Privacy Policy & Data Handling
Placeholder draft — replace bracketed items with your real entity/contact details and have this reviewed by your compliance/legal team before publish, same as the services pages.
The FATCA/CRS tool
The 5-question tool runs entirely in your browser. Your citizenship, residency, and account-country answers are used only to compute your result on this page — they are not sent to any server, logged, or stored by this tool itself. Refreshing or closing the page clears your answers.
Consultation requests
If you choose to book a consultation via the form on our services page (or its Dutch equivalent), we collect the contact details and information you voluntarily provide in that form (e.g. name, email, phone, a description of your situation). This is a separate, clearly-marked step from the tool — using the tool does not automatically send anything to us. We use Web3Forms, operated by Web3Creative, as a data processor to receive and forward your submission to our inbox; we remain the data controller. Web3Forms' own retention and international-transfer terms are described below — see "International data transfer." Data submitted through the consultation form is used solely to respond to your enquiry and, if you proceed, to deliver our services, and is retained on our side only as long as necessary for that purpose or as required by our own regulatory record-keeping obligations as a licensed CSP — see "Retention" below.
Cookies & analytics
[Disclose your actual analytics/cookie setup here — e.g. "We use [analytics tool] to understand aggregate site usage. No personally identifying information from the tool's question flow is included in analytics events."] A cookie consent banner is shown to EU/UK visitors per GDPR/ePrivacy requirements.
Data controller & legal basis
The data controller for information submitted through the consultation form is COMMENCE OVERSEAS LIMITED, licensed in the British Virgin Islands (BVI Financial Services Commission, Registered Agent, registration L8288). We process this data on the basis of your consent (given via the checkbox on the form) to respond to your enquiry, and — if you proceed with our services — on the basis of contract performance and our own regulatory record-keeping obligations as a licensed CSP under the BVI Anti-Money Laundering Regulations and AML/TF Code of Practice.
Retention
On our side, consultation-form data that doesn't lead to a client relationship is retained for 12 months before deletion, in line with the GDPR storage-limitation principle for enquiries that don't proceed further. Where a client relationship is established, records are retained for 5 years from the end of the relationship, the minimum period required under the BVI Anti-Money Laundering Regulations and AML/TF Code of Practice, after which they are deleted or anonymized. Separately, Web3Forms itself retains submission data for up to a maximum of 3 years under its own service terms, unless deleted sooner — see "International data transfer" below.
International data transfer
Our contact form is processed by Web3Forms (operated by Web3Creative), which states that it operates from India and may process data through infrastructure and subprocessors in multiple jurisdictions (including cloud hosting, security, spam-prevention, and email-delivery providers). India is not on the European Commission's adequacy list, so this is a third-country transfer. Web3Forms publishes a Data Processing Agreement, incorporated into its Terms and Conditions, under which transfers from the EEA, UK, or Switzerland are governed by the European Commission's Standard Contractual Clauses, with the UK International Data Transfer Addendum where applicable — see Web3Forms' own Privacy Policy for details. We limit the information collected through the form to what's reasonably necessary to respond to your enquiry and do not ask you to submit special-category or highly confidential information through it.
Your rights (GDPR)
If you're in the EU/EEA or UK, you have the right to:
- Access — request a copy of the personal data we hold about you.
- Rectification — correct inaccurate or incomplete data.
- Erasure — request deletion of your data, subject to our regulatory retention obligations above.
- Restriction — request that we limit processing of your data in certain circumstances.
- Objection — object to processing based on legitimate interest.
- Data portability — request your data in a portable format, where technically feasible.
- Lodge a complaint — with your national data protection supervisory authority (in the Netherlands, the Autoriteit Persoonsgegevens; elsewhere in the EEA/UK, your own national authority) if you believe your data has been mishandled.
Contact us at [privacy contact email] to exercise any of these rights. The tool itself holds nothing to request — see "The FATCA/CRS tool" above.
Contact
COMMENCE OVERSEAS LIMITED, licensed in the British Virgin Islands (BVI Financial Services Commission, Registered Agent, registration L8288). Privacy enquiries: [email].