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 Pharos Introductions
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Legal

Last updated: 2 August 2026

1. Who we are

Pharos Introductions("we", "us") operates the website at pharosintroductions.com - an introducer service connecting internationally mobile individuals with financial specialists. Full company registration details will be published here once our entity formation is complete.

For privacy-related enquiries, or to exercise your data subject rights, contact our Data Protection Officer at: privacy@pharosintroductions.com

2. What data we collect and why

2a. Enquiry and lead data

When you complete a request form, we collect:

  • Full name and email address (to respond to your enquiry and make an introduction)
  • Phone number, if provided (to contact you about your enquiry)
  • Country of residence (eligibility check and adviser matching)
  • U.S. person status (regulatory compliance, FATCA-aware matching)
  • Financial topic / service category (adviser matching)
  • Free-text message (context for matching)

Legal basis: Legitimate interests - processing your enquiry and matching you with a suitable specialist is necessary for the service you are requesting.

2b. Location personalisation

We use your IP address to derive an approximate country and timezone for display purposes on our website (e.g. showing your local time in the page header). We use the geolocation data derived from your IP address by our hosting provider (Vercel) as part of standard request handling. No additional third-party geolocation service is used. Your IP address is not stored; only the derived country/timezone is used in memory for the current page session.

Legal basis: Legitimate interests - improving the relevance of information displayed to you.

2c. Technical / server logs

Our hosting provider (Vercel, Inc.) may collect standard server log data (IP address, browser user-agent, page URLs, timestamps) for security and performance monitoring. This data is retained for up to 30 days.

2d. Analytics and advertising data

We use the following measurement tools on this site:

  • Vercel Analytics and Speed Insights (Vercel, Inc.) - anonymised, aggregate data about how visitors use the site and how fast pages load (page views, referral source, device type, loading performance). These tools are cookieless and do not collect personally identifiable information.
  • Google Analytics (Google LLC) - aggregate usage statistics that help us understand which pages are useful. Loads only if you accept analytics cookies in the cookie banner.
  • Microsoft Clarity (Microsoft Corporation) - session replay and heatmaps that show us how visitors interact with pages so we can improve them. Loads only if you accept analytics cookies in the cookie banner.
  • Meta Pixel (Meta Platforms, Inc.) - measures the effectiveness of our advertising. Loads only if you accept advertising cookies in the cookie banner.

Legal basis: Consent for Google Analytics, Microsoft Clarity and the Meta Pixel, given and withdrawable at any time through the cookie banner (managed by CookieYes). Legitimate interests for Vercel Analytics and Speed Insights, which operate without cookies or personal data.

3. How we store and protect your data

Enquiry data is stored in encrypted form on servers located in the United States and European Economic Area, via our hosting provider Vercel, Inc.. We do not use the data for marketing without your explicit consent. We do not sell your data to third parties.

We retain enquiry data for 2 years from the date of submission, after which it is deleted.

4. Who we share data with

We share personal data only where necessary:

  • Matched financial specialist - when an introduction is made, we share your name, contact details, country, and relevant context with the matched specialist. You will be informed before any introduction is made.
  • Google LLC (Google Workspace) - enquiry data submitted via our request form is stored in an encrypted Google Sheets spreadsheet accessible only to the site owner. Google acts as a data processor under the Google Workspace Data Processing Agreement.
  • OpenAI, Inc.- if you use the AI assistant feature on our site, your chat messages are sent to OpenAI's API to generate responses. OpenAI acts as a data processor under their Data Processing Addendum. Conversation data is not stored beyond your session. Please avoid sharing sensitive personal data in chat.
  • Email delivery service - to send notification emails to our team and, where applicable, confirmation emails to you. We use a third-party SMTP email delivery provider for this purpose. The specific provider is available on request from our Data Protection Officer.
  • Hosting / infrastructure provider (Vercel, Inc.) - as necessary for operating the service, including anonymised analytics as described in section 2d. Vercel processes data under their Data Processing Addendum.
  • Workflow automation provider (Make.com) - routes form submissions from the website into our secure enquiry records. Make acts as a data processor.
  • Meta Platforms, Inc. - where you have accepted advertising cookies, Meta receives advertising measurement events as described in section 2d. Where your enquiry originated from one of our advertisements, we may also send Meta a conversion signal so advertising can be measured and improved; contact details in these signals are hashed before transmission. We rely on our legitimate interest in measuring and improving our advertising for these conversion signals. You can object to this processing at any time by contacting our Data Protection Officer.

We do not sell your data. We never share your details with your existing financial adviser, and beyond the advertising measurement described above we do not share personal data with any third party for marketing purposes.

5. International transfers

Our service operates internationally. Where personal data is transferred across borders, we rely on appropriate safeguards including Standard Contractual Clauses (SCCs) to ensure an equivalent level of protection for your data.

6. Your rights

Depending on your country of residence, you may have rights regarding your personal data, including the right to:

  • Access - request a copy of the personal data we hold about you
  • Rectification - ask us to correct inaccurate data
  • Erasure - ask us to delete your data
  • Restriction - ask us to limit how we use your data
  • Portability - receive your data in a machine-readable format
  • Object - object to processing based on legitimate interests

To exercise any of these rights, email our Data Protection Officer at privacy@pharosintroductions.com. We will respond within 30 days.

You also have the right to lodge a complaint with a supervisory authority at any time. If you are based in the UK, you may contact the Information Commissioner's Office (ICO). If you are based in the EEA, please contact your local data protection authority. We would, however, appreciate the opportunity to address your concerns directly before you approach a regulator.

7. Cookies

For information about the cookies we use, please see our Cookie Policy.

8. Changes to this policy

We may update this policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the site after a change constitutes acceptance of the updated policy.