Privacy Policy

I. Information We Collect

Personal information. When you contact us or use our Sites, we may collect the following categories of personal information: name; email address; phone number (including mobile and country code); country of residence; and country of current citizenship. Once you engage PassPro under a written contract for advisory or application services, we collect the further personal information required to process a citizenship by investment application — including but not limited to: full legal name, prior names and aliases, date and place of birth, passport and identity document details, biometric data (photographs and, where required, fingerprints), residential address history, marriage and family information, financial records (bank statements, source-of-funds documentation, tax records), medical records as required by the relevant programme, criminal record information disclosed in public sources, and documented travel history.

Due diligence information. As part of our regulated work, we submit applicant data to third-party screening providers, including World-Check and equivalent services, and to the Citizenship by Investment Units of the Caribbean nations whose programmes we serve. Information returned by these checks — sanctions screening, adverse media, politically-exposed- person status — is processed as part of your application file.

Device and usage information. When you visit our Sites or open our communications (such as emails), some information is automatically collected from the device used to access them, including operating system, browser type and language, access times, device settings, and pages visited. We also collect information about your usage of our Sites using cookies, web beacons, and similar technologies.

Location information. If you use our Sites, we may receive your approximate location (such as city or region) based on your IP address. With your explicit consent, we may receive precise geographic location from your device.

II. How We Use Your Information

We use your information for the following purposes ("Purposes"): to provide advisory and application services; to respond to your enquiries and fulfil your requests; to assess eligibility and conduct internal due diligence before accepting a file; to submit applications and supporting materials to the relevant Citizenship by Investment Unit; to communicate with you about the status of your application; to comply with applicable law, including anti-money- laundering, counter-terrorist-financing, and know-your-client obligations; to operate, secure, and improve our Sites; and as otherwise permitted by applicable law.

Lawful bases for processing (GDPR and UK GDPR). Where GDPR or UK GDPR applies, we rely on one or more of the following lawful bases: performance of a contract with you (Article 6(1)(b)); compliance with our legal obligations (Article 6(1)(c)); our legitimate interests in operating, marketing, and securing our services (Article 6(1)(f)); and, where required, your explicit consent (Article 6(1)(a)). Where we process special categories of personal data (such as health information or data revealing ethnic origin contained in identity documents), we rely on Article 9(2)(a) (explicit consent) or Article 9(2)(g) (reasons of substantial public interest, as required by the regulated framework of citizenship by investment).

Electronic communications. Consistent with the Purposes above, we may communicate with you by electronic message, including email, text, and WhatsApp — to send updates on your application, share programme and policy developments that are likely to be of genuine interest to you, and provide information about PassPro that affects our clients. We follow a no-spam approach.

No automated decision-making. We do not make decisions about you based solely on automated processing. Every application file is reviewed by a senior advisor, and every recommendation and decision involves human judgement.

Aggregated and de-identified information. We may aggregate personal information together with device and location information to produce statistics that cannot be linked to you or any other specific individual, in order to understand how our Sites and services are used and to improve them.

III. How We Share Your Information

a. Government Citizenship by Investment Units

Once you have engaged PassPro under a written contract, we share your information with the Citizenship by Investment Unit ("CIU") of the country whose programme you have selected, and with any authorised due diligence providers the CIU instructs. This sharing is necessary for the CIU to process your application. We share only the information required for the application, on a need-to-know basis.

b. Authorised Due Diligence Providers

We submit applicant data to third-party screening providers — including World- Check and equivalent services — to satisfy the due diligence standards required by every Caribbean CBI programme. These providers are bound by their own confidentiality and data-protection obligations.

c. Professional Service Providers

We share certain information with external service providers acting on our behalf: legal translation providers, document attestation services, courier services required to transmit certified documents, and IT service providers. These parties are bound by written contract not to use your information for any purpose other than the specific service they are providing, and to maintain appropriate security.

d. Legal and Regulatory Disclosures

We may disclose your information to regulatory authorities, courts, government agencies, and other third parties where doing so is required or permitted by applicable law, regulation, or legal process; to defend the legal interests, rights, or property of PassPro or others; or to respond to emergencies.

e. Corporate Transactions

We may disclose or transfer your information to a third party if we sell, transfer, divest, or disclose all or a portion of our business or assets in connection with any merger, financing, acquisition, dissolution, transaction, or proceeding. Any such transfer will be made subject to appropriate confidentiality and data-protection commitments.

f. No Marketing Sharing

We do not share, sell, or licence your personal information to any external marketing, advertising, or soliciting entity, under any circumstances. This is an absolute commitment.

IV. How Long We Keep Your Information

We retain your information only for as long as necessary to fulfil the Purposes described in this Policy and as required by applicable law and the regulated frameworks under which we operate.

Application files. Where you have engaged PassPro for advisory or application services, we retain your complete file for a period of at least seven (7) years from the date of decision on your application, or such longer period as is required by the relevant Citizenship by Investment Unit, by UAE anti-money-laundering legislation, or by any other applicable legal or regulatory framework.

Contact and marketing information. Where you have provided contact details for the purpose of receiving information from PassPro but have not engaged us, we retain your contact data until you ask us to remove it, or until we determine that it is no longer required for the purposes for which it was collected.

De-identified data. Aggregated and de-identified data may be retained indefinitely.

V. Security of Your Information

PassPro implements commercially-reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Sensitive application data is stored on access-controlled systems, transmitted under encryption, and accessed only by personnel whose role requires it. We review our security practices regularly.

No method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security, but we treat the security of your information as a foundational obligation of the firm.

VI. Cookies and Other Tracking Technologies

We collect information about your usage of our Sites using cookies, web beacons, and similar technologies. Some of these are essential to the operation of the Sites; others are analytical or functional. Our Cookie Policy sets out the categories we use, the third parties that may set cookies through our Sites, and how you can control them.

VII. Your Rights Under GDPR and UAE PDPL

Under both the EU and UK GDPR and the UAE Personal Data Protection Law, you have the following rights in respect of your personal information:

• Right of access. You may request confirmation of whether we hold personal information about you, and a copy of that information.
• Right to rectification. You may request that we correct inaccurate or incomplete personal information about you.
• Right to erasure ("right to be forgotten"). You may request that we delete personal information we hold about you, subject to legal or regulatory obligations that may require continued retention (such as anti-money-laundering recordkeeping).
• Right to restriction of processing. You may ask us to limit the way we use your personal information in specific circumstances.
• Right to data portability. You may request that we provide your personal information to you, or to another data controller of your choosing, in a structured, commonly used, machine-readable format.
• Right to object. You may object to our processing of your personal information for direct marketing purposes, or where we rely on our legitimate interests as the lawful basis for processing.
• Right to withdraw consent. Where we process your personal information on the basis of your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal.
• Right not to be subject to automated decision-making. You have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. As noted in Section II, PassPro does not engage in automated decision-making.
• Right to lodge a complaint. You have the right to lodge a complaint with a data protection supervisory authority — the UAE Data Office, or the relevant supervisory authority in the EU member state, the European Economic Area, or the United Kingdom in which you reside.

How to exercise these rights. To exercise any of the rights set out above, please email us at enquiry@passpro.co with "Data Subject Request" in the subject line, or contact us via our contact page. We will respond to your request within thirty (30) days of receipt, in accordance with applicable law. In exceptional cases where a request is complex or where we have received multiple requests from you, we may extend that period by up to a further sixty (60) days, and will let you know if we do.

We may need to verify your identity before responding to a request, in order to protect your information. We do not charge a fee for handling a request unless the request is manifestly unfounded or excessive.

VIII. International Transfers

PassPro operates from the United Arab Emirates and serves clients globally. Processing a citizenship by investment application necessarily involves the transfer of personal information across borders — including to the Caribbean nations whose programmes we serve, to international due diligence providers, and to professional service providers in various jurisdictions.

Where personal information is transferred from the EU, the European Economic Area, or the United Kingdom to jurisdictions that have not been deemed by the relevant authority to provide adequate protection, we put in place appropriate safeguards — including, where required, the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement, or equivalent instruments — to ensure that your information continues to receive the protection of GDPR and UK GDPR.

IX. Minors

PassPro does not knowingly collect personal information from minors as a stand- alone matter. Where minors appear in a citizenship by investment application as qualifying dependants, the personal information of those minors is provided by, and processed under the authority of, the parent or legal guardian who is the main applicant on the file. We process that information only to the extent required to complete the family application, and we treat it with the same care as the information of the principal applicant.

X. Changes to This Policy

Except to the extent limited by applicable law, we reserve the right to update this Policy to reflect changes to our information practices, the regulatory environment, or the services we provide. We will give notice of any material update by prominently posting notice on our Sites and, where required, obtaining your consent. Any update becomes effective immediately on posting and applies to all information collected about you, unless applicable law requires otherwise. We will update the "Last Updated" date at the top of this Policy to reflect any change.

If we make any change that materially affects the way we use personal information previously collected about you, we will obtain your prior consent before that change takes effect.

XI. Contact Us

If you have any questions about this Policy, or about the personal information we hold about you, please contact us:

By email: enquiry@passpro.co

Via our contact page: passpro.co/contact

PassPro is registered in the United Arab Emirates. Full registered office details are available on request.