Privacy Policy

Last updated: [Insert Date]

Advance Escrow Transfer Agent (“we,” “our,” or “us”) is committed to protecting the privacy, confidentiality, and security of the personal information entrusted to us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you engage with our escrow and securities transfer services.

1. Information We Collect

In the course of providing escrow, securities transfer, and related financial services, we may collect the following categories of personal and financial information:

• Identification Data: Full name, date of birth, nationality, government-issued identification documents (e.g., passport, driver’s license).
• Contact Information: Address, phone number, email address.
• Financial Information: Bank account details, securities account details, tax documentation (e.g., W-8BEN, W-9).
• Transaction Data: Records of escrow deposits, transfers, share certificates, agreements, and related communications.
• Compliance Data: KYC/AML verification data, proof of address, sanctions screening results.

2. Legal Basis for Processing

We process personal data under the following lawful bases:

• To fulfill our contractual obligations as an escrow and transfer agent.
• To comply with legal and regulatory obligations (e.g., securities laws, anti-money laundering, tax reporting).
• To protect our legitimate business interests in safeguarding our operations and preventing fraud.
• With your consent, where required (e.g., certain marketing communications).

3. How We Use Your Information

We use personal information for the following purposes:

• To verify your identity (KYC) and meet compliance requirements.
• To establish and manage escrow accounts and securities transfers.
• To process payments, distributions, and settlement of transactions.
• To communicate with you regarding your account and case file.
• To comply with tax reporting, audit, and financial disclosure obligations.
• To prevent fraud, money laundering, and unauthorized transactions.

4. Information Sharing and Disclosure

We do not sell or rent your personal data. We may share your information only in the following limited circumstances:

• With regulators, tax authorities, and law enforcement where legally required.
• With service providers (e.g., banking partners, auditors, IT providers) bound by confidentiality agreements.
• With legal representatives (e.g., Karpman Law Firm or other appointed counsel) for case handling.
• In connection with business continuity, mergers, or restructuring, provided safeguards are in place.

5. Data Retention

We retain your personal data only for as long as necessary to:

• Fulfill our contractual and legal obligations.
• Comply with regulatory retention requirements (typically 5–10 years).
• Resolve disputes and enforce agreements.

When data is no longer needed, it will be securely deleted or anonymized.

6. Data Security

We apply strict technical, administrative, and physical safeguards to protect your information, including:

• Encrypted data storage and secure transfer protocols.
• Access controls with role-based permissions.
• Regular security audits and monitoring.
• Staff training in privacy and data handling.

7. Your Rights (EU/EEA Residents – GDPR)

If you are located in the European Union or EEA, you have the following rights regarding your data:

• Right of access, rectification, or erasure.
• Right to restrict or object to processing.
• Right to data portability.
• Right to withdraw consent at any time.
• Right to lodge a complaint with your Data Protection Authority.

8. Your Rights (U.S. Residents)

In compliance with applicable U.S. laws (e.g., GLBA, CCPA for California residents):

• You may request access to and correction of your personal information.
• You may request deletion of certain data, subject to regulatory exceptions.
• You may opt-out of limited data-sharing practices not essential to our services.

9. Cross-Border Data Transfers

As a global financial services provider, your data may be transferred outside your home country, including to the United States. In such cases, we ensure appropriate safeguards (e.g., Standard Contractual Clauses under GDPR).

10. Updates to This Policy

We may update this Privacy Policy from time to time in response to changes in law, regulation, or business practices. Updated versions will be posted on our official website with the “last updated” date.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy, please contact: