Privacy Policy

1. Controller

Flubes Limited, HE 433660, Republic of Cyprus. Contact for data protection matters: phone +357 94 04 21 89 or via the contact form on wealthborders.com.

2. Data we process

When you use the website: IP address, time of access, page requested, referring page, browser used. This data arises technically upon access and is deleted after seven days.

Upon registration and use of the portal: name, email address, password in encrypted form, language setting, times of login.

Upon placing an order: company details, registration number, address, information on the intended activity, payment details.

To satisfy due diligence obligations: identity documents, proof of address, details of beneficial owners, information on the source of funds employed.

During ongoing service: correspondence, uploaded documents, contract and invoice data.

3. Purposes and legal bases

| Purpose | Legal basis | |---|---| | Provision of the website | Art. 6(1)(f) GDPR | | Registration and portal access | Art. 6(1)(b) GDPR | | Performance of the contract | Art. 6(1)(b) GDPR | | Identification and due diligence | Art. 6(1)(c) GDPR | | Invoicing and record retention | Art. 6(1)(c) GDPR | | Improvement of our services | Art. 6(1)(f) GDPR |

4. Audience measurement without consent

We measure the use of our website using a self-hosted solution. No cookies are set, no cross-device identifiers are formed and no data is transmitted to third parties. The information collected does not permit any conclusion as to individual persons. For this reason no consent is required.

We do not use advertising networks, retargeting or third-party analytics services.

5. Fonts and external content

Fonts are served from our own server. There is no connection to Google Fonts or comparable services.

For appointment scheduling we use an external service. When you open the relevant page, data is transmitted to its provider. This occurs only if you expressly open that page.

6. Recipients

We disclose data to:

· Local service providers in the relevant jurisdiction — registered

agents, company secretaries, notaries, law firms — insofar as necessary to perform the order

· Registries and authorities of the relevant jurisdiction

· Banks and payment service providers, where the opening of an

account or the processing of payment has been instructed

· Technical service providers for operations and email delivery, in

each case on the basis of a data processing agreement

No disclosure takes place for advertising purposes.

7. Transfers to third countries

The subject matter of our services entails the transfer of data to countries outside the European Economic Area. Where a company is formed in the United States, the British Virgin Islands, Singapore, Hong Kong, Georgia, St. Vincent, the Marshall Islands or the Cayman Islands, the relevant documents are sent to bodies in those countries.

This transfer is necessary for the performance of the contract and takes place on the basis of Art. 49(1)(b) GDPR. Where adequacy decisions exist, we rely on them; otherwise we conclude standard contractual clauses.

Without this transfer the order cannot be carried out.

8. Retention

We retain your data for the duration of the business relationship. Thereafter statutory retention periods apply:

· Identification documents and transaction data: five years after the

end of the business relationship

· Invoicing and accounting records: in accordance with Cypriot law

· Website access data: seven days

Upon expiry we delete or anonymise the data.

9. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21).

These rights are not unlimited: where we are under a statutory obligation to retain data, restriction of processing takes the place of erasure.

Please address requests to the contact given above.

You have the right to lodge a complaint with a supervisory authority. The competent authority is the Commissioner for Personal Data Protection of the Republic of Cyprus; you may also contact the authority of your place of residence.

10. Necessity of the information

The information required for identification is prescribed by law. Without it we cannot perform the contract. All other information is voluntary unless otherwise indicated.

11. No automated decision-making

No automated decision-making, including profiling, takes place.

12. Changes

We will adapt this policy where our processing or the legal requirements change. The version published on this page applies.