1. Who we are
Fulcrum Advisory FZE ("Fulcrum", "we", "us") is a company established in the Ajman Free Zone, United Arab Emirates, under licence number 47264, with its registered address at Office C1-1F-SF13223, Ajman Free Zone C1 Building, Ajman Free Zone, United Arab Emirates.
Fulcrum is the controller of the personal data described in this policy. This means we decide why and how your personal data is processed, and we are responsible for it.
For any privacy question or request, contact us at fulcrumadvisoryfze@proton.me or on WhatsApp at +971 50 871 9210.
2. Which laws apply
As a UAE company, we process personal data in line with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the "PDPL") and its implementing regulations, supervised by the UAE Data Office.
Our clients and website visitors live in many countries, so we apply the same high standard to everyone and also respect the privacy laws that apply to you where you live, including, where applicable:
- the EU General Data Protection Regulation (GDPR), including in Portugal;
- the UK GDPR and the UK Data Protection Act 2018;
- the Australian Privacy Act 1988 and the Australian Privacy Principles;
- Indonesia's Personal Data Protection Law (Law No. 27 of 2022) for our work in Bali;
- Brazil's General Data Protection Law (LGPD), and other local laws that apply to you.
Where these laws give you stronger rights or protections than this policy describes, those rights apply to you.
3. Data we collect
Information you give us
- Contact details: your name, email address, phone or WhatsApp number.
- Assessment answers: your goals, where you are based, your profile, an approximate range of capital you could deploy, and your timeline.
- Consultation information: what you tell us in messages, calls and strategy sessions about your business, finances, family, plans and preferences.
- Client documentation (only if you become a client and only what each service requires): identity documents such as passports and photographs, proof of address, business and ownership documents, source of funds and source of wealth information, and details of family members included in a residency application.
- Payment information: when you pay for a session or package. Card payments are handled by our payment provider; we do not see or store your full card details.
Information collected automatically
- Technical data: when you visit our website, our hosting provider receives your IP address, browser type and the pages requested, as part of normal website operation. Our fonts are hosted on our own website, so no font provider receives your data.
- Analytics data: if you consent to analytics or advertising cookies, information about how you use our website (see section 7).
Information from others
With your knowledge, we may receive information about you from people who refer you to us, and from partners working on your matter, such as licensed advisers, banks, corporate service providers and government authorities.
Sensitive information
We do not seek sensitive personal data such as health, religious, political, biometric or criminal-record information. Where a residency, banking or citizenship process legally requires it (for example a police clearance certificate or medical test), we process it only with your explicit consent, only for that process, and with extra care.
4. How and why we use it
| Purpose | Legal basis |
|---|---|
| Replying to your enquiry, assessment or WhatsApp message | Your consent, and steps you request before entering a contract |
| Booking and delivering strategy sessions and packages | Performance of our contract with you |
| Preparing residency, company, banking, citizenship and investment introductions | Performance of our contract, and your consent for each disclosure to a partner |
| Identity, anti-money-laundering and know-your-customer checks | Compliance with our legal obligations |
| Invoicing, accounting and record-keeping | Compliance with our legal obligations |
| Improving our website and services | Your consent (for analytics cookies) or our legitimate interests |
| Sending you updates and marketing | Your consent, which you can withdraw at any time |
| Protecting our rights and handling disputes | Compliance with legal obligations and our legitimate interests |
We do not sell your personal data, and we do not use it for any purpose that is incompatible with the purposes above.
6. International transfers
Our work is international by nature, so your data may be transferred outside your country, including to and from the UAE, Indonesia, the European Union, Switzerland, the United Kingdom, Australia and the United States, where our partners and service providers operate.
We make these transfers only as permitted by the PDPL and the laws that apply to you: to countries with adequate data protection, under contractual safeguards such as standard contractual clauses, where the transfer is necessary to perform our contract with you, or with your consent.
8. How long we keep it
- Enquiries and assessments that don't become clients: up to 24 months after our last contact, unless you ask us to delete them sooner.
- Client records: for the length of our relationship and then for as long as UAE law requires, including anti-money-laundering and commercial record-keeping rules, which can require at least five years after the relationship ends.
- Marketing: until you unsubscribe or withdraw consent.
When data is no longer needed, we delete or anonymise it securely.
9. How we protect it
We use technical and organisational measures appropriate to the sensitivity of the data, including encrypted email, encrypted connections (HTTPS) on our website, access limited to the people who need it, confidentiality commitments from partners, and secure handling of identity documents.
No system is completely secure. If a personal data breach is likely to harm you, we will notify you and the relevant authorities as the law requires.
10. Your rights
Depending on where you live, you have some or all of these rights:
- Information and access: to know what data we hold about you, how we use it and who receives it, and to get a copy.
- Correction: to have inaccurate or incomplete data corrected.
- Erasure: to have your data deleted when we no longer need it or have no legal basis to keep it.
- Restriction: to limit how we use your data in certain circumstances.
- Objection: to stop processing based on our legitimate interests, and to stop marketing at any time.
- Portability: to receive your data in a structured, commonly used format, or have it sent to another provider.
- Automated decisions: to object to decisions made solely by automated means that significantly affect you.
- Withdraw consent: at any time, without affecting processing that already happened.
To use any of these rights, contact us at fulcrumadvisoryfze@proton.me. We may need to verify your identity first. We aim to respond within 30 days, and there is normally no charge. Some rights are limited where we must keep data by law, for example under anti-money-laundering rules.
11. Marketing
We send updates, insights and offers only if you have agreed to receive them. Every email includes a way to unsubscribe, and you can also tell us on WhatsApp or by email at any time.
12. The online assessment
Our Global Exit Assessment suggests a starting point based on your answers. This is a simple automatic suggestion to guide your first conversation. It has no legal or financial effect, and every recommendation is reviewed personally by Nelson before any advice is given.
13. Children
Our services are for adults. We do not knowingly collect personal data from anyone under 18, except information about a client's children that is needed for a family residency application and provided by the parent or guardian.
14. Changes to this policy
We may update this policy as our services or the law change. We will post the new version on this page with a new "last updated" date, and tell clients directly about significant changes.
15. Contact and complaints
If you have a question or concern, contact us first so we can put it right:
- Email: fulcrumadvisoryfze@proton.me
- WhatsApp: +971 50 871 9210
- Post: Fulcrum Advisory FZE, Office C1-1F-SF13223, Ajman Free Zone C1 Building, Ajman Free Zone, United Arab Emirates
You also have the right to complain to a data protection authority: in the UAE, the UAE Data Office; in the EU, the authority in your country (in Portugal, the CNPD); in the UK, the Information Commissioner's Office; in Australia, the Office of the Australian Information Commissioner; or the authority where you live.