Privacy Policy

1. Introduction and Scope

Strategic Global Alliance ("SGA", "we", "us", or "our") is committed to protecting the privacy and security of personal data entrusted to us by our clients, partners, and website visitors. This Privacy Policy ("Policy") outlines our practices regarding the collection, use, disclosure, and protection of personal data in the course of our sovereign advisory, infrastructure development, and financial consulting services.

This Policy is drafted in compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK Data Protection Act 2018 ("UK GDPR"), the EU ePrivacy Directive 2002/58/EC, the Digital Personal Data Protection Act, 2023 ("DPDP Act") of India, and other applicable global privacy frameworks.

This Policy applies to all personal data collected through our website, communications, and professional engagements, unless a specific service agreement or engagement letter provides otherwise.

2. Definitions and Interpretation

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person ("Data Subject").
• "Processing" means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation, or alteration.
• "Data Controller" means the entity that determines the purposes and means of the processing of personal data.
• "Data Processor" means an entity that processes personal data on behalf of the Data Controller.
• "Sovereign Client" means a national, regional, or local government entity, ministry, or public sector body.

3. Lawful Basis for Processing

We process personal data only when we have a lawful basis to do so, including:

• Consent: Where you have given clear consent for us to process your personal data for a specific purpose.
• Contractual Necessity: Where processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract.
• Legal Obligation: Where processing is necessary for compliance with a legal obligation to which SGA is subject.
• Legitimate Interests: Where processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

4. Categories of Personal Data Collected

We adhere to the principle of data minimization and collect only the personal data necessary for our specified purposes. Categories of data may include:

• Identity Data: Name, professional title, organization, and role.
• Contact Data: Email address, telephone numbers, and business address.
• Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform (collected via standard web server logs).
• Engagement Data: Information provided during the course of professional advisory services, which may include due diligence information, conflict checks, and correspondence.

5. Purpose of Data Processing

We process personal data for the following professional and business purposes:

• To provide sovereign advisory, infrastructure planning, and financial consulting services.
• To manage our relationship with you, including onboarding, invoicing, and client communication.
• To comply with legal and regulatory obligations, including anti-money laundering (AML), know-your-customer (KYC), and conflict of interest checks.
• To improve our website functionality, security, and user experience.
• To respond to inquiries submitted via our contact forms or direct correspondence.

6. Data Collection Methods

We collect data through:

• Direct Interaction: You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email, or otherwise.
• Automated Technologies: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns.
• Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties and public sources as part of our due diligence and professional engagement processes.

7. Use of Cookies and Tracking Technologies

Our website uses minimal cookies necessary for the functioning of the site and for analytical purposes to help us understand how visitors engage with our content.

• Strictly Necessary Cookies: Essential for the operation of the website.
• Analytical/Performance Cookies: Allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works.

We do not use advertising or targeting cookies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

8. Data Sharing and Disclosure

We adhere to strict confidentiality duties. We do not sell, rent, or trade your personal data. We may share your personal data with:

• Service Providers: Third-party vendors who provide IT, system administration, and professional support services, strictly under data processing agreements.
• Professional Advisers: Lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• Regulators and Authorities: Tax authorities, regulators, and other government bodies who require reporting of processing activities in certain circumstances.

9. International Data Transfers and Safeguards

Given our global operations, personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

We have implemented appropriate safeguards to require that your personal data will remain protected in accordance with this Policy. This includes implementing the European Commission’s Standard Contractual Clauses (SCCs) or UK International Data Transfer Agreement (IDTA) for transfers of personal data between our group companies and third-party service providers.

10. Data Security Measures

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

11. Data Retention Policy

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

12. Rights of Data Subjects

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

• Request access to your personal data (commonly known as a "data subject access request").
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party).
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact our Privacy Office.

13. Compliance with Sovereign and Government Clients

SGA acknowledges its obligations when handling sensitive data related to sovereign clients. We implement enhanced security protocols and data segregation measures for government-related engagements, ensuring compliance with specific national security and data sovereignty requirements of the jurisdictions in which we operate.

14. Amendments and Policy Updates

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

15. Contact Information

If you have any questions about this Privacy Policy or our privacy practices, please contact our Privacy Office via email at:

Strategic Global Alliance
Legal & Compliance Department