DATA PROTECTION & PRIVACY POLICY

Larson Wealth & Legacy Group – LWL Group
(American English · DIFC-Compliant · GDPR/LGPD-Aligned)

Last Updated: November21, 2025.

Your privacy is important to Larson Wealth & Legacy Group (“LWL Group”, “we”, “our”, “us”), headquartered in the Dubai International Financial Centre (DIFC) and operating globally across the United States, Europe, Latin America, and the United Arab Emirates.

This Data Protection & Privacy Policy outlines how we collect, use, store, protect, and share your personal data in accordance with applicable data privacy regulations worldwide.

By accessing or using our website, Client Portal, forms, resources, or communication channels, you agree to the practices described in this Policy.

1. Purpose of This Policy

This Policy explains how LWL Group handles personal data, maintains confidentiality, and complies with local and international data protection laws, including:

• DIFC Data Protection Law (Law No. 5 of 2020)

• UAE Personal Data Protection Law (PDPL)

• General Data Protection Regulation (GDPR – EU)

• Lei Geral de Proteção de Dados (LGPD – Brazil)

• U.S. Federal and State Privacy Standards

• Other global privacy frameworks as applicable

Our goal is to offer a safe, transparent, and respectful data environment for clients, partners, and website users.

2. Data We Collect

We may collect the following categories of personal data:

A. Information You Provide Directly

• Name

• Email address

• Phone number

• Country of residence

• Company or professional information

• Documents voluntarily shared for advisory purposes

• Information submitted through forms, emails, or consultations

B. Information Collected Automatically

• IP address

• Browser type, version, and device identifiers

• Geographic location (approximate)

• Cookies and usage analytics

• Client Portal access logs

• Pages viewed, time spent, click patterns

C. Sensitive Data

We only collect sensitive or regulated data (e.g., financial documents, tax reports, legal files) when expressly provided by you and only for the purpose of delivering contracted services.

We do not collect biometric, medical, or legally restricted data unless required by law or explicitly requested by the client.

3. How We Use Your Data

Your personal information may be processed for:

• Delivering wealth structuring, tax strategy, and advisory services

• Responding to inquiries or consultation requests

• Verifying identity and compliance with KYC/KYB procedures

• Improving website functionality and user experience

• Sending updates, insights, or publications (only with your consent)

• Complying with legal, regulatory, and fiscal obligations

• Maintaining the security and integrity of our systems

4. Legal Basis for Processing

We process data based on:

• Your consent

• Performance of a contract

• Compliance with legal obligations (DIFC, UAE, U.S., EU, Brazil)

• Legitimate interests (fraud prevention, service improvement, business operations)

We will always clarify the legal basis applicable to your situation.

5. Data Protection for HNWI & Sensitive Financial Documentation

As a boutique advisory firm serving global families and high-net-worth individuals:

• We maintain strict confidentiality

• Use encrypted storage and secure communication channels

• Restrict access to authorized personnel only

• Never share data with third parties without explicit consent

• Do not sell, rent, or trade personal data under any circumstances

LWL Group follows the highest international standards of financial confidentiality, similar to private banks, fiduciaries, and legal firms.

6. International Data Transfers

Given our global operations, data may be transferred to:

• United States

• United Arab Emirates

• European Union

• Brazil

• Other jurisdictions where our partners, advisors, or service providers operate

All transfers comply with:

• Standard Contractual Clauses (GDPR)

• Adequacy principles

• DIFC and UAE PDPL cross-border requirements

• LGPD international transfer rules

• Local legal safeguards

We ensure all third parties adhere to equivalent levels of protection.

7. Sharing Data With Third Parties

We may share personal data with:

• Tax advisors

• Legal firms

• Fiduciary and trust companies

• Banks and financial institutions (when authorized)

• Technology and cybersecurity providers

• Regulatory authorities (only when required by law)

All third-party partners are carefully vetted and bound by confidentiality and data protection agreements.

8. Data Retention

Personal data is retained only for:

• The period necessary to fulfill the purpose for which it was collected

• Compliance with DIFC, UAE, U.S., EU, and Brazilian regulatory requirements

• Statutory limitations applicable to tax and legal records

When no longer needed, data is securely deleted or anonymized.

9. Your Rights

Depending on your jurisdiction, you may request:

• Access to your personal data

• Correction of inaccurate information

• Deletion of your data

• Restriction of processing

• Data portability

• Withdrawal of consent

Requests may be submitted through our Contact section.

We will respond within the timeframe required by applicable law.

10. Cookies

We use cookies to:

• Enhance website functionality

• Personalize user experience

• Analyze performance and trends

Users can manage their preferences at any time via our Cookie Settings / Cookie Preferences panel.

See our Cookie Policy for details.

11. Security Measures

We implement:

• Encryption (in transit and at rest)

• Multi-factor authentication

• Secure servers

• Periodic security audits

• Restricted staff access

• Secure document exchange systems

These measures reflect industry best practices for international advisory firms.

12. Children’s Privacy

Our website and services are not intended for individuals under 18 years of age.

We do not knowingly collect data from minors.

13. Changes to This Policy

We may update this Policy periodically to reflect changes in:

• Regulations

• Internal practices

• Technology

• Services

Updated versions will be posted on this page with the effective date.

14. Contact Information

For questions regarding this Policy or data-related requests:

Larson Wealth & Legacy Group — DIFC, Dubai
Dubai International Financial Centre (DIFC), UAE

Email: info@larsondubai.com
Phone: +1 407 765.6588