Privacy Policy & Data Handling

Placeholder draft — replace bracketed items with your real entity/contact details and have this reviewed by your compliance/legal team before publish, same as the services pages.

The FATCA/CRS tool

The 5-question tool runs entirely in your browser. Your citizenship, residency, and account-country answers are used only to compute your result on this page — they are not sent to any server, logged, or stored by this tool itself. Refreshing or closing the page clears your answers.

Consultation requests

If you choose to book a consultation via the form on our services page (or its Dutch equivalent), we collect the contact details and information you voluntarily provide in that form (e.g. name, email, phone, a description of your situation). This is a separate, clearly-marked step from the tool — using the tool does not automatically send anything to us. The form is processed by Web3Forms, a third-party form-delivery service, which transmits your submission directly to our email inbox; Web3Forms does not itself store your data beyond what's needed to deliver the message. Data submitted through the consultation form is used solely to respond to your enquiry and, if you proceed, to deliver our services, and is retained only as long as necessary for that purpose or as required by our own regulatory record-keeping obligations as a licensed CSP.

Cookies & analytics

[Disclose your actual analytics/cookie setup here — e.g. "We use [analytics tool] to understand aggregate site usage. No personally identifying information from the tool's question flow is included in analytics events."] A cookie consent banner is shown to EU/UK visitors per GDPR/ePrivacy requirements.

Data controller & legal basis

The data controller for information submitted through the consultation form is [Legal Entity Name], licensed in [jurisdiction]. We process this data on the basis of your consent (given via the checkbox on the form) to respond to your enquiry, and — if you proceed with our services — on the basis of contract performance and our own regulatory record-keeping obligations as a licensed CSP under [applicable AML/KYC framework].

Retention

Consultation-form data that doesn't lead to a client relationship is retained for [X months/years — set the real period] before deletion. Where a client relationship is established, records are retained for [X years] per our regulatory record-keeping obligations under [applicable AML/KYC framework], after which they are deleted or anonymized.

International data transfer

The consultation form is processed by Web3Forms, a US-based form-delivery service. Submitting the form may involve your data being transmitted to and briefly processed on servers outside the EEA/UK before reaching our inbox. [State the actual safeguard once confirmed — e.g. Standard Contractual Clauses, or a data processing agreement with Web3Forms — rather than leaving this unaddressed.]

Your rights (GDPR)

If you're in the EU/EEA or UK, you have the right to:

• Access — request a copy of the personal data we hold about you.
• Rectification — correct inaccurate or incomplete data.
• Erasure — request deletion of your data, subject to our regulatory retention obligations above.
• Restriction — request that we limit processing of your data in certain circumstances.
• Objection — object to processing based on legitimate interest.
• Data portability — request your data in a portable format, where technically feasible.
• Lodge a complaint — with your national data protection supervisory authority (in the Netherlands, the Autoriteit Persoonsgegevens; elsewhere in the EEA/UK, your own national authority) if you believe your data has been mishandled.

Contact us at [privacy contact email] to exercise any of these rights. The tool itself holds nothing to request — see "The FATCA/CRS tool" above.

Contact

[Legal Entity Name], licensed in [jurisdiction]. Privacy enquiries: [email].