Privacy Policy

1. Introduction

GMRC (Global Mobility & Residency Concierge), "GMRC", "we", "us" or "our", advises private clients and families on residency and citizenship by investment and coordinates the work of the lawyers, developers and other specialists involved in an application.

Your privacy matters to us. Our clients trust us with sensitive information about their families, finances and plans, and we treat that trust as the foundation of our work. This Privacy Policy explains what personal information we collect through this website and our enquiry channels, why we collect it, who we share it with and how you can control it.

Please read this policy carefully. By using this website or sending us an enquiry, you confirm that you have read and understood it. If you do not agree with it, please do not submit personal information to us.

2. Who we are and how to reach us

GMRC is responsible for the personal information described in this policy. Our office is at 325 Front St W, 2nd Floor, Toronto, ON M5V 2Y1.

If you have any question about this policy or about your personal information, contact our privacy team at info@gmrconcierge.com or call +1 (561) 590-2407. We aim to reply within five business days.

3. Scope of this policy

This policy applies to personal information we collect:

• through this website, including the consultation, contact, assessment and country-guide forms;
• when you email, call or message us, including through WhatsApp;
• during a free consultation and before you become a client.

If you go on to engage GMRC, your engagement letter and any client privacy notice we give you will also apply, and they will take precedence where they differ from this policy. This policy does not cover websites or services run by other organisations, even if we link to them.

4. The information we collect

Information you give us

When you book a consultation, send an enquiry or complete the home-page assessment, we ask for some or all of the following:

• your full name;
• your email address and telephone number, including the country dialling code;
• your nationality, country of citizenship and country of residence;
• the program or country you are interested in and your intended investment range;
• your preferred date and time for a call;
• any message you choose to write, which may include details about your family, goals, timeline or circumstances;
• your consent to be contacted about your enquiry.

When you request a country guide, we ask for your name, email address and telephone number so that we can send you a secure, time-limited download link.

Information collected automatically

When you submit a form, our server records your IP address, the language version of the site you used and your browser's user-agent string. We use this to protect the forms from spam and abuse and to reply in the right language. Like most websites, our hosting provider also keeps short-term server logs of the pages requested, the time of the request and the IP address that made it. See our Cookie Policy for the cookies this website uses.

Our forms are protected by Google reCAPTCHA, which helps us tell real visitors apart from automated abuse. When it runs, Google receives your IP address and information about your interaction with the page and processes it under Google's own privacy policy and terms of service.

Information we do not ask for

We do not ask for passport copies, bank details, source-of-funds evidence or other identity documents through this website. If you become a client, we will collect those documents through a secure channel and explain at that time why each one is needed.

5. How we use your information

We use the personal information described above to:

• reply to your enquiry and arrange the consultation you asked for;
• assess which residency or citizenship programs may suit you and your family and prepare an indicative cost;
• send you the country guide or other information you requested;
• keep a record of our communications with you;
• improve our services, website and the information we publish;
• protect our website, forms and systems from fraud, spam and misuse;
• meet our legal and regulatory obligations and establish, exercise or defend legal claims.

We do not use your information for automated decision-making that produces legal or similarly significant effects for you, and we never sell it.

6. Consent and legal basis

We collect, use and disclose personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and other privacy laws that apply. In most cases we rely on your consent, which you give when you submit a form, write to us or speak with us. You can withdraw consent at any time, subject to legal or contractual restrictions, and we will explain the consequences, for example that we may no longer be able to help with your enquiry.

Where the EU or UK General Data Protection Regulation applies to you, we rely on the following legal bases:

• steps you have asked us to take before entering into an engagement, such as a consultation or assessment;
• our legitimate interests in running and improving our advisory business, keeping records and protecting our website, balanced against your rights;
• your consent, for example to send you guides or updates;
• compliance with a legal obligation, such as record-keeping or anti-money-laundering requirements.

7. Marketing communications

We contact you only about the enquiry you made unless you have agreed to receive more. With your permission, we may occasionally send updates on program changes, new country guides or events that may interest you.

Every marketing email includes an unsubscribe link, and you can also opt out at any time by writing to info@gmrconcierge.com. Opting out of marketing will not affect messages we need to send you about an active enquiry or engagement.

8. When we share your information

We treat your information as confidential. We share it only in the following circumstances and only as far as necessary:

• Service providers who help us run our business, such as website hosting, email delivery and IT support. They may use your information only to provide their service to us and must protect it.
• Program partners, such as licensed immigration lawyers, real-estate developers, banks, translators and government-authorised agents, when you ask us to explore or progress a particular program. We tell you who they are before sharing anything beyond your basic details.
• Government authorities that decide residency and citizenship applications, but only as part of an application you have instructed us to support.
• Professional advisers, such as our lawyers, auditors and insurers, under a duty of confidentiality.
• Authorities, courts or regulators where we are required by law, or where disclosure is needed to prevent fraud or protect the rights, property or safety of GMRC, our clients or others.
• A buyer or successor if all or part of our business is reorganised, merged or sold, in which case this policy will continue to protect your information.

We do not sell, rent or trade personal information, and we do not share it with third parties for their own marketing.

9. International transfers

Residency and citizenship planning is international by nature. Your information may be stored or processed in Canada and in other countries where our service providers or program partners operate, including the country whose program you are considering. Privacy laws in those countries may differ from those where you live.

When we transfer information across borders, we take reasonable steps to make sure it receives a comparable level of protection, for example through contractual safeguards with service providers. Information held abroad may be accessible to courts and authorities in those countries under their laws.

10. How long we keep your information

We keep personal information only for as long as we need it for the purposes described in this policy:

• Enquiries that do not lead to an engagement are kept for up to 24 months after our last contact, so that we can pick up the conversation if you come back to us.
• Information about clients is kept for the length of the engagement and for as long afterwards as required by law, regulation or professional obligations, typically seven years.
• Server and security logs are kept for a short period, usually no longer than 90 days, unless needed to investigate an incident.

When information is no longer needed, we delete it or make it anonymous.

11. How we protect your information

We use physical, technical and organisational safeguards appropriate to the sensitivity of the information, including encrypted (HTTPS) connections to this website, restricted access to our lead and client records, protection of forms against automated abuse, and confidentiality obligations for our staff and partners.

No method of transmission over the internet or electronic storage is completely secure, so we cannot guarantee absolute security. If we become aware of a breach of security safeguards that creates a real risk of significant harm to you, we will notify you and the relevant authorities as required by law.

12. Your rights and choices

Subject to the law that applies to you, you have the right to:

• ask whether we hold personal information about you and request a copy of it;
• ask us to correct information that is inaccurate or incomplete;
• withdraw your consent to our use of your information;
• ask us to delete your information where we no longer need it;
• object to, or ask us to restrict, certain uses of your information, including direct marketing;
• receive information you gave us in a structured, commonly used format, where data portability applies.

To exercise any of these rights, write to info@gmrconcierge.com. We may ask you to confirm your identity before acting on your request, and we will respond within 30 days or within the time the applicable law allows. There is normally no charge.

13. Children

This website is intended for adults. We do not knowingly collect personal information directly from anyone under 18. Where a family application includes children, we collect their information from their parent or legal guardian and only once an engagement has started.

14. Third-party websites and services

This website links to or relies on services run by others, such as WhatsApp, Google Maps, LinkedIn and X, uses Google reCAPTCHA to protect its forms, and may offer Google Translate on some pages. When you use those services, the provider collects and uses information under its own privacy policy, which we do not control. We recommend that you read those policies before you use them.

15. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our services, our practices or the law. The "Last updated" date at the top of this page shows when it was last changed. Where a change is significant, we will take reasonable steps to let you know, for example by posting a notice on the website or contacting you directly.

16. Contact and complaints

If you have a concern about how we handle your personal information, please contact us first at info@gmrconcierge.com or +1 (561) 590-2407, or write to us at 325 Front St W, 2nd Floor, Toronto, ON M5V 2Y1. We will investigate and reply to you.

If you are not satisfied with our response, you may complain to the Office of the Privacy Commissioner of Canada (www.priv.gc.ca). If you live in the European Union or the United Kingdom, you may also contact your local data protection authority.