent as the legal basis for processing, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
To exercise any of these rights, please contact us at [privacy@globalcitizenshippartners.com]. We will respond within 30 days. We may need to verify your identity before processing your request.
Right to object: You may object to our processing of your personal data where we rely on legitimate interests, or where we process your data for direct marketing purposes.
J — Complaints
If you have concerns about how we handle your personal data, please contact us in the first instance at: privacy@globalcitizenshippartners.com. We will investigate and respond to all complaints promptly.
If you are located in the United Kingdom or the European Economic Area and remain dissatisfied with our response, you have the right to lodge a complaint with the relevant data protection supervisory authority. In the UK, this is the Information Commissioner’s Office (ico.org.uk). In the EU, you may contact the supervisory authority in your country of residence.
K — Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, the services we offer, or applicable law. We will post any updated version on this page with a revised ‘Last updated’ date. Where changes are material, we will notify active clients by email.
L — How to Contact Us
For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact us: