Privacy Policy

This Privacy Policy explains how ⚠️ [Company Name] (“we,” “us,” or “our”) collects, uses, discloses, and protects personal information obtained from visitors to ⚠️ [Website URL] (the “Website”). This Website provides information about the EB-5 Immigrant Investor Visa program and the process for applying.

By accessing or using this Website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not use this Website.

This Privacy Policy is designed to comply with applicable data protection laws across the jurisdictions in which this Website is accessible, including but not limited to: the European Union General Data Protection Regulation (GDPR), the UK General Data Protection Regulation (UK GDPR), Brazil’s Lei Geral de Proteção de Dados (LGPD), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), Australia’s Privacy Act 1988, and other applicable national and regional privacy laws.

Information We Collect

1.1 Information You Provide Voluntarily

We may collect personal information you voluntarily submit through contact forms, inquiry forms, or email correspondence, including:

• Full name
• Email address
• Phone number
• Country of residence or citizenship
• Any other information you choose to provide

1.2 Information Collected Automatically

When you visit our Website, we or our third-party service providers may automatically collect:

• IP address and approximate geographic location
• Browser type, version, and language settings
• Device type and operating system
• Pages visited, time spent on pages, and navigation paths
• Referring website or source
• Date and time of access
• Cookies and similar tracking technologies (see Section 5)

1.3 Sensitive Information

We do not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health data, biometric data, or financial account details through this Website. Please do not submit such informationthrough general contact forms.

Legal Basis for Processing Personal Data

Depending on your country of residence, we rely on the following legal bases to process your personal information:

• Consent: Where you have provided explicit consent (e.g., newsletter sign-up, submitting an inquiry form).
• Legitimate Interests: To operate and improve our Website, respond to inquiries, and prevent fraud, where these interests are not overridden by your rights.
• Contractual Necessity: Where processing is necessary to take steps at your request prior to entering into an agreement.
• Legal Obligation: Where processing is required to comply with applicable laws.

Note — EU/EEA/UK Residents (GDPR/UK GDPR): You have the right to withdraw consent at any time without affecting the lawfulness of
processing before withdrawal. Our lawful bases for processing are documented and available upon request.

Note — Brazilian Residents (LGPD): Processing is conducted based on the applicable legal hypotheses under Articles 7 and 11 of theLGPD, including consent and legitimate interest.

Note — Canadian Residents (PIPEDA/Provincial Laws): We collect, use, and disclose personal information only with your knowledge and consent, except where required or permitted by law. Quebec residents have additional rights under Law 25.

Note — Australian Residents (Privacy Act 1988): We comply with the Australian Privacy Principles (APPs). You may request access to or correction of your personal information.

Note — Chinese Residents (PIPL): We process personal information in accordance with China’s Personal Information Protection Law. Cross-border transfers comply with applicable requirements.

Note — Japanese Residents (APPI): We handle personal information in accordance with Japan’s Act on the Protection of Personal Information.

Note — South Korean Residents (PIPA): We process personal information in accordance with South Korea’s Personal Information Protection Act.

Note — Indian Residents (DPDP Act): We process personal data in compliance with India’s Digital Personal Data Protection Act 2023.

Note — Middle East / Gulf Residents: Processing complies with applicable national data protection regulations including those of the UAE, Saudi Arabia, Qatar, Kuwait, and Oman.

How We Use Your Information

We use the personal information we collect for the following purposes:

• To respond to your inquiries, questions, and requests
• To provide information about the EB-5 Visa application process
• To send you updates, newsletters, or communications you have requested
• To operate, maintain, and improve our Website
• To analyze Website usage and optimize user experience
• To comply with applicable legal obligations
• To detect, prevent, and address technical issues, fraud, or security breaches
• To enforce our Terms of Use and other agreements

We do not use your personal information for automated decision-making or profiling that produces legal or similarly significant effects.

Disclosure of Your Personal Information

4.1 Service Providers

We may share your personal information with trusted third-party service providers who assist us in operating the Website and delivering services, including web hosting providers, email service providers, analytics platforms, and customer relationship management tools. These providers are contractually obligated to handle your data securely and only as directed by us.

4.2 Legal Requirements

We may disclose your personal information if required to do so by law or in response to valid legal processes, such as a court order, subpoena, or government request, or to protect the rights, property, or safety of our company, our users, or others.

4.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or other business transaction, your personal information may be transferred as part of that transaction. We will notify you via email or prominent notice on our Website of any such change and your choices.

4.4 No Sale of Personal Data

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

Cookies and Tracking Technologies

Our Website may use cookies and similar technologies (pixel tags, web beacons, local storage) to enhance your browsing experience, analyze traffic, and understand user behavior.

5.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Website to function properly. These cannot be disabled.
• Analytics/Performance Cookies: Help us understand how visitors interact with the Website (e.g., Google Analytics).
• Functional Cookies: Remember your preferences and settings.
• Marketing/Targeting Cookies: Used only with your consent to deliver relevant content.

5.2 Your Cookie Choices

You can control cookies through your browser settings or our cookie consent tool (where provided). Disabling certain cookies may affect Website functionality.

Note — EU/EEA/UK Residents: In accordance with the ePrivacy Directive and GDPR, non-essential cookies are only placed after you provide explicit consent via our cookie banner.

Note — Brazil Residents (LGPD): Cookies requiring consent will only be activated upon your agreement.

Note — California: Although this Website is not targeted at US users, California residents who access this site retain rights under applicable law.

International Data Transfers

Your personal information may be transferred to and processed in countries other than your country of residence. We implement appropriate safeguards to ensure that such transfers comply with applicable data protection laws, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission for EU/EEA data transfers
• UK International Data Transfer Agreements (IDTAs) for UK data transfers
• Binding Corporate Rules or other approved transfer mechanisms where applicable
• Adequacy decisions where the European Commission or other regulators have determined the destination country provides adequate protection

Note — EU/EEA Residents (GDPR Articles 44-49): Where we transfer data outside the EU/EEA, we ensure appropriate safeguards are in place. You may request details of the safeguards applied to your data.

Note — Brazilian Residents (LGPD Art. 33): International transfers are conducted only to countries with an adequate level of protection or with appropriate safeguards.

Note — Chinese Residents (PIPL): Cross-border transfers comply with China’s requirements, including security assessments where applicable.

Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. When determining retention periods, we consider:

• The nature and sensitivity of the data
• The purposes for which it was collected and used
• Applicable legal, regulatory, or contractual retention requirements
• Whether the purpose can be achieved through anonymized data

Inquiry and contact form data is generally retained for up to ⚠️ [X] years . Analytics data is retained in aggregated, anonymized form. You may request deletion of your personal data subject to applicable legal requirements (see Section 8).

Your Privacy Rights

Depending on your country of residence, you may have the following rights regarding your personal information:

• Right of Access: Request a copy of the personal information we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure (“Right to be Forgotten”): Request deletion of your personal data, subject to legal exceptions.
• Right to Restrict Processing: Request that we limit how we use your data in certain circumstances.
• Right to Data Portability: Receive your data in a structured, machine-readable format.
• Right to Object: Object to processing based on legitimate interests or for direct marketing.
• Right to Withdraw Consent: Withdraw consent at any time without affecting prior lawful processing.
• Right Not to Be Subject to Automated Decision-Making: Request human review of automated decisions.

8.1 Jurisdiction-Specific Rights

EU/EEA/UK Residents (GDPR/UK GDPR): All rights listed above apply. You have the right to lodge a complaint with your national supervisory authority. UK residents may contact the Information Commissioner’s Office (ICO) at ico.org.uk.

Brazilian Residents (LGPD): You have rights under Art. 18, including confirmation of processing, access, correction, anonymization, blocking, deletion, data portability, and the right to revoke consent.

Canadian Residents (PIPEDA/Law 25): You have the right to access your personal information and challenge its accuracy. Quebec residents have additional rights including the right to de-indexing.

Australian Residents (Privacy Act 1988): You may access and correct your personal information, and lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

Japanese Residents (APPI): You may request disclosure, correction, addition, deletion, or suspension of use of your personal data.

South Korean Residents (PIPA): You have rights to access, correction, deletion, and suspension of processing. Complaints may be filed with the Personal Information Protection Commission (PIPC).

Indian Residents (DPDP Act): You have rights to access information, correction, erasure, and grievance redressal under the Digital Personal Data Protection Act 2023.

UAE Residents: You may exercise rights under Federal Decree-Law No. 45 of 2021 on Personal Data Protection.

Mexico Residents (LFPDPPP): You have ARCO rights (Access, Rectification, Cancellation, and Opposition) under the Ley Federal de Protección de Datos Personales en Posesión de los Particulares.

To exercise any of these rights, please contact us at ⚠️ [Privacy Contact Email] . We will respond within the timeframe required by applicable law (generally 30 days, extendable in certain circumstances).

Children’s Privacy

This Website is not intended for individuals under the age of 18 (or 16 in certain EU jurisdictions, or 13 under other applicable
laws). We do not knowingly collect personal information from minors. If you believe we have inadvertently collected information from a minor, please contact us immediately at ⚠️ [Privacy Contact Email] and we will delete it promptly.

Data Security

We implement technically and organizationally appropriate security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols
• Access controls and authentication procedures
• Regular security reviews and vulnerability assessments
• Staff training on data protection obligations

However, no method of internet transmission or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you and applicable regulatory authorities as required by law.

Third-Party Links

Our Website may contain links to third-party websites, including government immigration websites, law firm websites, and informational resources. We are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policies of any third-party websites you visit.

Do Not Track Signals

Some browsers transmit “Do Not Track” signals to websites. Our Website does not currently respond to these signals. However, you may opt out of analytics tracking and non-essential cookies through our cookie consent tool or browser settings.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the “Last Updated” date at the top of this page and, where required by law, notify you by email or by a prominent notice on our Website.

We encourage you to review this Privacy Policy periodically. Your continued use of the Website after changes take effect constitutes acceptance of the updated Privacy Policy.

Contact Us & Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

EU/EEA Residents: If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local supervisory authority. A list of EU supervisory authorities is available at: edpb.europa.eu

UK Residents: You may contact the Information Commissioner’s Office (ICO) at ico.org.uk or call 0303 123 1113.

Swiss Residents: You may contact the Federal Data Protection and Information Commissioner (FDPIC) at edoeb.admin.ch

Brazilian Residents: You may contact the Autoridade Nacional de Proteção de Dados (ANPD) at gov.br/anpd