PRIVACY POLICY
Last Updated: January 20, 2026
1. WHO WE ARE
Our website address is: https://patri.ae.
PATRI is a joint venture between three entities under the PATRI brand managed by Findisy FZCO. We combine expertise in corporate structuring, regulatory advisory, and international business solutions across UAE, Luxembourg, and Panama jurisdictions.
This Privacy Policy explains how we collect, use, and protect your personal data in accordance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL), the European Union General Data Protection Regulation (GDPR), and applicable international data protection standards.
Our Legal Entities
Findisy FZCO serves as our primary controller for UAE operations. We are based at Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates. Our Trade License Number is [TO BE COMPLETED] and we are licensed by the Dubai Silicon Oasis Authority. You can reach us at contact@patri.ae or +971 50 268 4743.
Giovanni Patri & Associates S.A. operates our EU branch from Luxembourg, offering strategic advisory services among others. Our offices are located at 73, Rue du Golf, L-1638 Senningerberg, Luxembourg. Our RCS Number is B 199.321. Contact us at contact@giovannipatri.com.
PHOENICI S.A. operates our EU branch from Luxembourg, provides ID and AML compliance services, where we have operated since 2015. Our offices are located at 73, Rue du Golf, L-1638 Senningerberg, Luxembourg. Our Registration Number is B 199.181. You can contact us at contact@phoenici.com.
2. WHAT INFORMATION WE COLLECT
We collect different types of information depending on how you interact with us.
Information You Provide Directly
When you contact us or use our services, you provide us with basic contact information including your full name, email address, phone number, and business details such as your company name and your role within the organization. If you’re interested in our corporate structuring or visa services, we may also collect information about your nationality, country of residence, business objectives, and financial position relevant to the services you’re seeking.
For our paid consultation services, we collect billing information and payment details, which are processed securely through our payment processors. We maintain records of your transactions, invoices, and consultation history to provide you with quality service and maintain accurate business records.
Throughout our relationship, we collect communication data including email correspondence, meeting notes from consultations, support inquiries, and any feedback or survey responses you provide.
Information Collected Automatically
When you visit our website, we automatically collect certain technical information. This includes your IP address, browser type and version, device information, operating system, and details about how you navigate our site such as which pages you visit and how long you spend on them. We use cookies and similar technologies to collect this information, as explained in our separate Cookie Policy.
Sensitive Personal Data
For certain services such as UAE Golden Visa applications and corporate structuring, we may need to process sensitive personal data. This includes copies of passports and identification documents, financial records required for corporate structuring, information about family status for visa applications, and where legally required, criminal background checks. We only process this sensitive data with your explicit consent or where legally required, and we apply enhanced security measures and strict access controls to protect it.
Our Data Protection Officer is Mrs. XXX, who serves as our Head of Legal and Compliance. For any questions regarding this Privacy Policy or to exercise your data protection rights, please contact our DPO at dpo@patri.ae or call +971 50 268 4743.
3. WHY WE USE YOUR INFORMATION
We use your personal data to provide you with our professional services and maintain our business relationship with you.
Service Delivery
The primary purpose of collecting your data is to deliver our consultation services, which include our three-tier model: the 99€ Qualification Call, 189€ Discovery Session, and 449€ Strategic Consultation. We also use your information to provide corporate structuring and entity formation services, assist with UAE company setup and licensing, facilitate Golden Visa and residency permits, support relocation and banking needs, coordinate investment projects, and deliver mentoring and executive advisory services.
Business Operations and Legal Compliance
We process your data to handle essential business operations such as processing payments, managing billing, communicating about your services and appointments, and maintaining our client relationship management systems. We conduct due diligence and compliance checks as required by law, particularly for anti-money laundering and know-your-customer regulations that apply across the UAE, Luxembourg, and Panama jurisdictions where we operate.
We maintain accurate records to fulfill our tax reporting obligations and regulatory filing requirements across multiple jurisdictions. We may also need to respond to legal requests, protect against fraud and abuse, and defend or establish legal claims when necessary.
Marketing and Service Improvement
With your consent, we use your information to send newsletters and updates about our services, share promotional offers, provide educational content and industry insights, and invite you to relevant events. You can withdraw your consent for marketing communications at any time.
We analyze how visitors use our website to troubleshoot technical issues, enhance user experience, and improve our services. We also monitor for security threats and maintain the overall integrity of our systems.
4. LEGAL BASIS FOR PROCESSING
Under UAE PDPL and GDPR, we process your personal data based on specific legal grounds.
We obtain your explicit consent for newsletter subscriptions and marketing communications, for using optional cookies and tracking technologies, and when we share testimonials or case studies that include your information.
When you engage our services, we process your data as necessary to fulfill our contractual obligations to you. This includes providing consultation services, processing payments, delivering mentoring and advisory services, handling corporate structuring and regulatory matters, assisting with UAE Golden Visa applications, facilitating business setup and relocation services, and coordinating banking and investment needs.
We process certain data to comply with legal obligations across the jurisdictions where we operate. This includes UAE tax and commercial regulations, Luxembourg regulatory and fiscal requirements, Panama legal and reporting obligations, anti-money laundering and know-your-customer procedures, and various record-keeping requirements mandated by law.
In some cases, we process data based on our legitimate interests as a business, provided these interests don’t override your rights and freedoms. Our legitimate interests include preventing fraud and monitoring security, improving our services and website functionality, managing internal business operations, and protecting ourselves in disputes or legal proceedings.
5. INTERNATIONAL DATA TRANSFERS
Due to PATRI’s multi-jurisdictional structure, your personal data may be transferred between our operating countries.
Transfers Between Our Entities
We transfer data between our UAE, Luxembourg, and Panama operations to provide seamless service across jurisdictions. Data processed by Findisy FZCO in the UAE is protected under UAE PDPL requirements and stored on our European servers provided by GoDaddy.
Our Luxembourg entity, GPA S.A., processes data in full compliance with GDPR standards. The European Union is recognized as providing an adequate level of data protection under UAE PDPL Article 22, which means transfers to our Luxembourg operations benefit from both UAE and EU protection standards.
For our Panama operations through PHOENICI S.A., where Panama may not have an adequate level of protection recognized by UAE authorities, we have implemented contractual safeguards. These include standard contractual clauses that bind PHOENICI S.A. to UAE PDPL provisions and provide mechanisms for appropriate protection measures. We also rely on your explicit consent for specific processing activities and contractual necessity where transfers are essential to provide you with the services you’ve requested.
Third-Party Service Providers
We use certain third-party service providers that may be located outside the UAE. Our website is hosted by GoDaddy using European servers. Payment processing services are provided by [TO BE COMPLETED]. We use email and communication services from [TO BE COMPLETED], and our analytics and marketing tools may include [TO BE COMPLETED].
All international transfers to countries without adequate protection are secured through standard contractual clauses approved by data protection authorities, comprehensive data processing agreements with our vendors, and where applicable, frameworks such as the EU-US Data Privacy Framework. In all cases, we require your explicit consent for transfers that may not be covered by other legal mechanisms.
6. HOW LONG WE KEEP YOUR DATA
We retain your personal data only as long as necessary to fulfill the purposes for which we collected it and to comply with our legal obligations.
For active client relationships, we maintain your data throughout the duration of service provision plus seven years afterward. This retention period is required by UAE commercial law and Luxembourg tax law requirements. Consultation records are kept for five years after your last consultation to support professional liability and quality assurance needs.
Financial and transaction data must be retained for seven years following the transaction date to meet tax and accounting obligations in the UAE, Luxembourg, and Panama. Marketing data is kept until you withdraw your consent, plus an additional year to properly process your opt-out request and ensure we don’t inadvertently contact you again.
Website analytics and cookie data are retained for a maximum of twelve months, which is sufficient for our technical and analytical purposes. Legal and compliance records are kept for the duration required by applicable laws plus two additional years, which is necessary to comply with anti-money laundering regulations and other regulatory requirements. General correspondence and communications are maintained for three years after the last communication for business operations and potential dispute resolution.
After these retention periods expire, we securely delete your personal data using industry-standard methods or anonymize it for statistical purposes where applicable. We maintain audit logs of deletion activities to demonstrate our compliance with data protection requirements. You may request earlier deletion by exercising your right to erasure, subject to our legal obligations to retain certain records.
7. WHO WE SHARE YOUR DATA WITH
We share your data only when necessary to provide our services or when required by law.
Within PATRI
Your information is shared between Findisy FZCO, GPA S.A., and PHOENICI S.A. as joint controllers to provide seamless services across jurisdictions. All three entities are bound by this Privacy Policy and have entered into data protection agreements that govern how we handle your information internally.
Service Providers
We engage carefully vetted third-party processors who act solely on our instructions. Our website hosting is provided by GoDaddy using European servers. Payment processing is handled by WooCommerce integrated with [TO BE COMPLETED]. We use email service providers and communication tools from [TO BE COMPLETED], and our analytics and marketing platforms include [TO BE COMPLETED].
We also work with professional service providers including legal advisors who operate under professional privilege, accounting and audit firms who help us maintain accurate financial records, and regulatory consultants who assist with compliance across our operating jurisdictions.
Legal Requirements
We may disclose your data when required by law or legal process. This includes responding to requests from the UAE Data Office or other regulatory authorities, complying with requests from Luxembourg’s Commission Nationale pour la Protection des Données, cooperating with law enforcement agencies and courts, providing information to tax authorities, and supporting anti-money laundering investigations when legally required.
Business Transfers
In the event of a merger, acquisition, or sale of our business assets, your data may be transferred to the acquiring entity. Any such transfer would be subject to equivalent privacy protections, and we would notify you in advance of any change in control.
We want to be absolutely clear: we never sell, rent, or trade your personal data to third parties for their marketing purposes. Your data is used solely to serve you and fulfill our legal obligations.
8. YOUR RIGHTS AND HOW TO EXERCISE THEM
Under UAE PDPL and GDPR, you have important rights regarding your personal data.
Right to Access
You have the right to obtain confirmation of whether we process your personal data and to receive a copy of that data. You can also request information about why we’re processing your data, who we share it with, and how long we keep it. We provide this information free of charge unless your request is manifestly unfounded or excessive.
Right to Rectification
If your personal data is inaccurate or incomplete, you have the right to have it corrected. You can update your information at any time by contacting us, and we’ll make the necessary corrections promptly.
Right to Erasure
You can request that we delete your personal data when it’s no longer necessary for the purposes we collected it, when you withdraw consent and we have no other legal basis to process it, when you object to processing and we have no overriding legitimate grounds, or when the data was unlawfully processed. However, we may need to retain certain data to comply with legal obligations, such as tax records that must be kept for seven years, or to defend legal claims.
Right to Restriction
In certain circumstances, you can ask us to limit how we use your data. This might apply when you contest the accuracy of your data and we need time to verify it, when processing is unlawful but you don’t want the data deleted, when we no longer need the data but you need it for legal claims, or when you’ve objected to processing and we’re verifying whether our legitimate grounds override yours.
Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, machine-readable format. Where technically feasible, you can also ask us to transmit your data directly to another service provider.
Right to Object
You can object to processing of your personal data based on our legitimate interests, and you have an absolute right to object to direct marketing at any time, including profiling for marketing purposes. When you object to marketing, we’ll stop processing your data for that purpose immediately.
Right to Withdraw Consent
When we process your data based on consent, you can withdraw that consent at any time. This won’t affect any processing that occurred before you withdrew consent, but it may impact our ability to provide certain services to you.
How to Exercise Your Rights
To exercise any of these rights, contact our Data Protection Officer at dpo@patri.ae or call +971 50 268 4743. You can also write to us at Findisy FZCO, Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, UAE.
We’ll respond to your request within thirty days, though complex requests may require up to sixty days and we’ll notify you if we need the extra time. We may need to verify your identity before processing your request to prevent unauthorized access to your data. There’s no charge for exercising your rights unless your request is manifestly unfounded or excessive.
Right to Complain
If you’re not satisfied with how we’ve handled your data, you can file a complaint with the UAE Data Office (contact details to be announced when operational) or with Luxembourg’s Commission Nationale pour la Protection des Données at info@cnpd.lu or via their website at https://cnpd.public.lu.
9. HOW WE PROTECT YOUR DATA
We take the security of your personal data seriously and have implemented comprehensive safeguards.
Our technical security measures include SSL/TLS encryption for all data transmission, role-based access controls that limit who can view your data, secure hosting on GoDaddy’s European servers with enterprise-grade security, network security monitoring with firewalls and intrusion detection systems, encrypted backup systems with secure storage, and regular security updates and software patching.
From an organizational perspective, we provide regular data protection training for all our employees, require binding confidentiality agreements from all staff and processors, follow data minimization principles by collecting only necessary information, build privacy considerations into our systems and processes from the design stage, maintain documented incident response procedures, and conduct thorough due diligence on all our service providers.
If we experience a personal data breach that poses risks to your rights, we’ll notify the UAE Data Office within seventy-two hours when operational, inform affected individuals directly without undue delay, notify Luxembourg’s CNPD as required under GDPR, and explain the nature of the breach, likely consequences, and steps we’re taking to address it.
If you believe your data has been compromised, please contact us immediately at dpo@patri.ae so we can investigate and take appropriate action.
10. COOKIES AND TRACKING
Our website uses cookies and similar technologies to function properly and improve your experience. For complete details about the cookies we use and how to manage them, please see our separate Cookie Policy.
We use essential cookies that are necessary for the website to function, including session management, security features, and basic functionality. These don’t require your consent because they’re technically necessary.
With your consent, we may use analytics cookies from [TO BE COMPLETED] to understand how visitors use our website and identify areas for improvement. We may also use marketing cookies from [TO BE COMPLETED] for advertising and remarketing purposes.
You can manage your cookie preferences through our cookie consent banner when you first visit the site, through your browser settings to block or delete cookies, or through third-party opt-out tools. Please note that disabling essential cookies may affect how the website functions.
11. UPDATES TO THIS POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements.
For material changes that significantly affect your rights or how we handle your data, we’ll notify you at least thirty days in advance via email to registered users and through a prominent notice on our website. For minor changes, such as clarifications or updates to contact information, we’ll simply update the “Last Updated” date at the top of this policy.
Your continued use of our services after the effective date of any changes constitutes acceptance of the updated Privacy Policy. If you don’t agree with the changes, you can exercise your right to erasure or stop using our services.
12. CHILDREN’S PRIVACY
Our services are designed for business professionals and adults. We do not knowingly collect personal data from individuals under eighteen years of age without parental consent.
If you believe we have inadvertently collected data from a minor, please contact us immediately at dpo@patri.ae and we’ll delete it promptly in accordance with UAE PDPL’s special protections for minors.
13. CONTACT US
For general inquiries, you can reach us at contact@patri.ae or call +971 50 268 4743. Visit our website at https://patri.ae.
For data protection matters, contact our Data Protection Officer, [TO BE COMPLETED], Head of Legal and Compliance, at dpo@patri.ae or +971 50 268 4743.
Our postal address is Findisy FZCO, Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates.
Our EU representative is GPA S.A., 73, Rue du Golf, L-1638 Senningerberg, Luxembourg.
14. GOVERNING LAW
This Privacy Policy is governed by UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), the EU General Data Protection Regulation (GDPR) for our Luxembourg operations, and applicable data protection laws in Panama and other jurisdictions where we operate.
Any disputes arising from this Privacy Policy are subject to the exclusive jurisdiction of the courts of Dubai, UAE, though EU residents retain their rights under GDPR to bring proceedings in their local courts.
ACKNOWLEDGMENT
By using PATRI services or providing us with your personal data, you acknowledge that you have read, understood, and agree to this Privacy Policy.
If you have questions or concerns about how we handle your personal data, please contact our Data Protection Officer at dpo@patri.ae.
PATRI – Your Gateway to Business, Residency, and Opportunities in the UAE.
Joint venture between Findisy FZCO (UAE), GPA S.A. (Luxembourg), and PHOENICI S.A. (Panama) under the PATRI brand managed by Findisy FZCO.
Document Version: 1.0
Last Updated: January 19, 2026
Next Review: July 19, 2026
2. DATA CONTROLLERS
Your personal data is controlled jointly by the following legal entities:
Primary Controller (UAE Operations):
Findisy FZCO
- Trade License Number: [TO BE COMPLETED]
- Address: Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates
- License Authority: Dubai Silicon Oasis Authority (DSOA)
- Phone: +971 50 268 4743
- Email: contact@patri.ae
- Website: https://patri.ae
EU Branches (Luxembourg Operations):
Strategic Advisory Services
Giovanni Patri & Associates S.A. (GPA S.A.)
- RCS Number: [TO BE COMPLETED]
- TVA Number: [TO BE COMPLETED]
- Address: 73, Rue du Golf, L-1638 Senningerberg, Luxembourg
- Email: contact@giovannipatri.com
ID & AML Services
PHOENICI S.A.
- Registration Number: [TO BE COMPLETED]
- Established: 2015
- Address: [TO BE COMPLETED]
- Email: contact@phoenici.com
Data Protection Officer (DPO):
[TO BE COMPLETED – DPO Name]
Title: Head of Legal and Compliance
Email: dpo@patri.ae
Phone: +971 50 268 4743
You may contact our DPO for any questions regarding this Privacy Policy or to exercise your data protection rights.
Suggested text: When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
3. SCOPE AND APPLICATION
This Privacy Policy applies to:
- All visitors to our website (https://patri.ae)
- Clients and prospective clients of PATRI services
- Newsletter subscribers and marketing contacts
- Business partners and professional contacts
- Anyone whose personal data we process in connection with our services
Territorial Scope:
This policy applies to personal data processing activities conducted by PATRI entities in the UAE, Luxembourg, Panama, and any other jurisdiction where we operate or provide services.
4. LEGAL BASIS FOR PROCESSING
Under UAE PDPL and GDPR, we process your personal data based on the following legal grounds:
4.1 Consent (UAE PDPL Article 4)
- Newsletter subscriptions and marketing communications
- Optional cookies and tracking technologies
- Sharing testimonials or case studies
4.2 Contractual Necessity
- Providing consultation services (Qualification Call, Discovery Session, Strategic Consultation)
- Processing payments for services
- Delivering mentoring and advisory services
- Corporate structuring and regulatory advisory
- UAE Golden Visa assistance
- Business setup and relocation services
- Banking and investment facilitation
4.3 Legal Obligations
- Compliance with UAE tax and commercial regulations
- Luxembourg regulatory and fiscal requirements
- Panama legal and reporting obligations
- Anti-money laundering (AML) and Know Your Customer (KYC) procedures
- Record-keeping requirements across all jurisdictions
4.4 Legitimate Interests
- Fraud prevention and security monitoring
- Improving our services and website functionality
- Internal business operations and administration
- Professional liability and dispute resolution
4.5 Protection of Public Interest
- Regulatory compliance reporting
- Cooperation with governmental authorities
Media
Suggested text: If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Cookies
Suggested text: If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
Embedded content from other websites
Suggested text: Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
Who we share your data with
Suggested text: If you request a password reset, your IP address will be included in the reset email.
How long we retain your data
Suggested text: If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
What rights you have over your data
Suggested text: If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Where your data is sent
Suggested text: Visitor comments may be checked through an automated spam detection service.
