1. Introduction
At MADAXA ("we," "our," or "us"), we understand that privacy and confidentiality are paramount when managing family wealth. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal and financial information in compliance with applicable privacy laws including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other relevant jurisdictions.
Our Commitment: We treat your information with the highest level of confidentiality and security. We never sell your personal data to third parties, and we limit data sharing to essential service providers bound by strict confidentiality agreements.
2. Information We Collect
2.1 Personal Information
- Name, address, date of birth, and contact information
- Government-issued identification numbers (passport, tax ID, etc.)
- Family structure and beneficiary information
- Employment history and source of wealth documentation
2.2 Financial Information
- Bank account details and investment holdings
- Real estate and business ownership records
- Tax returns and financial statements
- Transaction history and portfolio performance data
2.3 Technical Information
- IP address, browser type, and device information
- Login credentials and authentication data
- Portal usage patterns and access logs
- Communication metadata (time, recipient, subject lines)
3. How We Use Your Information
We collect and process your information exclusively for the following purposes:
- Advisory Services: Providing personalized wealth management, tax planning, and estate structuring recommendations
- Reporting & Analysis: Generating consolidated reports and performance analytics
- Regulatory Compliance: Meeting anti-money laundering (AML), know-your-client (KYC), and tax reporting obligations
- Communication: Sending important account updates, market insights, and service notifications
- Security: Detecting and preventing fraud, unauthorized access, and other security threats
4. Data Sharing and Disclosure
4.1 Service Providers
We engage carefully vetted third-party service providers to support our operations, including:
- Technology platforms and cloud infrastructure providers
- Legal counsel and tax advisors
- Custodian banks and financial institutions
- Compliance and regulatory consultants
All service providers are bound by confidentiality agreements and are prohibited from using your information for any purpose other than providing services to MADAXA.
4.2 Legal Requirements
We may disclose your information when required by law, including:
- Responding to valid legal process (subpoenas, court orders)
- Complying with tax reporting obligations
- Cooperating with regulatory examinations and audits
- Protecting our legal rights or defending against claims
4.3 No Sale of Data
We never sell, rent, or trade your personal information to third parties for marketing or any other commercial purpose.
5. Data Security
We implement industry-leading security measures to protect your information:
- Encryption: 256-bit AES encryption for data at rest and TLS 1.3 for data in transit
- Access Controls: Multi-factor authentication and role-based access permissions
- Network Security: Firewalls, intrusion detection systems, and regular vulnerability assessments
- Physical Security: Secure data centers with 24/7 monitoring and biometric access controls
- Employee Training: Regular security awareness training and strict confidentiality protocols
- Incident Response: Comprehensive breach notification procedures compliant with applicable laws
6. Data Retention
We retain your information for as long as necessary to fulfill the purposes outlined in this policy and comply with legal requirements:
- Active Clients: For the duration of the advisory relationship plus applicable statute of limitations periods
- Former Clients: Minimum seven years from termination of services for regulatory compliance
- Marketing Inquiries: Up to two years unless you request earlier deletion
7. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal information:
- Access: Request a copy of the personal information we hold about you
- Correction: Request correction of inaccurate or incomplete information
- Deletion: Request deletion of your information, subject to legal retention requirements
- Portability: Receive your information in a structured, machine-readable format
- Objection: Object to certain processing activities
- Restriction: Request restriction of processing under certain circumstances
- Withdrawal of Consent: Withdraw previously granted consent at any time
To exercise these rights, please contact us at privacy@madaxa.org
8. International Data Transfers
As a global family office advisor with operations across multiple jurisdictions, we may transfer your information internationally. We ensure all cross-border data transfers comply with applicable laws through:
- Standard Contractual Clauses approved by relevant data protection authorities
- Adequacy decisions recognizing equivalent privacy protections
- Your explicit consent for specific transfers when required
9. Cookies and Tracking Technologies
Our website and client portal use cookies and similar technologies to:
- Enable core functionality and maintain your session
- Remember your preferences and settings
- Analyze usage patterns to improve our services
- Provide security features and detect fraudulent activity
You can control cookie preferences through your browser settings, though disabling certain cookies may limit functionality.
10. Changes to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes through:
- Email notification to your registered address
- Prominent notice on our website and client portal
- Direct communication during regular client meetings
Continued use of our services after notification constitutes acceptance of the updated policy.
11. Contact Information
For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact:
MADAXA Privacy Office
Email: privacy@madaxa.org
Offices:
New York: 1177 Avenue of the Americas, 5th Floor, New York, NY 10036, USA
Paris: 5 Parvis Alan Turing, Station F, 75013 Paris, France
Dubai: Gate Village Building 3, Level 1, DIFC, P.O. Box 506713, Dubai, UAE
Singapore: 9 Straits View, Marina One West Tower, Level 20, Singapore 018937
São Paulo: Avenida Paulista, 1374, 12th Floor, Bela Vista, São Paulo 01310-100, Brazil
You also have the right to lodge a complaint with your local data protection authority if you believe we have not complied with applicable privacy laws.
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