Privacy notice.
Triad Escrow (the “firm”) is regulated by the Superintendencia General de Entidades Financieras (SUGEF) of Costa Rica and is bound by the confidentiality and data-protection obligations applicable to fiduciaries under Costa Rican law.
1 · Personal data collected
We collect personal data from prospective and existing account holders for the purposes of due diligence, regulatory reporting, and the operation of escrow matters. This includes legal name, jurisdiction of residence, identity-document particulars, residence address, and source of funds, together with any documents the client uploads in support of the foregoing.
2 · Lawful basis
The lawful basis for processing is (i) compliance with anti-money- laundering and counter-terrorism financing obligations under SUGEF Acuerdo 8-08 and related guidance; (ii) performance of the firm’s fiduciary engagement with the client; and (iii) the legitimate interests of the firm in the prudent operation of its business.
3 · Retention
Personal data is retained for the longer of (i) the duration of any active matter in which the data subject is a party of record and (ii) the minimum retention period prescribed by Costa Rican law, currently five years from the date the matter is closed.
4 · Disclosure
Personal data is not disclosed to third parties save (i) to regulators, courts, or law-enforcement authorities under lawful process; (ii) to the firm’s banks for the operation of trust accounts; and (iii) to professional advisors of the firm bound by equivalent confidentiality obligations.
5 · Rights of the data subject
Data subjects have the right to access, rectify, and — subject to regulatory retention obligations — request the deletion of personal data held by the firm. Requests should be addressed to compliance@triadcr.com.
6 · Contact
The firm’s Compliance Officer is the designated point of contact for any privacy enquiry. Triad Escrow · Plaza Tempo, Escazú · San José, Costa Rica.