Privacy Policy

Effective Date: May 28, 2025
Last Updated: May 28, 2025

1. Introduction

This Privacy Policy explains how Elite Golden Visa Limited (“EGV”, “we”, “us”, or “our”) collects, uses, stores, shares, and protects your personal data when you use our website (elitegoldenvisa.com), enquire about our services, or engage us as a client.

Elite Golden Visa Limited is registered in Scotland (Company Number SC852697) with its registered office at 23 Melville Street, Edinburgh, and maintains operational presence at Avenida da República 50, Lisbon, Portugal. We are registered with the UK Information Commissioner’s Office (ICO) as a data controller.

We are committed to protecting your privacy and handling your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and, where applicable, the EU General Data Protection Regulation (EU GDPR) as it applies to our operations in Portugal. Where we process personal data of individuals in other jurisdictions, we comply with applicable local data protection laws.

By using our Website, contacting us, or engaging our services, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy should be read alongside our Terms and Conditions.

 

2. Who We Are

EGV is an immigration consultancy and concierge service. We design and coordinate the residency process for clients pursuing Portugal’s Golden Visa through qualifying investment funds. We are not a regulated financial adviser, investment adviser, legal adviser, or tax adviser. For further details of what we do and do not do, please refer to Section 2 of our Terms and Conditions.

For the purposes of data protection law, Elite Golden Visa Limited is the data controller responsible for your personal data. If you have any questions about this Privacy Policy or our data practices, you can contact us at:

  • Email: info@elitegoldenvisa.com
  • Post: Elite Golden Visa Limited, 23 Melville Street, Edinburgh, Scotland

 

3. Personal Data We Collect

We collect and process personal data in several categories depending on your relationship with us and the services you require.

3.1 Enquiry and Website Data

When you visit our Website, make an enquiry, or book a consultation, we may collect:

  • Full name and contact details (email address, telephone number)
  • Country of residence and nationality
  • Details of your enquiry and how you heard about us
  • Scheduling preferences (via our integrated booking tools)
  • Technical data such as IP address, browser type, device information, and pages visited

3.2 Client Data

If you engage our services, we will collect additional personal data necessary to coordinate your Golden Visa application. This may include:

  • Full legal name, date of birth, and nationality
  • Passport or national identity card details
  • Tax identification numbers (in relevant jurisdictions)
  • Proof of address documentation
  • Source of funds and source of wealth documentation
  • Self-certification of High Net Worth Individual status (where applicable and required)
  • Family composition details (spouse and dependents included in the application)
  • Telephone number

3.3 Family Member and Dependent Data

Where your Golden Visa application includes family members or dependents (including children under the age of 18), we collect only the minimum personal data required for the application. This typically includes names, dates of birth, nationality, and identity document details. We collect this data from you as the primary applicant and rely on you to ensure that any family members whose data you provide are aware of, and consent to, such provision.

3.4 Data Received from Third Parties

We may receive your name, email address, and telephone number from third-party introducers, referral partners, or fund managers who have referred you to us or vice versa. Where we receive data from third parties, we will inform you of the source at or before the point of first contact and ensure that the data was shared with an appropriate legal basis.

 

4. How We Use Your Personal Data

We use your personal data for the following purposes:

4.1 Service Delivery

  • To respond to your enquiries and assess whether our services are suitable for your circumstances
  • To coordinate your Golden Visa application, including document collection, translations, apostilles, and liaison with fund managers and legal professionals
  • To provide you with factual, fund-manager-sourced information about Golden Visa-eligible investment funds
  • To ensure you receive quarterly fund updates and are informed of next steps, dates, and items required
  • To administer our client relationship, including invoicing and service fee collection

4.2 Marketing and Communications

  • To send you marketing communications about our services, educational content, and programme updates, where you have given your explicit consent to receive such communications
  • To personalise your experience on our Website and tailor content to your interests

You may withdraw your consent to marketing communications at any time by using the unsubscribe link in any marketing email, or by contacting us at info@elitegoldenvisa.com. Withdrawal of marketing consent does not affect the lawfulness of processing carried out prior to withdrawal.

4.3 Internal Operations

  • To conduct internal reporting, analysis, and business planning
  • To improve our Website, services, and client experience
  • To comply with our legal and regulatory obligations
  • To establish, exercise, or defend legal claims

 

5. Legal Bases for Processing

We rely on the following legal bases under the UK GDPR (and, where applicable, the EU GDPR) to process your personal data:

5.1 Performance of a Contract

Where processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. This includes coordinating your Golden Visa application, liaising with fund managers, and providing our consultancy and concierge services.

5.2 Consent

Where you have given your explicit, informed consent to the processing of your personal data for specific purposes. This applies to marketing communications and the sharing of fund-related materials that reference returns or performance data, which require a self-certification of your High Net Worth status. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5.3 Legitimate Interests

Where processing is necessary for our legitimate interests or those of a third party, provided these interests are not overridden by your rights and freedoms. Our legitimate interests include improving our services, internal reporting and analysis, maintaining the security of our systems, and responding to enquiries. We carry out a balancing exercise to ensure our interests do not override your rights.

5.4 Legal Obligation

Where processing is necessary to comply with a legal obligation to which we are subject, such as anti-money laundering regulations, tax reporting requirements, or other regulatory obligations.

 

6. Who We Share Your Data With

We do not sell your personal data to any third party. We share your personal data only where it is necessary for the delivery of our services, where required by law, or where you have given your consent. The categories of recipients include:

6.1 Fund Managers

Where you have selected a particular Golden Visa-eligible investment fund, we will share your personal data with the relevant fund manager for the purposes of your subscription and application. We only share data with the fund manager(s) you have chosen to engage with. Fund managers are independent data controllers and process your data in accordance with their own privacy policies, which we encourage you to review.

6.2 Immigration Lawyers

If you choose to use our independent immigration lawyer, we will share relevant personal data with them for the purposes of advising on and progressing your Golden Visa application. This sharing only occurs with your consent. The immigration lawyer operates as an independent data controller for the legal services they provide.

6.3 Translation and Apostille Services

We coordinate the translation and apostille of documents as part of the Golden Visa process. This may involve sharing copies of personal documents with accredited translation and apostille service providers, who act as data processors on our behalf.

6.4 Portuguese Authorities

As part of the Golden Visa application process, personal data will be submitted to the relevant Portuguese immigration authorities (including AIMA – the Agency for Integration, Migrations and Asylum, or its successor body). These submissions are made in accordance with Portuguese immigration law and are necessary for the performance of our contract with you.

6.5 Technology Service Providers

We use a number of third-party technology platforms that process personal data on our behalf as data processors. These include:

  • HubSpot (customer relationship management, marketing automation, and content management)
  • Google Workspace (email, document storage, and internal collaboration)
  • Superchat (WhatsApp business communications)
  • Salesflow (LinkedIn outreach)
  • Calendly (meeting scheduling)
  • Google Analytics and Google Ads (website analytics and advertising)
  • Meta Platforms (advertising via Facebook and Instagram)
  • LinkedIn (advertising)

These providers are contractually bound to process your data only in accordance with our instructions and applicable data protection law. Several of these providers are based in the United States – please see Section 8 (International Data Transfers) for further information.

6.6 Professional Advisers and Regulators

We may share your personal data with our own professional advisers (such as accountants or legal advisers) where necessary for our business operations, or with regulators and law enforcement agencies where required by law.

 

7. Cookies and Tracking Technologies

Our Website uses cookies and similar tracking technologies to help us understand how visitors use the site, to improve your browsing experience, and to support our advertising efforts.

7.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They are widely used to make websites work more efficiently and to provide information to website operators.

7.2 Cookies We Use

We use the following categories of cookies on our Website:

Strictly Necessary Cookies

These cookies are essential for the Website to function and cannot be switched off. They are usually set in response to actions you take, such as setting your privacy preferences, logging in, or filling in forms.

Analytics Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve Website performance. They help us understand which pages are most and least popular and how visitors move around the site. We use Google Analytics for this purpose. All information collected is aggregated and therefore anonymous.

Functional Cookies

These cookies enable the Website to provide enhanced functionality and personalisation, including cookies set by HubSpot to support our customer relationship management and chat functionality.

Advertising and Targeting Cookies

These cookies may be set through our Website by our advertising partners, including Google Ads, Meta (Facebook and Instagram), and LinkedIn. They may be used to build a profile of your interests and show you relevant advertisements on other sites. They do not directly store personal information but are based on uniquely identifying your browser and internet device.

7.3 Managing Cookies

When you first visit our Website, you will be presented with a cookie consent banner allowing you to accept or reject non-essential cookies. You can change your cookie preferences at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of our Website.

Most web browsers allow you to control cookies through their settings. You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. For more information about how to manage cookies in your browser, please visit your browser’s help pages.

 

8. International Data Transfers

As a business operating from both the United Kingdom and Portugal, and using technology platforms based in several countries, your personal data may be transferred to and processed in countries outside of your country of residence.

8.1 Transfers to Portugal and the EEA

We transfer personal data to our operational office in Lisbon, Portugal, and to Portuguese fund managers, immigration lawyers, and government authorities as part of the Golden Visa process. The European Economic Area (EEA) is recognised as providing an adequate level of data protection under UK data protection law, so these transfers do not require additional safeguards.

8.2 Transfers to the United States

Several of our technology service providers are based in the United States, including HubSpot, Google, Meta, Calendly, and Salesflow. Where personal data is transferred to the United States, we ensure that appropriate safeguards are in place, which may include:

  • The UK-US Data Bridge, where the receiving organisation has been certified under the relevant framework
  • Standard Contractual Clauses (SCCs) approved by the UK Information Commissioner
  • Other transfer mechanisms recognised as providing adequate protection under UK data protection law

You may request further information about the specific safeguards applied to any particular transfer by contacting us at info@elitegoldenvisa.com.

8.3 Transfers to Other Countries

We may serve clients from any jurisdiction. Where we process the personal data of individuals located outside the UK and EEA, we will comply with the applicable data protection laws of their jurisdiction and ensure that appropriate safeguards are in place for any cross-border transfers.

 

9. Data Retention

We retain your personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Our retention periods are as follows:

9.1 Client Data

We retain client data for the duration of the Golden Visa journey (which may span several years, including initial application, renewals, and citizenship eligibility) plus two years after the conclusion of our services. This allows us to support any follow-up queries, provide references, and comply with legal and regulatory requirements.

9.2 Enquiry Data

If you enquire about our services but do not become a client, we retain your personal data for a maximum of 24 months from your last interaction with us. After this period, your data will be securely deleted or anonymised.

9.3 Marketing Data

We retain marketing-related data (such as email addresses and communication preferences) for as long as you remain subscribed to our communications. If you unsubscribe, we will retain a minimal record of your email address on our suppression list to ensure we do not contact you again, in accordance with applicable regulations.

9.4 Legal and Regulatory Requirements

In certain circumstances, we may be required to retain data for longer periods to comply with legal, regulatory, or tax obligations. Where this applies, we will retain only the minimum data necessary and for no longer than the applicable statutory period.

 

10. Data Security

We take the security of your personal data seriously and have implemented appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction. These measures include:

  • Secure internal document sharing, restricted to authorised personnel
  • All business communications and data storage managed through a centralised, access-controlled Google Workspace environment
  • Use of work email accounts only for client communications (no personal email accounts)
  • Access controls and permission settings within our CRM and technology platforms
  • Regular review of our security practices and data processing activities


While we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but are committed to maintaining industry-appropriate standards.

 

11. Your Rights

Under the UK GDPR (and, where applicable, the EU GDPR), you have the following rights in relation to your personal data:

11.1 Right of Access

You have the right to request a copy of the personal data we hold about you, together with information about how and why we process it.

11.2 Right to Rectification

You have the right to request that we correct any personal data that is inaccurate or incomplete.

11.3 Right to Erasure

You have the right to request that we delete your personal data, subject to certain exceptions (for example, where we are required to retain it for legal or regulatory purposes).

11.4 Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to our processing.

11.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that we transmit it to another controller, where technically feasible.

11.6 Right to Object

You have the right to object to the processing of your personal data where we rely on legitimate interests as our legal basis, or where your data is processed for direct marketing purposes.

11.7 Right to Withdraw Consent

Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This does not affect the lawfulness of processing carried out before the withdrawal.

11.8 Exercising Your Rights

To exercise any of your rights, please contact us at info@elitegoldenvisa.com. We will respond to your request within one month. In certain circumstances, we may extend this period by up to two further months, in which case we will inform you of the extension and the reasons for it. There is no fee for exercising your rights, although we may charge a reasonable fee for manifestly unfounded or excessive requests.

 

12. Children’s Data

Our services are not directed at children under the age of 18, and we do not knowingly collect personal data from children in the context of marketing or enquiries.

However, where a Golden Visa application includes dependent children, we collect only the minimum personal data required for the application (such as names, dates of birth, nationality, and identity document details). This data is collected from the parent or legal guardian who is the primary applicant, and is processed solely for the purpose of the immigration application.

 

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The updated Privacy Policy will be posted on our Website with a revised “Last updated” date. Where changes are material, we will take reasonable steps to notify you, such as by email or by a prominent notice on our Website.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

 

14. Complaints

If you are unhappy with how we have handled your personal data, we encourage you to contact us first at info@elitegoldenvisa.com so that we can try to resolve the issue.

If you are not satisfied with our response, you have the right to lodge a complaint with a supervisory authority. In the United Kingdom, this is the Information Commissioner’s Office (ICO):

  • Website: ico.org.uk
  • Telephone: 0303 123 1113

If your complaint relates to the processing of data through our Portuguese operations, you may also contact the Portuguese supervisory authority, the Comissão Nacional de Proteção de Dados (CNPD):

 

15. Governing Law

This Privacy Policy is governed by the laws of Scotland and the United Kingdom, including the UK GDPR and the Data Protection Act 2018. Where our processing activities fall within the scope of the EU GDPR (for example, in relation to our operations in Portugal or the offering of services to individuals in the EEA), the EU GDPR shall also apply.

 

16. Contact Information

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:

  • Email: info@elitegoldenvisa.com
  • Scotland Office: 23 Melville Street, Edinburgh, Scotland
  • Portugal Office: Avenida da República 50, Lisbon, Portugal
  • Company Registration: SC852697 (Scotland)

 

By using elitegoldenvisa.com or engaging our services, you acknowledge that you have read, understood, and agree to this Privacy Policy.