Our Privacy Policy
For www.vanuatupassport.com.hk — a trading name of Strategic Corporate Services Ltd, Vanuatu.
1. Who We Are
www.vanuatupassport.com.hk is owned and operated by Strategic Corporate Services Ltd (“SCS”), a company registered in the Republic of Vanuatu. SCS provides citizenship, financial advisory, and related professional services.
All references to “we”, “us”, or “our” in this policy refer to SCS.
All personal data is administered and stored within the Republic of Vanuatu, in accordance with the Data Protection and Privacy Act No. 13 of 2024.
2. Purpose of This Privacy Policy
This Privacy Policy explains how we collect, store, use, and protect personal information. It also outlines:
- Where your data is held
- The legal basis for processing
- Your rights under Vanuatu law
- Security measures designed to safeguard confidentiality
3. Data We Collect
Depending on your interaction with SCS, we may collect the following information:
- Basic identity and contact information (name, email address, phone number, country of residence)
- Initial enquiry information submitted via online forms
- Information provided when requesting appointments or consultations
- Documents supplied for due diligence or Know-Your-Client (KYC) assessments
- Documents and information required for Vanuatu citizenship applications
4. Where Your Data Is Stored
4.1 Vanuatu (Primary Data Location)
All substantive personal data—including citizenship documents, identification materials, financial records, due-diligence information, and KYC documentation—is stored and processed exclusively within Vanuatu, in accordance with the Data Protection and Privacy Act No. 13 of 2024.
4.2 Hong Kong (Limited, Preliminary Contact Information Only)
Our Hong Kong office, subject to applicable Hong Kong laws, collects and stores only the following information and retains it solely for 90 days or until the applicant’s citizenship is granted, declined, or the application is withdrawn, whichever occurs first:
- Initial client intake
- Scheduling appointments
- Responding to early enquiries
Our Hong Kong office does not store:
- Citizenship application materials
- Identification documents
- Financial statements
- KYC or due-diligence information
- Sensitive or regulated personal data
Note: If you prefer your preliminary enquiry not to be viewed by our Hong Kong team, notify us and we will direct your communication exclusively through our Vanuatu office.
5. How Your Data Is Used
We process personal data strictly for the following purposes:
- Responding to enquiries
- Providing preliminary information or advice
- Conducting due diligence and KYC assessments
- Preparing and submitting citizenship applications
- Fulfilling regulatory and legal obligations under Vanuatu law
- Ensuring secure communication and continuity of service
Processing is carried out fairly, transparently, and only for lawful, explicit, and legitimate purposes in accordance with Sections 4 and 5 of the Act.
6. Cross-Border Data Transfers
Under Part 4 of the Data Protection and Privacy Act No. 13 of 2024:
- Personal data generated or collected in Vanuatu cannot be transferred outside Vanuatu unless authorised by the Minister, or by explicit client consent.
- SCS does not transfer citizenship documents, due-diligence records, or sensitive information to any foreign jurisdiction.
- Limited preliminary enquiry information may be accessible in Hong Kong for administrative purposes only.
Where a transfer is legally permitted, it will occur only when:
- The receiving country provides an adequate level of data protection;
- Authorisation is granted under Vanuatu law;
- You provide informed, explicit consent; or
- The transfer is necessary for the legitimate interests of the data subject or a lawful public-interest purpose.
These cross-border safeguards shall be read together with the protections in Clauses 12 and 12.1, which strictly limit any third-party disclosure and provide clients with the right, where lawful, to instruct SCS to resist compelled disclosure through appropriate legal processes.
7. Security and Confidentiality
We use strong technical and organisational safeguards to protect personal data against:
- Unauthorised access
- Unlawful processing
- Accidental loss, destruction, or alteration
Measures include:
- Secure servers located in Vanuatu
- Encryption of sensitive communications
- Controlled-access systems
- Internal confidentiality protocols
- Restricted access to authorised personnel only
8. Your Rights Under Vanuatu Law
You may, at any time:
- Request access to your personal data
- Request correction of inaccurate or incomplete information
- Request deletion of data no longer required
- Object to certain forms of processing
- Request restriction of processing
To exercise your rights, please contact us using the details provided below.
9. Data Retention
We retain personal data only for as long as necessary to:
- Provide services
- Meet legal or regulatory obligations
- Maintain records required by law
Once data is no longer required, it is securely deleted or anonymised.
10. Cookies
We have not programmed our website to collect or store cookies. However, certain third-party service providers — including web-hosting platforms, analytics tools, security services, and performance optimisers — may automatically attach cookies or similar tracking technologies to your device when you visit our site. Such cookies typically collect basic, non-identifying technical data for website performance, security, analytics, or limited marketing-related purposes.
- Cookies are small text files placed on your device to help websites function properly or to remember certain information. They cannot run programs or access your files. Common uses include maintaining page functionality, remembering user preferences, measuring website traffic, and improving overall user experience. You may disable cookies at any time through your browser settings; however, doing so may affect the site’s functionality or performance.
11. Embedded Content
Articles on this website may include embedded content (videos, articles, images, etc.). Embedded content behaves as if you visited the originating website directly.
Those websites may:
- Collect data
- Use cookies
- Implement third-party tracking
- Monitor interactions with embedded content
We do not control third-party websites and recommend reviewing their privacy policies.
12. Who We Share Your Data With
We do not share your data with any third party except where:
- Required by Vanuatu law
- Ordered by a competent court of the Republic of Vanuatu
- You have provided explicit written consent
12.1 Supplementary Provision – Resistance to Compelled Disclosure
Where a client explicitly instructs us to resist any form of compelled disclosure of their data — whether arising under the circumstances identified above or in any other situation — we shall, to the extent of such instructions and to the extent the client’s funds permit, take reasonable lawful steps and engage appropriate legal processes to contest such compulsion, insofar as is permitted by the laws of the Republic of Vanuatu.
13. Governing Law
The privacy provisions and information published on this website are governed exclusively by the laws of the Republic of Vanuatu. The material presented herein is general in nature and is intended to outline SCS’s core privacy standards in an open, publicly accessible form. Full and engagement-specific privacy terms, tailored to the circumstances and requirements of each client, will be set out in the applicable client engagement agreement and shall prevail where different or more detailed obligations apply.
Additional Legal Notices
A. Worldwide Jurisdiction Non-Disclosure Notice
SCS does not voluntarily disclose any client information to any government, regulator, court, agency, tax authority, law-enforcement body, or private litigant — whether located in Vanuatu or in any foreign jurisdiction. All requests, demands, notices, or attempts to obtain client information, from any entity howsoever constituted, are governed strictly by the protective provisions of Clauses 6, 12, and 12.1 above.
Where permitted by law and where so instructed by the client, SCS will take reasonable lawful steps to resist or contest any such request or compulsion, whether originating within Vanuatu or from outside it.
Upon receipt of any such request or demand, SCS’s legal representatives will—without delay—communicate the details to the client’s nominated legal representative, thereby preserving legal professional privilege over all related communications unless the client provides contrary written instructions. The manner and process of such communication shall occur in accordance with the applicable client engagement agreement.
B. Waiver of Private Information to Client’s Legal Representatives
Where a client instructs SCS to challenge, contest, or otherwise respond to any attempt by any entity or authority (howsoever constituted) to access the client’s data, SCS will—subject to Clauses 12 and 12.1—engage the client’s nominated legal representative and provide all reasonable assistance required. Upon the client’s written instruction, SCS will release to that legal representative such materials as are deemed reasonably necessary for counsel to act on the client’s behalf, to the extent permitted by law.
By directing SCS to release information to their legal representative, the client expressly waives the privacy protections otherwise afforded under this Privacy Policy in relation to the materials so provided. The client acknowledges that SCS, its officers, employees, and agents cannot guarantee, control, or ensure the continued confidentiality or privacy of any information once transmitted to the client’s legal representative, and the client agrees to hold SCS harmless in respect of any subsequent use, disclosure, or handling of that information by counsel.
C. Our Privacy Policy Principles
The privacy provisions set out above are published for the purpose of outlining the core principles and general standards by which SCS approaches the handling of personal information. They are intended to provide readers of this website with a clear understanding of our commitment to privacy in an open, publicly accessible format.
However, additional, amended, or more detailed privacy terms may apply in any formal engagement agreement entered into between SCS and a client. Where required, such engagement-specific provisions shall prevail to the extent necessary to address the circumstances of the engagement, applicable law, regulatory obligations, or the client’s expressed instructions.
Contact Us
Strategic Corporate Services Ltd
Port Vila, Republic of Vanuatu
Email: contact@vanucorp.com
Telephone: +678 22-159