Confidentiality & Privacy Notice
Last updated: October 2025
1. Who We Are
Elma Capital LLC provides international residence and citizenship advisory services. We are committed to protecting your personal information and handling it in a lawful, fair, and transparent manner in line with the EU General Data Protection Regulation (GDPR) and other applicable privacy laws.
2. What Information We Collect
We collect only the data necessary to provide our services or to communicate with you, such as:
- Basic contact details (name, email, phone number)
- Identification and financial data required for compliance checks (KYC/AML)
- Copies of documents you choose to share with us (passports, proof of funds, etc.)
- Records of communication (emails, messages, forms, calls)
- Technical information such as browser type or pages visited, collected through minimal cookies or analytics tools
3. How We Use Your Information
We process your information to:
- Provide advisory and application support services
- Fulfil contractual and pre-contractual obligations
- Meet legal and regulatory duties (for example, anti-money-laundering requirements)
- Improve our website and client communication We never sell or trade your data.
4. Legal Basis for Processing
Depending on the situation, we rely on one or more of the following lawful bases:
- Performance of a contract or steps prior to entering one
- Compliance with legal obligations
- Legitimate interests in operating our business responsibly
- Your consent, where explicitly required (e.g., marketing subscriptions)
5. How We Protect Your Data
All personal data are stored on encrypted servers located within the EU or equivalent-protection jurisdictions. Access is strictly limited to authorized personnel who are bound by confidentiality agreements. We use technical and organizational safeguards to prevent loss, misuse, or unauthorized access.
6. How Long We Keep Data
We retain personal data only as long as necessary for the purpose collected or as required by law—typically three to five years after contract completion or final communication. After that, information is securely deleted or anonymized.
7. Sharing of Information
We may share limited data only with:
- Our internal staff and vetted external partners who assist in processing applications or providing IT support
- Government or regulatory authorities when required by law All third parties are contractually bound to keep data confidential and secure.
8. International Transfers
If any data must be transferred outside the EU (for example, to a partner in another jurisdiction), we ensure adequate safeguards consistent with GDPR Articles 44–49.
9. Your Rights
Under GDPR you have the right to:
- Access, correct, or delete your personal data
- Restrict or object to certain processing
- Request data portability
- Withdraw consent at any time (when consent is the legal basis) To exercise these rights, email us at privacy@second-citizenship.org
- We respond within 30 days in accordance with EU law.
10. Cookies and Analytics
Our website uses a minimal number of cookies for basic functionality and anonymous analytics. You can adjust your browser settings to disable cookies at any time.
11. Updates to This Notice
We may update this notice periodically to reflect legal or operational changes. The current version will always be available on this page. Significant changes will be clearly indicated.
12. Contact Us
If you have any questions, concerns, or requests about how we handle personal data, please contact:
Data Protection Officer
Elma Capital LLC