1. Information We Collect

To fulfill our advisory mandate and comply with international anti-financial crime regulations, we collect:

• Identification Data: Full legal name, date of birth, nationality, government-issued photo ID (passport or national ID card).
• Contact Information: Professional email address, telephone number, verified residential address (utility bill or bank statement ≤ 3 months old).
• Financial Profile: Source of wealth confirmation, allocation tier preferences, transaction settlement records.
• Technical & Telemetry Data: IP address, browser type, device identifiers, session timestamps for terminal account security.

2. Purpose of Data Processing

Client information is processed solely for:

• Providing private strategic advisory, portfolio analytics, and transaction reporting.
• Executing mandatory Customer Due Diligence (CDD) and sanctions screening.
• Administering secure access to the investor/client terminal and processing profit accruals.
• Preventing financial crimes, unauthorized account access, and cyber security breaches.

3. Data Security & Encryption Safeguards

The platform uses HTTPS for data in transit, provider-managed encryption at rest, row-level database access controls, and a private document bucket with time-limited signed links. Access to confidential client files is limited to authenticated users and authorized administrators according to their role.

4. Third-Party Sharing & Disclosure Restrictions

Norvel Capital does not monetize or disclose personal data except where strictly necessary:

• To trusted KYC/AML verification providers and infrastructure partners under strict non-disclosure obligations.
• To regulatory authorities or law enforcement bodies when mandated by applicable statutory subpoenas.
• To independent financial auditors and legal advisors under professional confidentiality duties.

5. Data Retention Period

In adherence to international anti-money laundering statutory requirements, client verification records and transaction audit logs are retained for a minimum of five (5) years following the termination of an advisory relationship.

6. Your Rights

Clients are entitled to request access to their stored personal data, request corrections, or request data portability. Inquiries may be addressed to our Data Protection Officer at info@norvelcapital.com.