Confidentiality Policy

We are committed to respecting and protecting your privacy at all times. IMMIGRANT INVEST will not sell, rent, transfer, or otherwise make available to others any information about any person visiting Our Website except as expressly provided for in this Privacy Policy.

The purpose of this Privacy Policy is to:

• Set out the type of personal data IMMIGRANT INVEST will collect from you and how We will use your personal information 
• Set out the basis on which any personal data is processed by IMMIGRANT INVEST
• Make you aware of how IMMIGRANT INVEST will handle your personal data
• Clarify IMMIGRANT INVEST’ obligations under the data protection regulations with regard to processing your personal data lawfully and responsibly
• Inform you of your data protection rights

All processing of Personal Data performed by IMMIGRANT INVEST as envisaged in this Privacy Policy shall be carried out in line with:

• The Maltese Data Protection Act (hereafter referred to as the “DPA” – Chapter 586 of the Laws of Malta) as well as any other subsidiary legislation issued under the DPA as may be amended from time to time;
• Regulation (EU) 2016/679 of The European Parliament And of The  Council of  27  April  2016 On The Protection of Natural Persons With Regard to The Processing of Personal Data And On The Free Movement of Such Data, And Repealing Directive 95/46/EC (General Data Protection Regulation – hereafter referred to as “the Regulation” or “GDPR”).

We will comply with local data protection laws in the jurisdictions We operate in.

This Privacy Policy should be read in conjunction with Our Cookie Policy, and any other Privacy Notices We may provide on specific occasions when We are collecting or processing personal data about you so that you are fully aware of how and why We are using your data.

IMIN Malta Limited (company registration number C 76982), of Malta, is the data controller and is responsible for this Website. 

We are also the data controller of any personal data We collect or receive and process in connection with the Services and/or the Website. Our associated corporate entities may be data controllers of your personal data in their own right, whether jointly or as entirely separate data controllers. 

Contact details

Full name of legal entity: IMIN Malta Limited.

Postal address: 8/2, Portomaso Business Tower, 1 Church Street, St Julian's, STJ 4011, Malta.

Phone number: +356 (277) 811-04

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We have structured Our Website so that you can visit Us on the internet without identifying yourself or revealing any personal information. Once you choose to provide Us with personal information, We will protect such information and use it only in the ways described below.

We will collect and process the following personal data about you:

a) Identity Data, including first name, maiden name, last name, title, identity document number, gender, nationality, employment status, organisation, occupation, e-mail address, and phone number.

To the extent you engage in Our services or where you might apply for a job opportunity, you may be required to provide further information. Where you are a business user, We may also require further information before We enter into a commercial relationship with you.

We may also require you to provide Us with information that might be needed to establish and serve as proof of your identification, such as copies of your passport or national ID card. Where you are a job applicant, you will be required to provide a copy of your up-to-date CV.

Where We are required to collect personal data by law or under the terms of a contract We have with you, and you fail to provide that data when requested, We may not be able to perform the services as agreed, or We may not be able to enter into a contract with you. Still, We will notify you if this is the case at the time. We may have to terminate that contract with you as a result.

b) Contact Data includes billing address, mailing address, email address and contact numbers.

c) Compliance Data (AML and KYC)

Includes the following due diligence information and documentation relating to our clients, or their respective UBO, shareholders, founders, beneficiaries, directors, where a client is a legal person: copy of identity document, ‘KYC’ (database) checks, Politically Exposed Person (PEP) and global sanctions list screenings, documentation establishing Source of Wealth and Source of Funds, and any other documentation which may be mandated from time to time by the Prevention of Money Laundering Act (Chapter 373 of the Laws of Malta) (“PMLA”), the Prevention of Money Laundering and Funding of Terrorism Regulations (“PMLFTR”), the Financial Intelligence Analysis Unit (“FIAU”) and/or any other competent authority or related legislation.

To the extent that copies of identity documents (including passport scans and other government-issued identification) reveal information relating to your racial or ethnic origin or include biometric features used for unique identification (where applicable), such information constitutes a special category of personal data within the meaning of Article 9 of the GDPR. We process such data only where one of the conditions under Article 9(2) GDPR applies, in particular processing which is necessary for reasons of substantial public interest under Union or Maltese law in the area of the prevention of money laundering and terrorist financing, on the basis of the PMLA, the PMLFTR and related legislation.

d) Assistance Data includes the following information about Our clients:

• the client’s situation, plans, interests and targets or objectives;
• the Services requested by and provided to, the client.

e) Financial Data includes the bank account details of the client together with details about any payment methods used by the client to settle Our invoices and, as may be necessary under the particular circumstances, the financial status and creditworthiness of the client.

f) Transaction Data includes details about invoices issued to the client (including date of settlement and means of settlement), payments made to and from the client and any outstanding invoices due by the client.

g) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, as well as other information regarding your experience on Our Website such as page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Location information: We may receive information about your location and may determine your location through your IP address and, when accessing the Website through a mobile device, by using the data that We collect from that device. This includes information about the wireless networks or cell towers near your mobile device at the time of access.

Our Website uses cookies to distinguish you from other users of Our Website. This helps ensure that We provide you with a good experience when you browse Our Website and allows Us to improve it. For detailed information on the cookies We use and the purposes for which We use them, see Our Cookie Policy.

h) Marketing and Communications Data

Includes your preferences in receiving marketing from us and our third parties or associated entities, and your communication preferences. 

Communications data — the content and metadata of your correspondence with us, including messages exchanged by email, telephone, WhatsApp and other messaging channels; call and message timestamps; delivery and read status; the identity of the member of our team handling your matter; and records of any preferences or objections you express about how we contact you.

i) Data Collection Methods

Messaging channels. Where you contact us on WhatsApp or another messaging service, or where you consent to be contacted there, we collect your telephone number, your profile name as displayed by that service, and the content of the correspondence.

Events and downloadable materials. We collect the details you submit when you register for a webinar, request a guide or other downloadable material, or attend an event we organise or take part in.

Referral partners. We may receive your contact details from a business partner who has referred you to us. We accept referred contact details only where the partner confirms it has informed you that your data will be shared with IMIN Malta Limited and has obtained any consent required for that transfer. If you would like to know which partner referred you, write to legal@imin.pro.

You may provide such information in the following circumstances:

• Filling in an enquiry form on the Website,
• Corresponding with Us by post, phone, video calls, e-mail, or otherwise when you apply for Our services,
• Subscribing to Our services or publications,
• Requesting marketing to be sent to you,
• Giving Us some feedback,
• Starting negotiations for or entering into a contract to supply goods and/or services to us.
• Whenever you visit Our Website, We will automatically collect Technical data.
• We may receive personal data about you from various third parties and publicly available sources (Google Analytics advertising features, including Google Analytics, Google AdWords, Facebook Pixel, Google Tag Manager, LinkedIn, and other ad hoc paid media partnerships).
• Identity, contact, and background data from publicly available sources, compliance databases, and/or compliance and due diligence service providers within and outside the EU so We can confirm that you are a suitable client of or supplier to us.
• Communicating with you through the channels you have agreed to, including responding to your enquiries, sending you materials you have requested, keeping you informed about the progress of your matter, and arranging and confirming calls and meetings.

We shall use this information:

• To facilitate the provision of the services that you request and where We need to perform the contract We are about to enter into or have entered into with you,
• Where it is necessary for Our legitimate interests (or those of a third party), and where your interests and fundamental rights do not override those interests,
• Where We need to comply with a legal or regulatory obligation,
• To resolve any issues that you have reported and to provide support-related services,
• To manage the supplier relationship you have with us,
• To administer Our Website and for internal operations, including troubleshooting, and to keep Our Website safe and secure,
• To improve Our Website to ensure that content is presented most effectively for you,
• To ensure that content displayed on the Website is presented in a user-friendly manner.

We shall only process your personal data insofar as this is necessary for Us to provide the services We offer and/or for the purposes indicated in this Privacy Policy.

We may also process your personal data based on any legitimate interest or to comply with any legal obligations. These interests and obligations may include the exercise or defence of legal claims or to comply with an order of any court, tribunal, authority, or disclosure to a government or regulatory entity.

We rely on your consent to send you marketing communications and to contact you through messaging channels such as WhatsApp. Consent is given separately for each channel, is never a condition of receiving any material or service you request from us, and may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal. Electronic marketing communications are also subject to the Maltese Electronic Communications (Personal Data and Protection of Privacy) Regulations (S.L. 586.01) and to equivalent rules in other jurisdictions where they apply.

Generally, We do not rely on consent as a legal basis for processing your personal data. However, where your consent is required, We will provide you with a form requesting explicit consent to do so.

You will receive marketing communication if you have requested such information from Us by providing Us with your details through this Website and have consented and opted-in to receiving such information. Where We have entered a business relationship (namely a contract) with you, We may inform you about Our activities, offers, or other information that We believe would be useful to you in accordance with Our legitimate interest.

Without your explicit consent, we will not share your personal data with any third party for marketing purposes.

**You have the right to withdraw consent or to object to receiving marketing information at any time by contacting **unsubscribe@imin.pro or clicking the unsubscribe button. Once you have withdrawn your consent or object to any one of the purposes listed herein, We will stop sending you any marketing communications. If you choose not to consent or to object to any one of the purposes listed herein or withdraw your consent at any time, We will still be able to provide Our services; however, We will not be able to provide you with the full range of services that We offer, and it may affect the efficiency with which We provide the services you request.

We may disclose your personal data to any of Our international offices or the companies that form part of IMMIGRANT INVEST that may act as joint data controllers or data processors to the company. These offices or companies will be the data controller for your data when you obtain Our services, and/or they may provide administration, controls, and reporting services. All IMMIGRANT INVEST companies respect and protect the security of your personal data in accordance with the applicable law (including the GDPR) and apply security measures and safeguards.

We may need to share personal data with government agencies and authorities in the country where you seek to obtain residence or citizenship. We shall only provide the necessary information to perform services under Our contract with you.

We may be required to share your data with local agents or other service suppliers (in their capacity as data processors), which is necessary for Us to provide the services you request. These local agents and suppliers store and process your data based on strict confidentiality and are subject to the appropriate security measures and safeguards.

We may also share your data with other third parties in their capacity as data controllers, such as legal, tax, real estate, immigration or other advisors and consultants, ( international) banks for payment details, or third parties providing other or additional services or goods to you such as real estate agencies, owners, or developers who you might wish to engage with under separate terms and conditions between you and such third parties. These third parties will process your data in their own right as data controllers, and their data protection policies and processes shall become applicable.

We share personal data with the providers that operate the channels and systems through which we communicate with you and record that communication. These include: Meta Platforms Ireland Limited, which operates WhatsApp — where you have consented to be contacted on WhatsApp, we share your telephone number with WhatsApp in order to deliver our messages, and WhatsApp processes that data in accordance with its own privacy terms; our WhatsApp Business Solution Provider, which transmits messages between our systems and the WhatsApp Business Platform on our behalf; Salesforce, which hosts our client relationship management system and stores records of our correspondence with you; and the providers of our website chat and telephony services. Each of these providers acts as our processor, save for Meta Platforms Ireland Limited in respect of its own operation of the WhatsApp service, and each is bound by a data processing agreement or equivalent contractual safeguards.

We may also disclose or share your data if We are under a duty to do so to comply with any legal obligation or judgment or under an order from a court, tribunal, or authority. We may also disclose your data to enforce Our terms of use or to protect Our rights, property, or safety, that of Our partners or other users of Our Website. This includes exchanging information with other companies and organizations for the purposes of anti-money laundering or KYC checks, compliance with anti-bribery or corruption laws, and/or fraud protection.

Where We share your personal data with internal or external third parties, this may involve transferring your data outside the EEA. We will transfer your personal data in accordance with standard contractual clauses to ensure that your personal data is protected and transferred securely in compliance with applicable laws, including the GDPR.

IMIN Malta Limited acts as the EU data representative of all Our offices located outside the EEA. You may address any issues, queries, or concerns that you may have with IMMIGRANT INVEST by sending an e-mail with “Data protection” in the subject line to the following address: office@imin.pro.

We work closely with third parties to provide you with the services you request on Our Website. These third parties include cloud storage providers, analytics providers, and search engine information providers. We will only work with third-party providers that comply with applicable laws in the jurisdictions in which We operate and abide by the GDPR to protect and safeguard your personal data adequately.

We will ensure that appropriate security measures are taken against unlawful or unauthorized processing of personal data and the accidental loss of or damage to personal data. In addition, We limit access to your personal data to those employees, agents, contractors and other professional third parties who strictly need to know this information. They will only process your personal data on Our instructions and are subject to a duty of confidentiality. All of Our employees and agents have received appropriate training on data protection.

The transfer of information between Our Website and your device is protected with transport layer security (TLS) certificates. When the Website is accessed using compatible browsers, that technology protects personal information using both server authentication and data encryption to ensure that personal information is safe and secure while in transit. 

While we employ strict security measures across all our communication channels, we strongly advise against transmitting highly sensitive personal data, financial information, or comprehensive KYC documentation (such as bank statements or full passport copies) via WhatsApp or other instant messaging platforms. To ensure the highest level of data protection, such documentation should be submitted exclusively through our designated secure portals or directly via encrypted e-mail.

We shall only store your data as long as it is strictly necessary for the purposes for which it was collected. By and large, our retention of your personal data shall not exceed the period of six (6) years from the termination of your engagement with IMMIGRANT INVEST. This retention period enables us to use your personal data for potential AML reporting obligations to the FIAU (a legal obligation) and/or for the assertion, filing or defence of possible legal claims by or against you.

Whenever and to the extent possible, we anonymise the data that we hold about you when it is no longer necessary to identify you from that data.

You are entitled to exercise the following rights under the GDPR (and the equivalent rights under the UK GDPR, where applicable):

1. The right to access information.

2. The right to object.

3. The right to correction (rectification).

4. The right to erasure (“right to be forgotten”).

5. The right to restriction of processing.

6. The right to data portability.

7. The right to withdraw consent.

To exercise any of these rights, please contact legal@imin.pro.

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

For data processed by IMIN Malta Limited as controller, the lead supervisory authority is the Office of the Information and Data Protection Commissioner of Malta (“IDPC”), Level 2, Airways House, High Street, Sliema SLM 1549, Malta, https://idpc.org.mt/.

If you are located in the United Kingdom, you may lodge a complaint with the Information Commissioner’s Office (“ICO”), https://ico.org.uk/.

We do not take decisions concerning you based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you within the meaning of Article 22(1) GDPR.

We do use automated processing for limited purposes such as audience segmentation and the delivery of relevant marketing content through advertising and analytics technologies (including those referred to in our Cookie Policy). Such processing does not produce legal effects on you and is carried out only after you have given your consent through our cookie banner or where it is otherwise permitted by law. You may object to such processing at any time as described in the Marketing section and in our Cookie Policy.

The Website and our marketing services are not directed at minors and we do not knowingly collect personal data from individuals under the age of 16 through the Website without verifiable parental or guardian consent.

Where we provide residence or citizenship advisory services to a family, applications submitted on behalf of minor dependants are processed on the legal basis of performance of a contract (Article 6(1)(b) GDPR) and/or compliance with a legal obligation (Article 6(1)© GDPR) under the relevant immigration legislation. Information about minor dependants (including identity documents, where required by the relevant programme) is collected from the parent or legal guardian, who is responsible for ensuring that they are entitled to provide such information on the minor’s behalf.

We apply the same security and confidentiality safeguards to personal data of minors as we apply to personal data of adults, and we retain such data only for as long as necessary for the purposes of the application and any related legal obligations.

Where our residence or citizenship advisory services involve processing applications on behalf of adult dependents (such as a spouse, parents, or adult children), the primary applicant who submits personal data on their behalf warrants that they have the legal authority or have obtained the explicit, informed consent of those adult family members to share their personal information with us for the purposes outlined in this Privacy Policy.

If you are a California resident, you have specific rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA/CPRA”).

In the past 12 months, we may have collected the categories of personal information described in Section 4 above (Identifiers; Customer records; Commercial information; Internet or other electronic network activity; Geolocation data; Professional or employment-related information) for the business purposes described in this Privacy Policy.

We do not sell your personal information for monetary consideration. To the extent that our use of advertising cookies and similar technologies may be considered a “sale” or “sharing” of personal information under the CCPA/CPRA, you have the right to opt out of such sale or sharing. You can exercise this right by:

• adjusting your cookie preferences via our cookie banner / “Cookie settings” link in the website footer; and/or
• sending a request to legal@imin.pro with the subject line “Do Not Sell or Share My Personal Information”.

California residents also have the right to know what personal information we collect, the right to delete personal information, the right to correct inaccurate personal information, the right to limit use of sensitive personal information, and the right not to be discriminated against for exercising any of these rights.

The Privacy Policy and its subject matter is governed by Maltese law. You hereby agree that the courts of Malta shall have jurisdiction in relation to any claim, dispute or difference concerning the Engagement Letter and any matter arising from it, without prejudice to any mandatory consumer-protection rules that may apply to you in your country of habitual residence.

Any changes we make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you via e-mail.

If you have any questions regarding this Privacy Policy or would like to send us your comments, please contact us via the Contact details set out in Section 3 (“Controller”).