Effective Date: [To be confirmed at publication]
Last Updated: 23 April 2026

This privacy policy is currently under legal review. If you have any concerns about how your data is handled, please contact us directly at contact@jsprive.com and we will respond to you personally.

1. Who We Are

JS Privé is the personal advisory brand of Jason Swan, a residency and citizenship specialist. This privacy policy covers data collected through the jsprive.com website, client enquiry forms, consultation bookings, newsletter subscriptions, and direct correspondence.

Data Controller: JS Privé (trading name of Jason Swan). Email: contact@jsprive.com. Website: https://www.jsprive.com.

For the purposes of the UK GDPR and EU GDPR, JS Privé is the controller of your personal data. If you have any questions about this policy or how we handle your data, contact us at contact@jsprive.com.

2. What Personal Data We Collect

We collect and process the following categories of personal data depending on how you interact with us: contact details (name, email, phone, country of residence), enquiry details (your residency or citizenship objectives, current nationality, family situation, investment preferences, and timeline), technical data (IP address, browser type, device information, operating system), usage data (pages viewed, time spent, interactions with forms and content), and marketing preferences (your consent or withdrawal history).

We do not knowingly collect special category personal data and do not request such data through the website.

3. How We Collect Your Data

We collect data directly from you when you complete a contact form, book a consultation, subscribe to our newsletter, or email us. We collect data automatically through cookies and similar technologies when you browse the site. We may receive data from trusted professional partners who introduce clients to us, always with your knowledge.

4. How We Use Your Data

We use your personal data to respond to your enquiries, deliver consultations and advisory services, send marketing communications where you have consented, analyse website usage, comply with legal and regulatory obligations (including anti-money laundering and know-your-client requirements), and protect our legitimate business interests.

Our legal bases for processing are your consent, the performance of a contract, compliance with legal obligations, and our legitimate interests in running our business. You can ask us at contact@jsprive.com which legal basis applies to any specific use of your data.

5. Who We Share Your Data With

We do not sell your personal data. We share it only where necessary, with professional partners where your matter requires specialist input (for example tax or legal firms), with service providers under contract (website hosting, email delivery, consultation booking, analytics, cloud storage), and with regulatory and legal authorities where required by law.

All service providers and professional partners are bound by data processing agreements and assessed for their ability to handle your data securely and in compliance with GDPR.

6. International Transfers

Some of our service providers are based outside the UK and European Economic Area. Where your data is transferred outside the UK/EEA, we rely on Standard Contractual Clauses approved by the European Commission or UK ICO, adequacy decisions, or other legally recognised transfer mechanisms. Details of safeguards for any specific transfer are available on request at contact@jsprive.com.

7. How Long We Keep Your Data

We keep your data only as long as necessary. Enquiry data where no engagement follows is retained up to 24 months from last contact. Client engagement data is kept for the duration of the engagement plus seven years to meet regulatory and legal record-keeping requirements. Marketing data is kept until you withdraw consent. Technical and usage data is retained up to 26 months. When the retention period expires, we securely delete or anonymise your data.

8. Your Rights Under GDPR

You have the right of access to your data, rectification of inaccurate data, erasure in certain circumstances, restriction of processing, data portability, the right to object (particularly to direct marketing), the right to withdraw consent where consent is the legal basis, and the right not to be subject to automated decision-making.

To exercise any of these rights, email contact@jsprive.com. We will respond within 30 days. Most requests are free of charge.

9. How to Complain

If you have concerns, please contact us first at contact@jsprive.com. You also have the right to complain to a supervisory authority: the Comissão Nacional de Proteção de Dados (CNPD) in Portugal, the Information Commissioner’s Office (ICO) in the UK, or the data protection authority of your country of residence in the EU.

10. Cookies

Our website uses cookies and similar technologies. For details please see our Cookie Policy.

11. Security

We take appropriate technical and organisational measures to protect your personal data, including encryption in transit, access controls, secure password practices, and regular review. We will notify you and the relevant supervisory authority of any data breach that poses a risk to your rights in line with GDPR requirements.

12. Children

Our services are directed at adults. We do not knowingly collect data from anyone under 16. If you believe we have collected data about a child, contact contact@jsprive.com and we will delete it.

13. Changes to This Policy

We may update this privacy policy to reflect changes in our practices or legal requirements. Any changes will be posted on this page with an updated “Last Updated” date.

14. Contact Us

For any questions, concerns, or requests relating to your personal data or this policy: contact@jsprive.com