Privacy Policy

Last updated: January 2026

CI Associates Wealth Management, S.A. (“CI Associates”, “we”, “us” or “our”) respects your privacy and is committed to protecting the personal data entrusted to us.

This Privacy Policy explains how we collect, use, store, disclose and protect personal data when you visit our website, submit an enquiry, communicate with us, request information about our services, become a prospective client or otherwise interact with CI Associates.

Our processing of personal data is governed primarily by Law No. 81 of 26 March 2019 on Personal Data Protection of the Republic of Panama and Executive Decree No. 285 of 28 May 2021. Where the European Union General Data Protection Regulation, Regulation (EU) 2016/679 (“GDPR”), applies to particular processing activities, we also process personal data in accordance with its requirements.

1. About CI Associates

CI Associates Wealth Management, S.A. is an investment adviser regulated by the Superintendencia del Mercado de Valores de Panama (“SMV”).

CI Associates Wealth Management, S.A. holds an Investment Adviser Licence issued by the SMV pursuant to Resolution No. SMV-247-20 dated 1 June 2020.

The licence authorises CI Associates Wealth Management, S.A. to conduct regulated investment advisory activities in accordance with applicable Panamanian securities legislation and SMV requirements.

For data protection purposes, CI Associates Wealth Management, S.A. acts as the data controller or “responsable del tratamiento” in relation to personal data processed for the purposes described in this Privacy Policy.

Registered or business address:

[INSERT CURRENT PANAMA BUSINESS ADDRESS]

Privacy contact:

[INSERT PRIVACY EMAIL ADDRESS]

2. Scope of this Privacy Policy

This Privacy Policy applies to personal data collected through:

• our websites and landing pages;
• website contact and enquiry forms;
• telephone, email and electronic communications;
• meetings and consultations;
• marketing communications;
• prospective-client interactions;
• events, seminars and professional networking activities; and
• other interactions with CI Associates.

Additional privacy notices or disclosures may be provided where particular services, products or regulatory processes require them.

3. Personal data we may collect

The information we collect depends on how you interact with us.

Contact and identification information

This may include:

• name;
• email address;
• telephone number;
• country of residence;
• nationality;
• occupation or job title;
• employer or business information; and
• other information provided through our forms or communications.

Information relating to investment advisory services

If you request advice, proceed with a consultation or establish a client relationship, we may collect additional information required to assess your circumstances and comply with our legal and regulatory obligations.

This may include, where appropriate:

• financial circumstances;
• investment objectives;
• investment experience;
• risk tolerance;
• tax residence;
• source of funds or source of wealth;
• information required for Know Your Customer procedures;
• information necessary to meet securities, regulatory, compliance and record-keeping requirements.

We only request information that is reasonably necessary for the relevant purpose.

Website and technical information

When you use our website, certain technical information may be collected automatically, including:

• IP address;
• device type;
• browser type and version;
• operating system;
• approximate geographic information derived from an IP address;
• pages visited;
• referral source;
• date and time of access;
• website interaction information; and
• cookie or similar technology identifiers.

4. How we collect personal data

We may obtain personal data:

• directly from you;
• when you complete a website form;
• when you contact us by telephone, email or another communication channel;
• during consultations or meetings;
• during client onboarding;
• from publicly available professional or business sources;
• from service providers acting on our behalf;
• from regulatory, compliance or identity-verification providers, where permitted by law; and
• automatically through our website and related technologies.

Where personal data is obtained from another legitimate source, we will process it in accordance with applicable data protection requirements.

5. How we use personal data

We may process personal data for the following purposes:

Responding to enquiries

To respond to requests for information, arrange consultations, communicate with prospective clients and provide information about our services.

Providing investment advisory services

To evaluate client circumstances, provide investment advice, maintain client relationships and administer the services requested from us.

Regulatory and legal compliance

To comply with obligations imposed by the SMV and other competent authorities, including record keeping, client identification, suitability or appropriateness requirements, anti-money laundering controls, sanctions screening, fraud prevention, regulatory reporting and other applicable legal obligations.

Business administration

To manage our operations, maintain internal records, administer our CRM and communication systems, manage relationships and improve our services.

Website operation and security

To operate, maintain, secure and troubleshoot our website and information systems, including detecting unauthorised activity, fraud, security incidents and misuse.

Analytics and website improvement

Where permitted and, where required, with your consent, we may analyse how visitors interact with our website to understand performance and improve content, functionality and user experience.

Marketing

Where permitted by applicable law, we may provide information concerning our services, market commentary, events or other relevant communications.

Where consent is required, marketing communications will only be sent after the appropriate consent has been obtained.

You may opt out of direct marketing at any time.

6. Legal grounds for processing

Under Panamanian data protection legislation, we process personal data where the processing is permitted by applicable law, including where we have obtained the consent of the data subject or another lawful condition for processing applies.

Where GDPR applies, our legal basis may include:

• your consent;
• taking steps at your request before entering into a contract;
• performance of a contract with you;
• compliance with a legal or regulatory obligation;
• our legitimate interests, where those interests are not overridden by your fundamental rights and freedoms; or
• another legal basis permitted under applicable legislation.

Where processing relies on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing undertaken before consent was withdrawn.

7. Cookies and similar technologies

Our website may use cookies and similar technologies to provide essential functionality, protect the website, remember preferences, measure website performance and, where applicable, support analytics or marketing activities.

Cookies that are strictly necessary for operation and security may be used without optional consent where permitted by applicable law.

Where applicable law requires consent for analytics, advertising or other non-essential technologies, those technologies will not be activated until the appropriate consent has been obtained.

You may manage your preferences through the cookie consent controls provided on our website.

Withdrawing consent does not affect processing that occurred lawfully before withdrawal.

8. Sharing personal data

We do not sell personal data.

We may disclose personal data where reasonably necessary to:

• companies providing IT, hosting, cybersecurity or technical support;
• CRM and business administration providers;
• communications and email service providers;
• website