Privacy Policy

1. Data Controller

Aurelius Wealth Management Ltd (Registration No. [XXXXXX]), with registered office at [XX Example Street, Limassol 3025, Republic of Cyprus], is the data controller responsible for your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

[PLACEHOLDER — PENDING LEGAL REVIEW]

2. Data We Collect

We may collect and process the following categories of personal data:

• Contact information — name, email address, phone number, and postal address provided through our contact forms or correspondence
• Inquiry content — the substance of messages, questions, or requests you submit to us
• Technical data — IP address, browser type, operating system, referring URLs, and browsing behaviour on our website collected automatically via server logs and cookies

[PLACEHOLDER — PENDING LEGAL REVIEW]

3. Legal Basis for Processing

We process your personal data on the following legal bases under GDPR Article 6:

• Consent — where you have given explicit consent to the processing of your personal data for specific purposes (e.g., receiving communications)
• Legitimate interest — where processing is necessary for our legitimate business interests, such as improving our services and ensuring website security
• Legal obligations — where processing is necessary for compliance with a legal obligation to which we are subject, including anti-money laundering and regulatory requirements

[PLACEHOLDER — PENDING LEGAL REVIEW]

4. How We Use Your Data

We use the personal data we collect to respond to your inquiries, provide our services, comply with regulatory obligations, improve our website and user experience, and communicate with you about matters related to your engagement with Aurelius.

[PLACEHOLDER — PENDING LEGAL REVIEW]

5. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable laws and regulations. Inquiry data is typically retained for a period of [X years — PENDING LEGAL REVIEW] following your last communication with us.

[PLACEHOLDER — PENDING LEGAL REVIEW]

6. Third-Party Data Sharing

We may share your personal data with the following categories of third-party service providers who process data on our behalf:

• Email service provider — Resend (Resend, Inc.) for transactional email delivery
• Hosting provider — for website hosting and infrastructure
• Regulatory bodies — where required by law or regulation

All third-party processors are contractually obligated to process personal data in accordance with GDPR requirements.

[PLACEHOLDER — PENDING LEGAL REVIEW]

7. Your Rights

Under the GDPR, you have the following rights with respect to your personal data:

• Right of access — to obtain a copy of the personal data we hold about you
• Right to rectification — to request correction of inaccurate or incomplete data
• Right to erasure — to request deletion of your personal data where there is no compelling reason for continued processing
• Right to object — to object to the processing of your personal data based on legitimate interests
• Right to data portability — to receive your personal data in a structured, commonly used, and machine-readable format
• Right to lodge a complaint — to file a complaint with a supervisory authority (see Section 9)

[PLACEHOLDER — PENDING LEGAL REVIEW]

8. How to Exercise Your Rights

To exercise any of your rights under the GDPR, please contact our Data Protection Officer at:

Aurelius Wealth Management Ltd
[XX Example Street, Limassol 3025, Republic of Cyprus — PENDING LEGAL REVIEW]
[DPO Email — PENDING LEGAL REVIEW]

We will respond to your request within 30 days of receipt, in accordance with GDPR Article 12(3).

9. Supervisory Authorities

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the following supervisory authorities:

• Cyprus: Office of the Commissioner for Personal Data Protection (Dataprotection.gov.cy)
• United Kingdom: Information Commissioner's Office (ICO) — ico.org.uk

[PLACEHOLDER — PENDING LEGAL REVIEW]

10. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. Any changes will be posted on this page with an updated revision date. We encourage you to review this page periodically for any changes.

[PLACEHOLDER — PENDING LEGAL REVIEW]