Privacy Policy

Information We Collect From You

When you visit our website or interact with our services, we collect several types of information. This includes personal information you voluntarily provide when filling out inquiry forms, such as your name, email address, phone number, nationality, and any other details you choose to share. We also automatically collect technical information through your browser, including your IP address, browser type and version, time zone setting, operating system, and device information. Additionally, we gather usage data about how you navigate our website, including pages visited, time spent on pages, links clicked, and referral sources.

How We Use Your Information

We use the information we collect for several specific purposes:

• To respond to your inquiries about São Tomé and Príncipe citizenship programs and golden passport opportunities
• To provide you with information, guidance, and consultation services related to citizenship by investment
• To communicate with you via email, phone, or other means regarding your requests and our services
• To improve our website functionality, user experience, and service offerings
• To analyze website traffic and user behavior to better understand our audience
• To comply with legal obligations and protect our legitimate business interests
• To send you marketing communications about related services, where you have consented or where permitted by law

Legal Grounds for Processing Your Data

We process your personal information based on several legal grounds under applicable data protection laws. When you submit an inquiry or request information, we process your data based on our legitimate interest in responding to your request and providing the services you seek. Where we send marketing communications, we rely on your consent or our legitimate interest in promoting our services to individuals who have expressed interest in citizenship programs. For certain processing activities, we may rely on contractual necessity when entering into agreements with you, or legal obligation when required to retain or process data under applicable laws and regulations.

Sharing Information With Third Parties

We may share your personal information with selected third parties in specific circumstances. This includes trusted service providers and partners who assist us in operating our website, conducting our business, and providing services to you, such as hosting providers, email service providers, and customer relationship management platforms. We may also share information with professional advisors, including lawyers, accountants, and consultants who assist in delivering citizenship services. In some cases, we share data with government authorities in São Tomé and Príncipe or other jurisdictions when required for citizenship application processing or legal compliance. We may also disclose information when required by law, court order, or governmental regulation, or to protect our rights, property, or safety. We do not sell your personal information to third parties for their marketing purposes.

International Data Transfers

Given the international nature of citizenship by investment programs, your personal information may be transferred to, stored, or processed in countries outside your country of residence, including São Tomé and Príncipe 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 data internationally, we implement appropriate safeguards to ensure your information remains protected in accordance with this privacy policy and applicable data protection laws. These safeguards may include standard contractual clauses, adequacy decisions, or other legally recognized transfer mechanisms.

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 and regulatory obligations. Generally, we retain inquiry and communication data for up to seven years from the date of last contact, unless a longer retention period is required by law or for legitimate business purposes such as dispute resolution. Technical and usage data is typically retained for a shorter period, usually up to two years. If you become a client, we may retain your information for longer periods as required by citizenship program regulations and legal record-keeping requirements. Once the retention period expires, we securely delete or anonymize your personal information.

Your Privacy Rights and How to Exercise Them

You have several important rights regarding your personal information. Depending on your location and applicable laws, these may include the right to access the personal data we hold about you, the right to request correction of inaccurate or incomplete information, the right to request deletion of your data in certain circumstances, the right to object to or restrict certain types of processing, the right to data portability, and the right to withdraw consent where processing is based on consent. To exercise any of these rights, please contact us at [email protected]. We will respond to your request within the timeframe required by applicable law, typically within 30 days. Please note that certain rights may be subject to limitations or exceptions under applicable law, and we may need to verify your identity before processing your request.

Cookie Usage and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and understand user preferences. Cookies are small text files stored on your device that help us recognize you on subsequent visits and remember your preferences. We use both essential cookies necessary for website functionality and optional cookies for analytics and marketing purposes. For detailed information about the specific cookies we use, their purposes, and how to manage your cookie preferences, please review our comprehensive Cookie Policy. You can control cookie settings through your browser, though disabling certain cookies may affect website functionality.

Security Measures We Implement

We take the security of your personal information seriously and implement appropriate technical and organizational measures to protect it against unauthorized access, alteration, disclosure, or destruction. Our security measures include encryption of data in transit using SSL/TLS protocols, secure server infrastructure with regular security updates and patches, access controls limiting data access to authorized personnel only, regular security assessments and vulnerability testing, and staff training on data protection and security best practices. While we strive to protect your personal information, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. We encourage you to use strong passwords and exercise caution when sharing sensitive information online.

Updates to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices, legal requirements, or service offerings. When we make material changes, we will notify you by updating the "Last Updated" date at the top of this policy and, where appropriate, by posting a notice on our website or sending you an email notification. We encourage you to review this privacy policy periodically to stay informed about how we collect, use, and protect your information. Your continued use of our website and services after any changes indicates your acceptance of the updated policy. If you disagree with any changes, please discontinue use of our services and contact us to request deletion of your information where applicable.

Contact Information

If you have any questions, concerns, or requests regarding this privacy policy or our data processing practices, please contact us at [email protected]. We are committed to addressing your inquiries promptly and working with you to resolve any privacy concerns. If you are not satisfied with our response, you may have the right to lodge a complaint with your local data protection authority or supervisory body, depending on your jurisdiction.