Privacy Policy

Information We Gather

When you visit Sao Tome CBI, we collect certain information automatically through your browser and device. This includes your IP address, browser type, operating system, referring URLs, pages viewed, and the dates and times of your visits. If you contact us through our website forms or email, we collect the personal information you provide, such as your name, email address, phone number, and any other details included in your message or inquiry. We may also collect information about your citizenship investment interests and financial qualifications when you request consultation services.

How We Use Your Information

We use the information we collect for several purposes:

• To respond to your inquiries and provide information about Sao Tome and Principe's citizenship by investment program
• To assess your eligibility and suitability for citizenship investment opportunities
• To improve our website functionality and user experience
• To send you relevant updates about our services and the CBI program, where you have consented to receive such communications
• To comply with legal obligations and prevent fraudulent activity
• To analyze website traffic and usage patterns through analytics tools

Legal Grounds for Data Processing

We process your personal data based on the following legal grounds under applicable data protection laws. When you submit an inquiry or request our services, we process your information to take steps at your request prior to entering into a contract or to perform our contractual obligations. We also process data where we have a legitimate interest in operating our website, improving our services, and communicating with potential clients about citizenship investment opportunities. In some cases, we process data to comply with legal obligations, such as record-keeping requirements or anti-money laundering regulations. Where required by law, we will obtain your explicit consent before processing certain categories of personal information.

Disclosure to Third Parties

We may share your personal information with trusted third parties who assist us in operating our website and delivering our services. This includes technology service providers who host our website, email service providers, analytics platforms, and professional advisors such as lawyers and accountants. When you proceed with a citizenship investment application, we share relevant information with government authorities in Sao Tome and Principe and authorized agents involved in processing your application. We may also disclose your information where required by law, court order, or governmental regulation, or where necessary to protect our legal rights or prevent illegal activity. We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

Cross-Border Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including Sao Tome and Principe 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 personal data internationally, we implement appropriate safeguards to protect your information in accordance with applicable data protection laws. These safeguards may include standard contractual clauses approved by relevant authorities, adequacy decisions, or other legally recognized transfer mechanisms.

Data Retention Periods

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected and to comply with our legal obligations. If you submit an inquiry but do not proceed with our services, we typically retain your contact information and inquiry details for up to three years to respond to any follow-up questions and for our legitimate business interests. For clients who proceed with citizenship applications, we retain relevant documentation for at least seven years following the completion or termination of services, or longer where required by legal, regulatory, or professional obligations. Website analytics and technical data are generally retained for up to two years. When personal information is no longer needed, we securely delete or anonymize it.

Your Privacy Rights and How to Exercise Them

Depending on your location and applicable laws, you may have certain rights regarding your personal information. These rights may include the right to access the personal data we hold about you, the right to request correction of inaccurate information, the right to request deletion of your data in certain circumstances, the right to object to or restrict certain processing activities, and the right to data portability. You also have the right to withdraw consent where we rely on consent as the legal basis for processing. 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. 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

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and understand visitor behavior. Cookies are small text files stored on your device when you visit our website. We use both session cookies, which expire when you close your browser, and persistent cookies, which remain on your device for a specified period. Some cookies are essential for the website to function properly, while others help us improve our services and provide personalized content. For detailed information about the specific cookies we use, their purposes, and how you can manage your cookie preferences, please review our Cookie Policy.

Security Safeguards

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit using SSL/TLS technology, secure server infrastructure, access controls limiting who can view personal information, regular security assessments, and staff training on data protection practices. While we strive to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we continuously review and update our security practices to maintain a high level of protection for your data.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make material changes, we will update the effective date at the top of this policy and may provide additional notice through our website or by email where appropriate. 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 following the posting of changes constitutes your acceptance of those changes.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data 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.