Effective Date: [July 5 2025]
Last Updated: [July 5 2025]
Introduction
At S.J Trois Investments Ltd. (“Trois Investments,” “we,” “us,” or “our”), we are committed to protecting your privacy and maintaining the confidentiality of your personal information. This Privacy Policy explains how we collect, use, store, and protect your information when you use our website, services, or interact with us.
Given the nature of our investment advisory services and our commitment to serving high-net-worth individuals across MENA and GCC regions, we maintain the highest standards of data protection and confidentiality.
Personal Information
We may collect the following types of personal information:
Contact Information:
- Full name and preferred name
- Email addresses
- Phone numbers (mobile and landline)
- Mailing address and business address
- Country of residence and citizenship
Professional and Financial Information:
- Investment objectives and experience
- Risk tolerance and investment preferences
- Financial situation and net worth (when relevant to our services)
- Business interests and professional background
- Current investment portfolio information (when shared)
Identity Verification Information:
- Government-issued identification documents
- Passport information
- Proof of address documentation
- Source of funds documentation (when required)
Communication Records:
- Consultation notes and meeting records
- Email correspondence and communication history
- Phone call records (when legally permitted)
- Service inquiries and support requests
Website Usage Information:
- IP address and location data
- Browser type and version
- Pages visited and time spent on site
- Referral sources and navigation patterns
- Device information and operating system
How We Collect Information
Directly from You:
- Contact forms and consultation requests
- Phone calls and video conferences
- In-person meetings and consultations
- Email communications
- Document submissions and applications
Automatically Through Our Website:
- Cookies and similar tracking technologies
- Website analytics and usage data
- Security monitoring and fraud prevention
- Technical performance optimization
From Third Parties:
- Professional references and referrals
- Legal advisors and service providers (with your consent)
- Public records and regulatory databases
- Credit reporting agencies (when applicable)
How We Use Your Information
Service Delivery:
- Providing investment advisory and consultation services
- Analyzing your investment needs and objectives
- Developing personalized investment recommendations
- Facilitating real estate, private equity, and citizenship services
- Managing ongoing client relationships
Communication:
- Responding to inquiries and service requests
- Scheduling consultations and meetings
- Providing market updates and insights
- Sending regulatory and service notifications
- Cultural and language accommodation
Legal and Regulatory Compliance:
- Meeting know-your-customer (KYC) requirements
- Anti-money laundering (AML) compliance
- Tax reporting obligations
- Regulatory filing and documentation
- Court orders and legal process compliance
Business Operations:
- Website functionality and user experience
- Security monitoring and fraud prevention
- Service improvement and development
- Marketing and business development (with consent)
- Internal training and quality assurance
Legal Basis for Processing (GDPR)
Under the General Data Protection Regulation (GDPR), we process your personal data based on:
Legitimate Interests:
- Providing requested investment advisory services
- Maintaining client relationships and communication
- Website security and fraud prevention
- Business development and improvement
Contractual Necessity:
- Fulfilling service agreements and contracts
- Processing transactions and investments
- Delivering requested consultation services
Legal Obligations:
- Regulatory compliance requirements
- Anti-money laundering obligations
- Tax reporting and documentation
- Court orders and legal process
Consent:
- Marketing communications (where required)
- Optional data collection
- Third-party data sharing (when applicable)
- Cookies and tracking technologies
How We Share Your Information
Limited Sharing Principles
We maintain strict confidentiality and share your information only when necessary and with appropriate protections:
Service Providers:
- Legal advisors and law firms
- Tax advisors and accounting professionals
- Real estate agents and property managers
- Fund managers and investment platforms
- Technology and security service providers
Regulatory Authorities:
- Financial services regulators
- Tax authorities and revenue services
- Law enforcement agencies (when legally required)
- Anti-money laundering reporting entities
Professional Partners:
- Co-investment opportunities (with explicit consent)
- Referral partners and introduction sources
- Professional service providers (with consent)
Legal Requirements:
- Court orders and subpoenas
- Regulatory investigations and audits
- Legal proceedings and dispute resolution
- National security and public safety requirements
Third-Party Protections
All third parties with access to your information are bound by:
- Confidentiality agreements and professional obligations
- Data protection requirements equivalent to our standards
- Limited use restrictions for specified purposes only
- Security and protection requirement compliance
International Data Transfers
Cross-Border Considerations
Given our international client base and service delivery model:
Transfer Locations:
- European Union member states
- MENA and GCC region service providers
- United States technology providers
- Other jurisdictions as required for service delivery
Protection Mechanisms:
- European Commission adequacy decisions
- Standard contractual clauses (SCCs)
- Binding corporate rules and professional obligations
- Explicit consent for specific transfers
Regional Compliance:
- GDPR compliance for EU data subjects
- Local privacy law compliance in relevant jurisdictions
- Cultural and religious consideration accommodation
- Multi-jurisdictional legal requirement navigation
Data Security
Comprehensive Protection Measures
Technical Safeguards:
- End-to-end encryption for all communications
- Secure document storage and transmission systems
- Multi-factor authentication requirements
- Regular security audits and penetration testing
- Encrypted database storage and backup systems
Administrative Controls:
- Strict access controls and authorization requirements
- Regular employee training on privacy and security
- Incident response procedures and breach protocols
- Vendor management and third-party oversight
- Regular policy review and update procedures
Physical Security:
- Secure office facilities with controlled access
- Locked filing systems for physical documents
- Clean desk policies and document disposal procedures
- Visitor management and monitoring systems
Professional Standards:
- Professional liability insurance coverage
- Industry standard compliance and certification
- Regular legal review of privacy practices
- Cultural sensitivity and confidentiality training
Your Privacy Rights
Individual Rights and Controls
Access Rights:
- Request copies of your personal data
- Information about how we use your data
- Details about data sharing and transfers
- Correction of inaccurate or incomplete information
Control Rights:
- Withdraw consent for optional processing
- Object to marketing communications
- Request data deletion (where legally permitted)
- Data portability for certain information types
Protection Rights:
- Lodge complaints with supervisory authorities
- Request processing restrictions
- Notification of data breaches affecting you
- Independent dispute resolution mechanisms
Exercise Your Rights
To exercise your privacy rights:
- Email: privacy@troisinvestments.com
- Phone: [Privacy Officer Phone Number]
- Mail: Privacy Officer, Trois Investments Ltd., [Cyprus Address]
- Response Time: Within 30 days of verified requests
Cookies and Website Technologies
Cookie Usage and Management
Essential Cookies:
- Website functionality and navigation
- Security and fraud prevention
- Service delivery and user authentication
- Load balancing and performance optimization
Analytics Cookies:
- Website usage and performance analysis
- User behavior and navigation patterns
- Service improvement and development insights
- Regional and demographic usage trends
Marketing Cookies (Optional):
- Personalized content and recommendations
- Advertising effectiveness measurement
- Social media integration features
- Third-party marketing platform integration
Cookie Management
You can control cookies through:
- Browser settings and preferences
- Cookie consent management tools
- Opt-out mechanisms for specific services
Regular cookie deletion and management
Data Retention
Retention Periods and Policies
Client Relationship Data:
- Active client information: Duration of relationship plus 7 years
- Consultation records: 5 years from last contact
- Financial information: As required by regulatory obligations
- Communication records: 3-7 years depending on content type
Website and Marketing Data:
- Website analytics: 26 months maximum
- Marketing communications: Until consent withdrawn
- Contact inquiries: 2 years from last contact
- Newsletter subscriptions: Until unsubscribed
Legal and Regulatory Data:
- Compliance documentation: As required by applicable regulations
- Tax and reporting information: Per relevant jurisdiction requirements
- Legal proceeding records: As required by legal obligations
- Audit and investigation materials: As legally required
Deletion Procedures
We regularly review and delete data that:
- Exceeds required retention periods
- Is no longer necessary for stated purposes
- Has been requested for deletion (where legally permitted)
- Becomes inaccurate or outdated
Regional Privacy Considerations
Cultural and Legal Adaptation
MENA Region Considerations:
- Cultural privacy expectations and family dynamics
- Religious considerations affecting data handling
- Local regulatory compliance requirements
- Language and communication preferences
GCC Region Considerations:
- Business culture and relationship expectations
- Government and regulatory reporting requirements
- Cross-border business facilitation needs
- Traditional confidentiality and trust principles
European Union Compliance:
- Full GDPR compliance and implementation
- Data Protection Officer availability
- Supervisory authority cooperation
- Individual rights protection and facilitation
Children's Privacy
Protection of Minors
We do not knowingly collect personal information from individuals under 18 years of age. Our services are designed for adult investors and business purposes only.
If we become aware that we have collected information from a minor:
- We will delete the information immediately
- We will notify the parent or guardian if possible
- We will implement additional safeguards to prevent recurrence
Privacy Policy Updates
Change Management and Notification
Update Procedures:
- Regular review and policy updates
- Legal and regulatory change incorporation
- Service development and feature additions
- Security enhancement implementations
Notification Methods:
- Website posting of updated policies
- Email notification to active clients
- Direct communication for material changes
- Consultation notification during meetings
Effective Date Management:
- Clear effective date posting
- Transition period for significant changes
- Consent re-confirmation when required
- Historical version availability
Contact Information
Privacy Questions and Concerns
Privacy Officer: 📧 Email: privacy@troisinvestments.com
📞 Phone: [Privacy Officer Phone Number]
📍 Address: Privacy Officer, Trois Investments Ltd., [Cyprus Office Address]
General Inquiries: 📧 Email: info@troisinvestments.com
📞 Phone: [Main Phone Number]
Data Protection Authority: For EU residents, you may contact the Cyprus Commissioner for Personal Data Protection:Website: www.dataprotection.gov.cy
Email: commissioner@dataprotection.gov.cy
Regulatory Compliance
Applicable Laws and Standards
This Privacy Policy complies with:
- General Data Protection Regulation (GDPR)
- Cyprus Data Protection Laws
- Relevant MENA and GCC privacy regulations
- International financial services privacy standards
- Professional confidentiality obligations
Professional Standards
We maintain compliance with:
- Investment advisory professional standards
- International confidentiality requirements
- Cultural and religious consideration protocols
- Cross-border privacy protection mechanisms
This Privacy Policy reflects our commitment to protecting your privacy while delivering exceptional investment advisory services. Your trust is fundamental to our relationship, and we maintain the highest standards of confidentiality and data protection.
Last Updated: [July 5 2025]
Trois Investments Ltd. – Powering Global Moves