Introduction

Kindly review this Privacy Policy (the “Policy”) carefully to gain a clear understanding of how and why our web servers process your personal data for the purpose of allowing you to access and navigate through our website, https://www.globalxpert.net (referred to as the “Website”).

Global Xpert

Global Xpert is a global network of companies offering residence and citizenship planning services to clients, as well as advisory services to governments around the world.

The Global Xpert consists of various legal entities, and the details of these entities can be found here. This Privacy Policy is issued on behalf of the Global Xpert. Therefore, when the terms “Global Xpert,” “We,” “Us,” or “Our” are mentioned in this Privacy Policy, they refer to the relevant entity within the Global Xpert responsible for processing your data. We will inform you which entity is the data controller for your data when you avail any of our services. In certain cases, your personal data may be collected, stored, and processed in countries with their own local data protection laws. For more information about local data protection laws in those jurisdictions, you may refer to the relevant jurisdiction section below.

Global Xpert (company registration number 298482-5), based in Istanbul, Turkiye, is the data controller responsible for this Website. Our full contact details are provided below in section P, ‘How to contact us.’

General Information

We have designed our Website to allow you to browse without having to provide any personal information or identifying yourself.

If you choose to share your personal information with us, we will take steps to protect it and use it only as outlined below.

Purpose of This Privacy Policy

At Global Xpert, we are committed to safeguarding your privacy. We will not sell, rent, transfer, or disclose any personal information about visitors to our Website unless explicitly stated in this Privacy Policy.

The main purpose of this Privacy Policy is to:

  • Explain the types of personal data Global Xpert will collect from you and how we will use it (see section A, ‘The personal data we collect from you’ below).
  • Outline the legal basis on which any personal data is processed by Global Xpert (see section B, ‘How we use your information,’ and section C, ‘Legal basis for processing’ below).
  • Inform you on how Global Xpert handles your personal data.
  • Clarify our obligations under data protection laws to ensure the lawful and responsible processing of your personal data.
  • Notify you of your data protection rights (see section K, ‘Your rights as a data subject’ below).

We process your personal data appropriately, following applicable data protection regulations and the General Data Protection Regulation EU 2016/679 (the “GDPR”), which has been in effect since 25 May 2018.

We will comply with local data protection laws in the jurisdictions in which we operate. In accordance with these laws, the personal information we hold about you must be:

  • Used in a lawful, fair, and transparent manner
  • Collected for valid purposes that we have clearly explained to you, and not used in any manner incompatible with those purposes
  • Relevant to the purposes we have described and limited to those purposes
  • Accurate and up-to-date
  • Retained only as long as necessary for the purposes we have stated
  • Kept securely

This Privacy Policy should be read alongside our Cookie Policy and any other Privacy Notices we may provide when collecting or processing personal data. This ensures you are fully informed about how and why we are using your data. This Privacy Policy was last updated in March 2025

 

A. The personal data we collect from you

While using this Website, you may get in touch with our representatives to obtain information regarding residence and/or citizenship programs or the services provided by the Global Xpert. You can also begin the process of acquiring any of the services you are interested in. If you are seeking a career opportunity or require additional information for your press or media work, you can contact us as well. General inquiries or inquiries from potential suppliers are also welcomed.

We will collect and process the following personal data about you:

  1. Information You Provide Us

This includes personal details such as your first name, last name, nationality, country of residence, email address, and phone number. It also covers the services you are interested in or details about your inquiry. Additionally, we may collect data related to your marketing preferences.

You may provide such information under the following circumstances:

  • Completing an inquiry form on our Website
  • Corresponding with us by post, phone, email, or other methods when you apply for our services
  • Subscribing to our services or publications
  • Requesting marketing materials
  • Providing feedback
  • Initiating negotiations or entering into a contract to supply goods and/or services to Us

If you engage with Our services or apply for a job opportunity, you may be asked to supply additional information. For business users, further information may be required before entering into a commercial relationship.

Additional information may include payment details like banking information, VAT numbers, and/or tax IDs to facilitate payments for services. We may also request identification proof such as a copy of your passport or national ID card. If you’re applying for a job, we will require an updated CV and any other document we deem fit.

If we collect or process further information, we will provide separate privacy notices detailing how and why we use your personal data.

Where we are obligated to collect personal data by law or under the terms of a contract, and you fail to provide such data, we may not be able to provide services as agreed or enter into a contract with you. In such cases, we will inform you accordingly. This may lead to the termination of any agreement with you.

  1. Information We Collect About You from Our Website

When you visit our Website, we automatically gather the following:

  • Technical Information: This includes your IP address used to connect to the internet, log-in information, browser type and version, the full URL, and clickstream data from your interaction with the Website (including time and date). It also includes information such as page response times, download errors, the length of visits to specific pages, interaction data (scrolling, clicks, and mouse-overs), and methods used to navigate away from the page.
  • Location Information: We may receive data about your location through your IP address. If you access the Website via a mobile device, we may determine your location based on data collected from that device, such as the nearby wireless networks or cell towers at the time of access.

Our Website uses cookies to distinguish you from other users. This helps us provide you with a better experience and allows us to improve our site. For detailed information about the cookies we use and their purposes, please refer to our Cookie Policy.

 

  1. Information We Receive from Other Sources

We may also receive personal data about you from third parties and publicly available sources, as outlined below:

  • Technical Data from Google Analytics advertising features, including Google AdWords, Facebook Pixel, Google Tag Manager, Amiando, Microsoft Dynamics, LinkedIn, Gmail, and other ad hoc paid media partnerships.
  • Identity, Contact, and Background Data from publicly available sources, compliance databases, and compliance and due diligence service providers both within and outside the EU. This helps us verify that you are a suitable client or supplier for us.

 

B. How we use your information

  1. Information You Provide Us

We will use the information you provide for the following purposes:

  • To facilitate the delivery of the services you request and when it is necessary to perform the contract we are entering into or have entered into with you.
  • When required for our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override these interests.
  • To fulfill any legal or regulatory obligations we must comply with.
  • To address any issues you have reported and to provide you with related support services.
  • To manage and maintain the supplier relationship you have with us.
  1. Information We Collect About You from Our Website

We will use the information we collect from you for these purposes:

  • To administer our Website and carry out internal operations, including troubleshooting, and ensuring the safety and security of our Website.
  • To improve the functionality of our Website, ensuring that the content is displayed in the most effective way for you.
  • To make sure that the content shown on the Website is presented in a manner that is easy to navigate and user-friendly.
  1. Information We Receive from Other Sources

We may combine the information we receive from third-party sources with the information you provide and the data we collect from you. We will use your information solely for the purposes outlined in the sections above.

C. Legal Basis for processing

  1. We will process your personal data solely to the extent necessary for us to provide the services we offer and/or for the purposes outlined in this Privacy Policy (see section B, ‘How We Use Your Information’).

    Additionally, we may process your personal data based on legitimate interests or to comply with legal obligations. These interests and obligations could include the exercise or defense of legal claims, compliance with a court order, tribunal decision, or governmental/regulatory disclosure requirements.

    Typically, we do not rely on consent as the legal basis for processing your personal data. However, where consent is required, we will request your explicit approval through a form for that purpose.

D. Marketing

  1. You will receive marketing communications only if you have explicitly requested such information from us by providing your details through this Website and have opted-in to receive such communications. If we have established a business relationship with you (i.e., a contract), we may also notify you about our activities, offers, or other relevant information that we believe could be beneficial to you, based on our legitimate interests.

    To manage marketing communications, we centralize this process through Global Xpert Danışmanlık Hizmetleri A.Ş., a branch of Global Xpert based in Istanbul, Turkiye. This centralization ensures that you receive the marketing materials you have consented to, and that no additional marketing communications are sent to you. In some cases, this involves transferring personal data outside of the European Economic Area (EEA), which is further detailed in Section F of this policy, under “Transfers of Data to Third Countries.” Here, we outline the manner in which we transfer personal data outside the EEA and the safeguards we implement.

    We will only share your personal data with third parties for marketing purposes with your explicit consent. Before utilizing analytics for marketing, we require your consent for the use of marketing cookies. Your data will be transferred in a hashed format using the SHA256 algorithm to our marketing service providers. Third parties may collect data on our Website for purposes such as: (i) storing and accessing tracking technologies, (ii) conversion tracking, (iii) serving targeted ads, and (iv) enhancing third-party products to improve our marketing campaigns. This information may include details like URL addresses, device types, browser and operating system information, as well as your IP address. For more details on the service providers and their privacy policies, please refer to the Cookie Policy table, which provides links to their privacy policies.

    Please be aware that you have the right to access, correct, erase, or transfer your personal data held by third-party providers. Additionally, you may have the right to object to or request the restriction of certain processing activities. To exercise these rights, please contact the respective service provider directly. For further details on marketing and third-party cookies used on our Website, please visit our Cookie Policy. You also have the right to withdraw consent or object to receiving marketing communications at any time by contacting info@globalxpert.com or by clicking the unsubscribe button. Once you withdraw your consent or object to any of the purposes mentioned, we will cease sending you marketing materials. If you choose not to consent or withdraw consent for any of the purposes listed, we can still provide our services. However, this may limit the range of services we can offer, and it may impact the efficiency with which we deliver the services you requested.

E. Disclosure of your information

  1. We may share your personal data with our international offices or companies within the Global Xpert, who may act as joint data controllers or data processors for the company. These offices or companies will assume responsibility as the data controller for your information when you use our services, or they may handle administrative, control, and reporting functions. A complete list of the Global Xpert companies that may receive your data can be found here. All entities within the Global Xpert adhere to data protection laws, including the GDPR, and implement appropriate security measures to safeguard your personal data as outlined in Section H, ‘Data Security’.

    In certain circumstances, we may be required to disclose your data to government agencies and authorities in the country where you are seeking residence or citizenship. This disclosure will only include the essential information necessary for performing the services specified in our contract with you.

    Your data may also need to be shared with local agents or service providers (acting as data processors) to facilitate the services you have requested. These third parties process and store your data under strict confidentiality, ensuring compliance with the appropriate security measures and safeguards as detailed in Section H.

    We may also share your personal data with third-party entities acting as data controllers, such as legal, tax, real estate, immigration consultants, (international) banks for payment processing, or other service providers, such as real estate agencies, property owners, or developers. You may choose to engage with these parties under separate terms and conditions. These third parties process your data independently as data controllers, and their privacy policies and processes apply to your information.

    Additionally, we may disclose or share your personal data if required by law, a court order, or other legal obligations. This could include disclosing data to enforce our terms of use or to protect our rights, property, or safety, as well as that of our partners or Website users. This may also involve sharing information with other companies for purposes such as anti-money laundering, KYC (Know Your Customer) checks, compliance with anti-bribery or anti-corruption laws, and fraud prevention.

     

F. Transfers of data to third countries

  1. When we share your personal data with internal or external third parties, it may require transferring your data outside the EEA. We will ensure that such transfers are made in compliance with applicable laws, including the GDPR, using standard contractual clauses (also known as the ‘SCC’), which are the European Commission’s model contracts for transferring personal data to third countries. These clauses are designed to ensure your data is protected and transferred securely.

    Global Xpert serves as the data representative for all our offices located outside the EEA. If you have any concerns, queries, or issues related to data protection, you can contact Global Xpert by sending an email with “Data protection” in the subject line to: info@globalxpert.com.

     

G. Third party access to your personal data

  1. We collaborate with external partners to deliver the services you request through our Website. These partners include cloud storage services, analytics platforms, and search engine information providers. We ensure that all third-party providers we engage with comply with the relevant laws in the jurisdictions where we operate. Additionally, they must adhere to the GDPR and, when applicable, commit to the SCC (as outlined in section F., ‘Transfers of data to third countries’) to guarantee the proper protection and security of your personal data.

H. Data security

  1. We implement stringent security measures to prevent unlawful or unauthorized processing of personal data, as well as to protect against accidental loss or damage.

    Data transfers between our Website and your device are safeguarded using Transport Layer Security (TLS) encryption. When accessed via compatible browsers, this technology ensures that personal information remains secure during transmission through server authentication and data encryption. Supported browser versions include Internet Explorer (from version 11), Mozilla Firefox (from version 27), Google Chrome (from version 32), and Apple Safari (from version 7).

    All personal data is securely stored in a protected server environment with firewalls and advanced security technology to prevent unauthorized access or interference. Our servers are located in Lithuania. Access to personal data is restricted to authorized personnel, such as employees, who are assigned usernames and passwords and are legally obligated to maintain confidentiality.

    While we take comprehensive security precautions, no data transmission method is entirely risk-free, and absolute security cannot be guaranteed.

     

I. Data storage

  1. We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including providing our services and meeting any legal, accounting, or regulatory obligations. In any case, data storage will not exceed 10 years from the date of service completion or termination.

    This retention period allows us to address potential legal claims, considering the relevant statutory limitation periods. Additionally, where applicable, it ensures compliance with anti-money laundering (AML) and Know Your Customer (KYC) regulations, anti-bribery and corruption laws, as well as tax and accounting requirements in the jurisdictions where we operate.

J. Data minimization

  1. Wherever practical and to the greatest extent possible, we render your data anonymous once it is no longer required for identification purposes, ensuring that it cannot be traced back to you in any manner.

K. Your rights as a data subject

  1. Your Rights Under the General Data Protection Regulation (GDPR)

    1. Right of Access

    You have the right to request confirmation regarding whether Global Xpert is processing your personal data. If so, you are entitled to receive details about the nature and purpose of this processing. To exercise this right, you may contact us at info@GlobalXpert.com. We will provide one electronic copy of your personal data free of charge. However, if your request is manifestly unfounded, repetitive, or excessive, we reserve the right to impose a reasonable fee or, in certain cases, decline the request.

    1. Right to Object

    At any time, you may object to the processing of your personal data, particularly when processing is based on our legitimate interests or those of a third party, including for direct marketing purposes. If you submit a written objection to info@GlobalXpert.com, we shall cease processing your data for such purposes, unless we can demonstrate compelling legitimate grounds overriding your interests, rights, and freedoms.

     

    1. Right to Rectification

    You are entitled to request that we amend any inaccurate or incomplete personal data concerning you. If your details are incorrect, outdated, or incomplete, you may request their rectification or completion, including by providing a supplementary statement.

    1. Right to Erasure (Right to Be Forgotten)

    You may request the deletion of your personal data in specific circumstances, including but not limited to:

    • When your data is no longer necessary for the purposes for which it was originally collected;
    • If you withdraw consent and no other lawful basis for processing exists;
    • If you object to processing and no overriding legitimate grounds justify its continuation;
    • If your data has been unlawfully processed; or
    • If erasure is required to comply with legal obligations to which we are subject.
    1. Right to Restrict Processing

    You have the right to request that we limit our processing of your personal data in certain situations, such as:

    • If you contest the accuracy of the data, we will restrict processing while its accuracy is verified;
    • If processing is unlawful and you prefer restriction instead of erasure;
    • If we no longer require the data, but you need it to establish, exercise, or defend a legal claim;
    • If you have objected to processing, pending verification of whether our legitimate grounds override yours.
    1. Right to Data Portability

    Effective from May 25, 2018, you have the right to receive your personal data in a structured, commonly used, and machine-readable format. Furthermore, you have the right to transmit this data to another data controller, where technically feasible.

L. Right to withdraw consent

  1. Where you may have granted your consent for the collection, processing, and transfer of your personal data for a specific purpose (for example, for marketing), you have the right to withdraw that consent at any time, or you may choose to withdraw your consent to this Privacy Policy altogether. To withdraw your consent, please contact info@globalxpert.com. This will not affect the legality of any processing we conducted based on your consent prior to its withdrawal. After receiving your notification to withdraw consent, we will cease processing your data for that purpose unless we have another legitimate legal basis to do so. Please note that withdrawing consent to this Privacy Policy will necessitate the immediate termination of our services with you.

M. Quality of website and overall experience

  1. To enhance the quality and overall user experience of the Website, as well as to assist in event bookings and client registrations, we utilize Google Analytics advertising features and Microsoft Dynamics CRM.

    If you wish to opt out of Google Analytics for display advertising, you can do so through the ads preference manager.

    Additionally, there is a Google Analytics ‘opt-out browser’ extension available for download at https://tools.google.com/dlpage/gaoptout.

    You have the right to withdraw your consent for any of the purposes outlined above at any time. This will not affect the lawfulness of the processing of your personal data for those purposes before your withdrawal. To withdraw your consent, please email us at info@globalxpert.com, specifying the processing activities you wish to withdraw consent for.

N. Complaints

  1. We encourage any feedback, concerns, or questions regarding data protection. As previously noted, you can reach out to our Data Protection Officer via email at info@globalxpert.com or utilize the contact information provided in section P. ‘How to reach us’ below. We will make every effort to address any matter or issue you may have.

    If we are unable to resolve your concerns, you are entitled to submit a complaint to the Information and Data Protection Commissioner at idpc.org.mt, the competent national authority overseeing data protection issues.

O. Changes to this Privacy Policy

  1. Any modifications to this Privacy Policy will be published on this page. Where applicable, we will notify you of these changes via email.

P. How to contact us

  1. If you have any inquiries regarding this Privacy Policy, or if you would like to provide us with your feedback, please reach out to us today. Alternatively, you may contact us using the details below:

    Global Xpert, Esentepe caddesi Dergiler sok. No:7 34394 Sisli Istanbul, Türkiye +90 (555) 245 29 28

    Please visit this page regularly to stay informed about any updates or modifications to this Privacy Policy,