Effective Date: 10th March 2025
At Second Passport Hub , we respect your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, and share your data in compliance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 .
1. Who We Are
Second Passport Hub is a UK-based company specializing in Citizenship by Investment (CBI) and Residency by Investment (RBI) programs. We are registered in England and Wales, with our principal office at:
71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.
Our Data Protection Officer (DPO) can be contacted at dpo@secondpassporthub.com for privacy-related inquiries.
2. What Information Do We Collect?
We collect the following types of personal data to provide our services:
- Personal Information: Full name, date of birth, contact details (email, phone), and government-issued ID (e.g., passport).
- Financial Information: Bank details, investment amounts, and payment records.
- Background Checks: Police certificates, financial solvency documents, and other due diligence materials.
- Application Details: Program preferences (e.g., Vanuatu CBI, Nauru Family Citizenship, Romania Residency), family member details, and travel history.
- Communication Records: Emails, calls, or messages exchanged with our team.
3. How Do We Use Your Information?
We process your data for the following purposes:
- To Fulfil Services: Process citizenship/residency applications, verify eligibility, and liaise with government authorities.
- Compliance: Conduct due diligence, adhere to anti-money laundering (AML) and counter-terrorist financing (CTF) regulations.
- Communication: Provide updates on your application, respond to inquiries, and send marketing communications (with your consent).
- Legal Obligations: Comply with legal requests, resolve disputes, or enforce agreements.
4. Who Do We Share Your Information With?
Your data may be shared with:
- Government Authorities: Relevant CBI/RBI program countries (e.g., Vanuatu, Nauru, Romania) for application processing.
- Service Providers: Third-party vendors (e.g., legal advisors, payment processors, IT support) under strict confidentiality agreements.
- Regulators: Law enforcement or regulatory bodies as required by law.
5. International Data Transfers
Your data may be transferred to countries outside the UK, including:
- Citizenship/RBI Program Countries: Vanuatu, Nauru, Romania, etc.
- Third-Party Service Providers: Located in the EU, Asia, or other regions.
We ensure adequate safeguards for international transfers, such as implementing Standard Contractual Clauses (SCCs) or relying on recognized adequacy mechanisms.
6. Data Retention
We retain your information for as long as necessary to:
- Fulfil the purposes outlined in this policy.
- Comply with legal obligations (e.g., UK record-keeping requirements for 6 years post-application).
- Resolve disputes or enforce agreements.
7. Data Security
We implement robust security measures to protect your data, including:
- Encryption of sensitive information.
- Access controls to ensure only authorized personnel handle your data.
- Regular security audits and updates to safeguard against breaches.
8. Your Rights
Under UK GDPR, you have the following rights:
- Access: Request a copy of your data.
- Rectification: Correct inaccuracies.
- Erasure: Request deletion of your data (where applicable).
- Restriction/Portability: Request a pause on processing or transfer data to another provider.
- Object: Opt out of marketing or automated decision-making.
- Complaint: Lodge a complaint with the Information Commissioner’s Office (ICO) .
To exercise these rights, contact us at privacy@secondpassporthub.com or via our address above.
9. Children’s Privacy
Our services are not intended for minors. We do not knowingly collect data from individuals under 18 without parental consent.
10. Updates to This Policy
We may update this policy to reflect changes in laws or practices. The effective date will be revised accordingly. We encourage you to review this page periodically.
11. Contact Us
For privacy-related questions or concerns, contact:
Email: privacy@secondpassporthub.com
Postal Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Last Updated: 10th March 2025
