Privacy Policy

Golden Investment Gateway (“we”, “us”) operates the website at golden-investments.com and the related services (together, the “Service”). The Service is a marketplace that connects investors interested in European residency- and citizenship-by-investment programmes with immigration lawyers, real-estate professionals and startups seeking investment.

For the purposes of the EU General Data Protection Regulation (GDPR), the UK GDPR and similar laws, Golden Investment Gateway is the controller of the personal data described in this policy. You can reach us about anything in this policy at info@golden-investments.com.

Golden Investment Gateway is a marketplace, not a law firm, real-estate agency or investment adviser. Lawyers, agencies and startups listed on the Service are independent businesses. When you contact one of them, they handle your data under their own privacy terms.

We collect only what we need to run the Service. In practice that is:

We do not ask for, and ask you not to upload, government identity documents, passport scans, bank details or other sensitive documents through the Service. Share those directly with the professional you engage, under their own secure process.

We use personal data for the following purposes and on the following legal bases:

• To provide the Service — creating and securing your account, showing your dashboard, publishing listings you choose to publish, and delivering introductions and messages between members. Legal basis: performance of our contract with you.
• To keep the Service safe — verifying sign-ins, preventing fraud and abuse, protecting against account takeover and investigating security incidents. Legal basis: our legitimate interest in running a secure platform.
• To communicate with you — sending account, security and transactional emails such as sign-up confirmations, password changes and notifications that someone has contacted you. Legal basis: performance of our contract and legitimate interest.
• To improve the Service — understanding which programmes, countries and listings are most useful, in aggregate, so we can improve content and features. Legal basis: legitimate interest.
• To comply with the law — responding to lawful requests, enforcing our terms and meeting record-keeping obligations. Legal basis: legal obligation.
• Marketing — if we ever send promotional emails, we will only do so with your consent, and every message will include an unsubscribe link. Legal basis: consent, which you can withdraw at any time.

We do not sell personal data, and we do not use it for automated decision-making or profiling that has legal or similarly significant effects on you.

The Service uses only strictly necessary cookies. We do not use advertising or third-party analytics cookies, so no cookie banner is required.

Your language is detected from your browser’s language settings and the address of the page you visit. No cookie is used to store it. You can block cookies in your browser, but you will not be able to sign in without the session cookie.

We share personal data only in these situations:

• Other members, at your request. When you contact a lawyer, agency or startup through the Service, we pass your name, email address and message to them so they can respond. Anything you publish in a profile or listing is visible to visitors of the Service.
• Sign-in providers. If you sign in with Google or LinkedIn, those companies process your login under their own privacy policies. We receive only the basic profile fields listed in section 2.
• Service providers. We use hosting and database infrastructure, cloud file storage (Amazon Web Services S3) for uploaded photos and attachments, and an email delivery provider for transactional email. These providers act on our instructions under data-processing agreements and may not use your data for their own purposes.
• Legal reasons. If required by law, court order or a competent authority, or to protect the rights, property or safety of Golden Investment Gateway, our members or the public.
• Business transfers. If Golden Investment Gateway is involved in a merger, acquisition or sale of assets, your data may be transferred as part of that transaction. We will notify you before your data becomes subject to a different privacy policy.

The Service is operated from the European Union and aimed at an international audience. Some of our service providers, including Google, LinkedIn and Amazon Web Services, may process data in countries outside the European Economic Area, including the United States.

Where that happens we rely on an adequacy decision of the European Commission or on the European Commission’s Standard Contractual Clauses, together with additional safeguards where needed, so that your data receives a level of protection equivalent to that in the EEA.

• Account and profile data is kept for as long as your account is active. If you delete your account, we remove or anonymise it within 30 days, unless we must keep some of it to meet a legal obligation or resolve a dispute.
• Messages and introductions are kept while both accounts remain active so each party can refer back to them, and are removed when the relevant account is deleted.
• Server logs containing IP addresses are kept for up to 90 days for security and troubleshooting, then deleted or aggregated.
• Backups are rotated on a fixed schedule and fully expire within 90 days of the original data being deleted.

All traffic to the Service is encrypted with TLS (HTTPS). Passwords are hashed with bcrypt and are never stored in readable form. Session tokens are cryptographically signed and stored in cookies that JavaScript cannot read. Access to production systems is limited to staff who need it and is protected by individual credentials.

No system is perfectly secure. If we become aware of a breach that puts your rights at risk, we will notify you and the competent supervisory authority as the law requires.

Depending on where you live, you have some or all of the following rights:

• Access — ask for a copy of the personal data we hold about you.
• Rectification — correct data that is inaccurate or incomplete. You can edit most account details yourself from your dashboard.
• Erasure — ask us to delete your data. You can also delete your account at any time.
• Restriction — ask us to pause processing of your data in certain circumstances.
• Portability — receive the data you gave us in a structured, machine-readable format.
• Objection — object to processing based on legitimate interest, and to any direct marketing at any time.
• Withdraw consent — where processing is based on consent, withdraw it without affecting what was done before.
• Complain — lodge a complaint with your local data-protection authority. A list of EU authorities is published by the European Data Protection Board.

To exercise a right, email info@golden-investments.com from the address linked to your account. We respond within one month, and we may ask you to confirm your identity before acting. Exercising your rights is free, unless a request is manifestly unfounded or excessive.

If you are a California resident, the rights above cover those granted by the California Consumer Privacy Act. We do not sell or share personal information for cross-context behavioural advertising, and we do not discriminate against anyone for exercising their rights.

The Service is intended for adults engaged in professional and investment activity. It is not directed at anyone under 18, and we do not knowingly collect data from children. If you believe a child has given us personal data, contact us and we will delete it.

The Service links to government programme pages, professionals’ own websites and other third parties. We are not responsible for their content or privacy practices. Read their policies before sharing personal data with them.

We may update this policy as the Service and the law evolve. The date at the top shows when it last changed. For significant changes we will notify you by email or with a notice on the Service before they take effect. Continued use of the Service after that date means you accept the updated policy.

Questions, requests or complaints about privacy can be sent to info@golden-investments.com. Please include enough detail for us to identify your account and understand your request.