5. Who we share your information with

We share your information, on a need-to-know basis, with:

• the local lawyers, notaries, mortgage brokers, property hunters, property managers, and contractors we engage on your behalf in Spain, France, Portugal, Morocco, and Canada;

• regulators, courts, and other public authorities where the law requires us to disclose;

• our own professional advisors, including counsel, accountants, and auditors;

• the IT and infrastructure providers who host our systems, who act as our processors under written agreements that bind them to handle your data only on our instructions and to the standard described in this notice.

Among the recipients listed above, the local lawyers, notaries, banks, mortgage brokers, regulators, and public authorities act as independent data controllers under the laws of their jurisdiction — they decide how they use your information for their own statutory and professional purposes. Our IT and infrastructure providers, by contrast, act as our processors and handle your data only on our written instructions.

Sea of Sinbad does not sell your data. We do not share it for advertising. We do not pass it to property developers or sales agents without your explicit instruction.

6. International transfers

Because we are established in Kuwait, your property may be in the EU or in Morocco or in Canada, and the specialists supporting you sit in several of those jurisdictions, your information will inevitably cross borders during an engagement.

We rely on the following safeguards. For transfers out of the EU and EEA, we use the European Commission's Standard Contractual Clauses with the recipient. Every engagement letter we sign with a local specialist contains written confidentiality and data-protection clauses. And, as a firm policy, we handle the data of every client to a GDPR-level standard regardless of where the data physically sits.

Where personal data is transferred from the EU or EEA to a country without a European Commission adequacy decision, we assess the transfer against the laws and practice of the destination country and apply supplementary technical, contractual, or organisational measures where the assessment indicates they are needed.

Typical destinations for your information during an engagement are Kuwait (our base), Spain, France, Portugal, Morocco, and Canada, together with the European providers we use for hosting and analytics. You can ask us at any time for details of the safeguards that apply to a specific transfer by writing to privacy@sos-wealth.com, and we will give you a copy of the relevant clauses, with any commercial terms redacted.

7. How long we keep your information

We keep your information only for as long as we need it.

Know-your-client and anti-money-laundering records are kept for the period required by Kuwaiti law, currently five years from the end of our relationship with you. Where identification details appear both in the dedicated KYC file and inside the engagement file itself — for example, where they have been cited in a briefing note or in correspondence with a local specialist — the dedicated KYC copy is destroyed at the five-year mark, and any references that remain inside the engagement file are kept under the 10-year engagement-record rule.

Engagement records — correspondence, briefing notes, and our own working files — are kept for the duration of the advisory relationship and for ten years after the end of the engagement, unless a longer period is required for litigation, tax, anti-money-laundering, or other professional record-keeping obligations. Marketing data is kept only while you remain opted in; if you withdraw consent we stop using it for marketing immediately, and we delete it on the next routine purge unless we are required to keep evidence of the consent itself.

8. Your rights

You have, in summary, the right to:

•       ask us what information we hold about you and request a copy (access);

•       ask us to correct information that is wrong or out of date (rectification);

•       ask us to delete information we no longer need (erasure);

•       ask us to restrict how we use information while a question about it is resolved (restriction);

•       ask us to send your information to you, or to another provider, in a portable format (portability);

•       object to a particular use of your information (objection);

•       withdraw consent at any time where we rely on consent (withdrawal).

These rights come from the GDPR for readers in the EU and EEA. Equivalent rights exist under Morocco's Law 09-08, Kuwait's CITRA Data Privacy Protection Regulation, Canada's PIPEDA, and Quebec's Law 25.

To exercise any of these rights, write to privacy@sos-wealth.com. We will respond within 30 days. There is no charge unless your request is manifestly unfounded or excessive, in which case we will tell you and explain why.

If you are not satisfied with our response, you have the right to complain to the data protection supervisory authority where you live or work. Depending on where you are, that is the CNIL in France, the AEPD in Spain, the CNPD in Portugal, the CNDP in Morocco, the Office of the Privacy Commissioner of Canada (or the Commission d'accès à l'information for Quebec residents), or CITRA in Kuwait.

Where a request affects information we have already shared with a specialist handling your transaction — a lawyer, notary, bank, mortgage broker, or property manager — we will pass it on to them so that they can consider it under their own obligations as an independent controller.

Where we rely on your consent to send you updates, market briefings, or invitations, you can withdraw that consent at any time: click the unsubscribe link in any email we send you, reply STOP to an SMS or WhatsApp message, or write to privacy@sos-wealth.com. Withdrawal takes effect immediately and does not affect anything we did with your data before the withdrawal.

9. Cookies and analytics

The site uses a small number of cookies. We use strictly necessary cookies that allow the site to function, and a limited set of analytics cookies that help us understand which pages our visitors read and how they arrived. You can accept, refuse, or change your cookie preferences from the banner that appears the first time you visit, or at any time through your browser settings.

Our separate Cookie Policy (linked from the footer of every page on this site) lists every cookie we use, what it does, and how long it stays on your device.

10. Security

We protect your information through encrypted storage and encrypted transmission, access controls that limit each member of the team and each external specialist to the data they need to do their work, and written confidentiality terms with every counterparty we share information with.

If something goes wrong — if there is a personal data breach that materially affects you — we will tell you, and we will tell the relevant supervisory authority, within 72 hours of becoming aware of it. The exact timing and scope of any notification will depend on the level of risk the breach poses to you and on the obligations that apply under Kuwait's CITRA regulation (which can require shorter notification windows for breaches affecting a large number of users), the GDPR, Morocco's Law 09-08, Canada's PIPEDA, and Quebec's Law 25.

11. Children

The site and our services are not aimed at anyone under 18, and we do not knowingly collect personal data from children. If you believe a child has shared information with us, please write to privacy@sos-wealth.com and we will delete it.

12. Changes to this policy

When we update this notice, the "last updated" date at the top changes. If a change materially affects how we handle your data, we will notify our active clients by email before it takes effect.

13. Contact us

For any privacy question, complaint, or rights request, write to privacy@sos-wealth.com.

Our registered address in Kuwait is Mubarak Al Kabeer Street, Block 6, Building 13, Burj Maryam, Sharq.

Last updated: 21 June 2026