Privacy Policy

Information We Collect From You

When you visit our website or interact with our services, we may collect various types of personal information. This includes information you provide directly to us, such as your name, email address, phone number, postal address, date of birth, nationality, and passport details when you submit an inquiry or application form. We also automatically collect technical information about your device and browsing activity, including your IP address, browser type, operating system, referring URLs, pages viewed, and the dates and times of your visits. If you communicate with us via email or contact forms, we retain copies of that correspondence along with any information contained within it.

How We Use Your Personal Data

We use the information we collect for several specific purposes related to our citizenship by investment services. Your personal data allows us to respond to your inquiries, process applications, verify your identity and eligibility, conduct due diligence and background checks as required by law, communicate with you about our programs and services, improve our website functionality and user experience, comply with legal and regulatory obligations, prevent fraud and ensure security, and maintain records for administrative purposes. We may also use aggregated, anonymized data for statistical analysis and reporting purposes that cannot identify you personally.

Legal Grounds for Data Processing

We process your personal information based on several legal grounds depending on the nature of our interaction with you. When you submit an application or inquiry, we process your data based on our contractual relationship or steps taken at your request prior to entering into a contract. For compliance with legal obligations — including anti-money laundering regulations, know-your-customer requirements, and government reporting mandates — we process data to fulfill our legal duties. We also rely on our legitimate interests in operating our business, preventing fraud, and maintaining security, provided these interests do not override your fundamental rights and freedoms. In certain circumstances, we may seek your explicit consent for specific processing activities, which you may withdraw at any time.

Disclosure to Third Parties

We may share your personal information with carefully selected third parties who assist us in delivering our services and fulfilling our obligations. These include:

• Government authorities and agencies in Nauru and other relevant jurisdictions for application processing, background checks, and regulatory compliance
• Professional service providers such as legal advisors, accountants, and compliance consultants who assist with due diligence and application processing
• Background check and verification service providers who conduct identity verification and screening
• Technology service providers who host our website, manage our databases, and provide IT support
• Payment processors who handle financial transactions securely
• Other third parties where required by law, court order, or governmental regulation

We require all third parties to maintain appropriate security measures and to process your personal data only as instructed and for the specified purposes.

Cross-Border Data Transfers

Given the international nature of our citizenship by investment program, your personal information may be transferred to, stored in, and processed in countries outside your country of residence, including Nauru and other jurisdictions where our service providers operate. These countries may have data protection laws that differ from those in your jurisdiction. When we transfer your personal data internationally, we implement appropriate safeguards to ensure your information remains protected in accordance with applicable data protection standards. These safeguards may include standard contractual clauses approved by relevant authorities, adequacy decisions, or other legally recognized transfer mechanisms. By providing us with your personal information, you acknowledge and consent to such international transfers where necessary for the purposes described in this policy.

Data Retention Periods

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with our legal, regulatory, and contractual obligations. For application-related data, we typically retain records for a minimum of seven years following the completion or termination of an application, or longer if required by applicable law or regulation. Technical and usage data collected through our website is generally retained for shorter periods unless needed for security or legal purposes. When personal information is no longer required, we securely delete or anonymize it in accordance with our data retention schedule and applicable legal requirements. Certain information may be retained in archived form for historical or statistical purposes in a manner that no longer identifies you personally.

Your Privacy Rights and How to Exercise Them

You have several important rights regarding your personal information, subject to applicable law. These rights include the right to access the personal data we hold about you, to request correction of inaccurate or incomplete information, to request deletion of your data in certain circumstances, to object to or restrict certain types of processing, to withdraw consent where processing is based on consent, and to request a copy of your data in a portable format. You also have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated. To exercise any of these rights or if you have questions about how we handle your personal information, please contact us at [email protected]. We will respond to your request within a reasonable timeframe and in accordance with applicable legal requirements. Please note that certain rights may be limited by legal obligations or legitimate interests that require us to retain or continue processing your information.

Use of Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and understand user behavior. Cookies are small text files stored on your device that allow us to recognize your browser and capture certain information. We use both session cookies, which expire when you close your browser, and persistent cookies, which remain on your device for a specified period. These technologies help us remember your preferences, understand which pages are most popular, identify technical issues, and improve our website's functionality and content. Some cookies are essential for the website to function properly, while others are used for analytics and performance optimization. For detailed information about the specific cookies we use, their purposes, and how you can manage your cookie preferences, please review our comprehensive Cookie Policy. You can control cookies through your browser settings, though disabling certain cookies may affect your ability to use some features of our website.

Security Safeguards We Implement

We take the security of your personal information seriously and have implemented appropriate technical and organizational measures to protect it against unauthorized access, alteration, disclosure, or destruction. Our security measures include encryption of data in transit and at rest using industry-standard protocols, secure server infrastructure with firewalls and intrusion detection systems, regular security assessments and vulnerability testing, restricted access to personal data on a need-to-know basis with authentication controls, employee training on data protection and security practices, and secure backup and disaster recovery procedures. We also require our third-party service providers to maintain comparable security standards. However, please be aware that no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of any passwords or account credentials and should notify us immediately if you suspect any unauthorized access to your information.

Changes and Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other operational needs. When we make material changes to this policy, we will notify you by posting the updated version on our website with a revised "Last Updated" date at the top of the page. For significant changes that materially affect how we collect, use, or share your personal information, we may provide additional notice through email or a prominent notice on our website. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information and your privacy rights. Your continued use of our website and services after any changes to this policy constitutes your acceptance of the updated terms. If you do not agree with any changes, please discontinue use of our services and contact us regarding your personal data.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, we encourage you to contact us. You can reach our privacy team by email at [email protected]. We are committed to addressing your inquiries promptly and working with you to resolve any privacy-related issues. When contacting us, please provide sufficient detail about your question or concern so that we can respond appropriately and efficiently. We aim to respond to all privacy-related communications within 30 days of receipt, though complex matters may require additional time. Your privacy is important to us, and we value the trust you place in us when sharing your personal information.