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Privacy Policy

Last Updated: January 7, 2026

Your Privacy Matters: At Redwood Capital Advisors ("RCA", "we", "us", or "our"), we are committed to protecting your privacy and handling your personal information with the utmost care and discretion. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in compliance with applicable laws including the EU General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other international privacy regulations.

1. Information We Collect

1.1 Personal Information You Provide

We collect information that you voluntarily provide to us when you:

  • Contact us: Name, email address, phone number, and message content
  • Request consultation: Financial information, income details, investment portfolios, tax residency status
  • Engage our services: Identification documents, proof of address, banking information, business details
  • Subscribe to communications: Email address and communication preferences

1.2 Information Automatically Collected

When you visit our website, we automatically collect certain information:

  • Device Information: IP address, browser type, operating system, device identifiers
  • Usage Data: Pages viewed, time spent on pages, click patterns, referring URLs
  • Cookies and Tracking: Session cookies, preference cookies, analytics cookies (see Cookie Policy below)
  • Location Data: General geographic location based on IP address

1.3 Information from Third Parties

We may receive information from:

  • Financial institutions and banking partners
  • Regulatory and compliance databases
  • Professional advisors and service providers
  • Publicly available sources and business registries

2. How We Use Your Information

We use your personal information for the following purposes:

2.1 Service Delivery

  • Provide tax optimization and offshore structuring services
  • Establish and manage offshore companies and bank accounts
  • Conduct due diligence and compliance checks
  • Communicate with you about your account and services

2.2 Legal and Compliance

  • Comply with legal obligations (FATCA, CRS, AML/KYC requirements)
  • Prevent fraud, money laundering, and other illegal activities
  • Respond to legal requests and regulatory inquiries
  • Maintain records as required by law

2.3 Business Operations

  • Improve and optimize our website and services
  • Analyze usage patterns and conduct market research
  • Send marketing communications (with your consent)
  • Protect our rights and interests

3. Legal Basis for Processing (GDPR)

For users in the European Union, we process your personal data based on:

  • Contractual Necessity: To perform our services and fulfill our contractual obligations
  • Legal Obligation: To comply with regulatory requirements (AML, KYC, tax reporting)
  • Legitimate Interests: To improve our services, prevent fraud, and protect our business
  • Consent: For marketing communications and non-essential cookies (you may withdraw consent at any time)

4. How We Share Your Information

We maintain strict confidentiality but may share your information with:

4.1 Service Providers

  • Offshore incorporation agents and registered agents
  • Banking institutions and payment processors
  • Legal and accounting professionals
  • IT service providers and cloud hosting services

4.2 Legal and Regulatory Authorities

  • Tax authorities (as required by FATCA, CRS, and local laws)
  • Financial regulators and compliance agencies
  • Law enforcement (when legally required)
  • Courts and legal proceedings

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

Important: We do NOT sell your personal information to third parties for marketing purposes. All third-party service providers are bound by strict confidentiality agreements.

5. International Data Transfers

Given the international nature of our services, your information may be transferred to and processed in countries outside your jurisdiction, including:

  • British Virgin Islands (BVI)
  • Cayman Islands
  • United Arab Emirates
  • Singapore
  • Switzerland
  • United States

We ensure appropriate safeguards are in place, including:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy decisions by relevant authorities
  • Binding Corporate Rules and data protection agreements

6. Data Security

We implement industry-standard security measures to protect your information:

  • Encryption: SSL/TLS encryption for data transmission, AES-256 encryption for stored data
  • Access Controls: Role-based access, multi-factor authentication, regular access reviews
  • Physical Security: Secure data centers with restricted access
  • Monitoring: Continuous security monitoring and incident response procedures
  • Employee Training: Regular privacy and security training for all staff

However, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.

7. Data Retention

We retain your personal information for as long as necessary to:

  • Provide our services and maintain your account
  • Comply with legal and regulatory obligations (typically 7-10 years for financial records)
  • Resolve disputes and enforce our agreements
  • Pursue legitimate business interests

After the retention period, we securely delete or anonymize your information.

8. Your Privacy Rights

8.1 GDPR Rights (EU Users)

If you are in the European Union, you have the right to:

  • Access: Request a copy of your personal data
  • Rectification: Correct inaccurate or incomplete data
  • Erasure: Request deletion of your data ("right to be forgotten")
  • Restriction: Limit how we process your data
  • Portability: Receive your data in a structured, machine-readable format
  • Object: Object to processing based on legitimate interests
  • Withdraw Consent: Withdraw consent for processing at any time
  • Lodge a Complaint: File a complaint with your local data protection authority

8.2 CCPA Rights (California Users)

If you are a California resident, you have the right to:

  • Know: Request disclosure of personal information collected, used, and shared
  • Delete: Request deletion of your personal information
  • Opt-Out: Opt-out of the sale of personal information (we do not sell personal information)
  • Non-Discrimination: Not be discriminated against for exercising your rights

8.3 Other Jurisdictions

Users in other jurisdictions may have similar rights under local privacy laws. Contact us to exercise your rights.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience:

9.1 Types of Cookies

  • Essential Cookies: Required for website functionality
  • Analytics Cookies: Help us understand how visitors use our site
  • Preference Cookies: Remember your settings and preferences
  • Marketing Cookies: Track effectiveness of marketing campaigns (with consent)

9.2 Managing Cookies

You can control cookies through your browser settings. Note that disabling cookies may affect website functionality.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

11. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware of such collection, we will delete the information immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of material changes by:

  • Posting the updated policy on our website with a new "Last Updated" date
  • Sending email notification to registered users
  • Displaying a prominent notice on our website

Your continued use of our services after changes constitutes acceptance of the updated policy.

13. Contact Us

Data Protection Officer

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

Email: privacy@redwoodcapital.com
Subject Line: Privacy Inquiry - [Your Name]
Response Time: We will respond within 30 days (or as required by applicable law)

EU Representative: For GDPR-related inquiries, contact our EU representative at gdpr@redwoodcapital.com

Supervisory Authority: EU users may lodge a complaint with their local data protection authority if they believe their rights have been violated.

Confidentiality Commitment: As a provider of offshore tax optimization services, we understand the critical importance of discretion. All client information is treated with the highest level of confidentiality, and we maintain strict internal policies to protect your privacy beyond legal requirements.

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