1. Introduction & Data Processing
Expat Fiduciary (Enterprise Number: 0732.214.594) respects your privacy and is committed to protecting your personal data. This Privacy Policy informs you about how we handle your personal data when you visit our website, contact us via reverse solicitation, or use our administrative introduction services. We process your data in strict accordance with applicable international data protection legislation, including the General Data Protection Regulation (GDPR).
2. The Data We Collect
When you voluntarily contact us for information regarding our platform services or alternative introductions, we may process the following categories of data:
- Identity Data: First name, last name, nationality, and expatriate status.
- Contact Data: Email address, telephone number, and physical residential address.
- Financial Profile Data: Information necessary for statutory self-certification (such as High Net Worth or Sophisticated Investor status).
- Technical & Transactional Data: IP addresses, timestamps, and communication logs (including digital DocuSign verification data).
3. How We Share Your Data (Infrastructure & Distribution)
To perform our role as a transactional facilitator, we share your data exclusively within the following strictly defined operational channels:
- Platform Segment: If you engage our core wealth management services, your identity and compliance documents are processed via Capital Platforms and safely stored within the trading and custody network of Banque de Luxembourg (Moventum S.C.A.).
- Off-Platform Segment: If you explicitly request direct introductions to alternative providers (such as RW Secured Lending Limited / Rudolf Wolff) via reverse solicitation, your completed application forms are sent directly to the administration of the issuing institution and the designated Security Trustee (NWG Trustees Limited).
- International Distribution: We handle the data required for the administrative processing of introduction overrides in strict confidence with our firm and authorised B2B distribution partners. We never sell or lease your personal data to third parties for marketing purposes.
4. Lawful Basis for Processing
We process your personal data exclusively under the following legal grounds:
- Performance of a Contract: To facilitate the administrative processing and transmission of the application documents and brochures you have requested.
- Legitimate Interests: To comply with our internal compliance guidelines, which include keeping an accurate logbook of inbound reverse solicitation requests and DocuSign timestamps to defend against legal claims.
- Legal Obligation: To comply with international KYC (Know Your Customer) and AML (Anti-Money Laundering) procedures as required by our product partners and custodian banks.
5. Security & Data Retention
Your data is stored on secure, encrypted systems to prevent unauthorised access, loss, or theft. Digital transaction certificates (including IP logs of signatures) are securely archived. We do not store your personal data longer than is strictly necessary to achieve the purposes outlined in this policy, or as required under statutory limitation periods for contractual liability.
6. Your Legal Rights
Depending on your physical location and the applicable jurisdiction, you have the right to request access to the personal data we hold about you, to have it rectified, or to request its erasure (insofar as the request does not conflict with our legal obligations to retain transaction documentation). Enquiries or requests regarding your privacy may be submitted directly in writing through our official channels.
This privacy policy was last updated on July 17, 2026.