Privacy Notice

How IVERIS handles personal information.

Last updated: October 2026

Discretion is structural at IVERIS, and that includes personal information. This notice explains how IVERIS handles personal information of visitors to www.iveristrategies.com (the “Website”), of people who submit an inquiry or request IVERIS Insights, and of individuals IVERIS deals with in a business capacity, such as representatives of counterparties, partner institutions, advisers, and service providers.

Personal information of clients processed in the course of an engagement is governed by the documentation of that engagement, which prevails over this notice.

Controller

IVERIS STRATEGIES LTD (“IVERIS”) is responsible for the personal information described in this notice.

Privacy contact: confidential@iveristrategies.com

Information IVERIS collects

Private Inquiry. Full name, email address, country of residence, nature and description of the matter, how you found IVERIS, and preferred contact method; and, if you choose to provide them, organization, role or title, jurisdictions involved, and any additional context.

IVERIS Insights. Your email address, if you request access, your subscription preferences, and whether Insights emails are opened or their links followed.

Business contacts. Name, title, organization, business contact details, and professional background relevant to the relationship.

Communications. The content and details of emails and other communications with IVERIS.

Technical data. Information your browser sends automatically, such as IP address, browser and device type, pages visited, and date and time of access, recorded in server and security logs; and, only if you accept analytics, usage data as described in the Cookies Notice.

Please do not submit sensitive personal information, such as information about health, political opinions, or religious beliefs, nor confidential structures, client names, or transaction specifics, through the Website. None is needed at this stage.

Sources of information

Most information comes directly from you. IVERIS may also obtain information from the person or institution that introduced you to IVERIS; from your organization; from public sources such as company registries, professional profiles, and the media; and, for compliance screening, from sanctions lists and commercial screening databases.

Purposes and legal bases

Purpose	Information	Legal basis
Reviewing and responding to your inquiry, and assessing whether IVERIS can assist	Private Inquiry	Your consent, given when you submit the inquiry; steps taken at your request before any engagement; legitimate interest in responding to inquiries
Preliminary compliance screening before any engagement, including sanctions, politically exposed person, and adverse media checks, and conflict checks	Private Inquiry; business contacts; information from screening sources	Legal obligation, where applicable; legitimate interest in preventing financial crime and protecting the firm
Managing relationships with counterparties, partner institutions, advisers, and service providers	Business contacts; communications	Legitimate interest in conducting the firm’s business; performance of a contract with you or your organization
Reviewing subscription requests and sending selected Insights	Email address; Insights engagement data	Your consent, which you may withdraw at any time
Sharing IVERIS publications and information about the firm with professional contacts	Business contacts	Legitimate interest, or consent where the law requires it; you may object at any time
Operating, securing, and protecting the Website and the firm’s systems, and preventing fraud and impersonation	Technical data; communications	Legitimate interest in security and fraud prevention
Understanding use of the Website in aggregate	Analytics data	Your consent, given through the cookie banner
Complying with legal obligations, keeping records, and establishing, exercising, or defending legal claims	As needed	Legal obligation; legitimate interest

Where IVERIS relies on legitimate interest, it has weighed that interest against your rights and reasonable expectations. You may ask the privacy contact for more information about that assessment.

The fields marked as required in the Private Inquiry form are needed for IVERIS to respond; without them, IVERIS cannot review the inquiry.

Inquiry information is not used for marketing and is not added to any list. IVERIS does not sell personal information, does not use it for advertising, does not use information submitted through the Website to train artificial intelligence models, and does not make decisions based solely on automated processing that produce legal or similarly significant effects for you.

Recipients

Personal information is accessible to members of the IVERIS team who need it. IVERIS shares it only:

with service providers that host the Website and provide email, communications, technology, security, and compliance screening services and, where you have consented, analytics or Insights distribution, acting on IVERIS’s instructions and bound by confidentiality;
with professional advisers bound by duties of confidentiality, where needed;
with banks, partner institutions, or other counterparties, only with your prior agreement or where you have asked IVERIS to make an introduction;
where required by law, regulation, court order, or a competent authority, or to protect the rights and safety of IVERIS or others; and
with a successor entity in a reorganization of the firm, which will remain bound by this notice.

Other than as set out above, IVERIS does not share your inquiry with members of its ecosystem, partner institutions, or other counterparties without your prior agreement.

International transfers

IVERIS works internationally. Its team and service providers may process personal information in countries other than your own, including the Republic of Panama and the United States. Where the law requires it, IVERIS protects these transfers with appropriate safeguards, including, for transfers from the European Economic Area, the United Kingdom, or Switzerland, the standard contractual clauses approved by the European Commission and their United Kingdom and Swiss equivalents, or relies on another basis permitted by applicable law. You may request information on the safeguards used by writing to the privacy contact.

Retention

Inquiries, and related communications, that do not lead to an engagement: up to 24 months from the last communication, then deleted. If an engagement follows, the information becomes part of the engagement file and is kept under its terms.
Business contacts and communications: for as long as the business relationship continues and up to six years after the last interaction.
Compliance screening results: up to five years after the screening or the end of the relationship, whichever is later, or longer where the law requires.
Insights subscriptions: until you unsubscribe or withdraw consent. IVERIS keeps a minimal record of the withdrawal so that it is respected.
Server and security logs: up to 12 months, unless needed longer to investigate a security incident.
Cookie consent records: as stated in the Cookies Notice.

Information may be kept longer where the law requires it or where it is needed to establish, exercise, or defend legal claims. When it is no longer needed, it is deleted or anonymized.

Security

IVERIS applies technical and organizational measures proportionate to the sensitivity of the information, including encrypted transmission on the Website, access restricted on a need-to-know basis, and contractual security and confidentiality obligations for service providers. No transmission over the internet is completely secure. Where a matter requires it, indicate so in your inquiry and an encrypted channel will be arranged.

Your rights

Depending on the law that applies to you, you may have the right to access your personal information, rectify it, have it deleted, object to or restrict its processing, receive it in a portable format, and withdraw your consent at any time, without affecting processing already carried out. Under Law 81 of 2019 of the Republic of Panama, these include the rights of access, rectification, cancellation, opposition, and portability.

To exercise any of these rights, write to the privacy contact. Requests are free of charge. IVERIS may ask you to verify your identity, or, if you act through a representative, to provide evidence of authority, and will respond within the time limits set by applicable law. Where the law allows, IVERIS may decline requests that are manifestly unfounded or excessive, and will explain why. Exercising your rights will not lead to any less favorable treatment.

Complaints

You may lodge a complaint with a supervisory authority: in Panama, the Autoridad Nacional de Transparencia y Acceso a la Información (ANTAI); in the European Economic Area, the United Kingdom, or Switzerland, the data protection authority where you live or work. IVERIS would welcome the opportunity to address any concern first.

Residents of the United States

IVERIS does not sell personal information or share it for cross-context behavioral advertising, and does not use sensitive personal information to infer characteristics about you. Residents of US states with consumer privacy laws may exercise the rights those laws grant by writing to the privacy contact.

Minors

The Website is intended for professionals and is not directed at anyone under 18. IVERIS does not knowingly collect personal information from minors.

Changes to this notice

IVERIS may update this notice. The current version and its date are always available on this page.

Contact

Privacy matters: confidential@iveristrategies.com