Privacy Policy

This Privacy Policy explains how Rubinov Global LLC ("Rubinov Global," "we," "us," or "our") collects, uses, shares, and protects personal information when you visit rubinovglobal.com, submit an inquiry, complete our invitation-only client intake, or otherwise deal with us as a prospective client, client representative, business contact, or vendor.

This policy does not cover third-party websites linked from our Site, or information about our own employees. A signed engagement agreement or a more specific notice may also apply to you.

1. Information We Collect

Information you provide through the inquiry form

Your name, organization, title, work email address, country, area of interest, a description of your inquiry, how you heard about us, and your acknowledgment of this Privacy Policy.

Information you provide through the private client intake

The client intake is available only by personal invitation. Depending on the engagement, it may collect:

• Contact details: name, title, work email address, telephone number, and preferred contact method.
• Organization details: legal name, organization type, jurisdiction and date of formation, registration and tax identification numbers, addresses, ownership and control structure, and directors and officers.
• Identification details for individuals (owners, controllers, officers, and signatories): full name, date and place of birth, nationality, residential address, government identification document details and copies, and tax identification numbers.
• Engagement details: the objective, markets, timeline, counterparties, and advisors involved.
• Financial information: source of funds, source of wealth, banking relationships, and approximate revenue, transaction value, or net worth.
• Compliance declarations: politically exposed person status, sanctions exposure, and any criminal, litigation, or regulatory history.
• Documents you upload, and the typed name, date, and declarations you submit.

Information collected automatically

When you use the Site, we and our service providers collect your IP address, approximate location derived from it, browser and device type, pages viewed, referring page, dates and times of visits, and diagnostic and security logs. For the client intake, we also keep an audit log of invitation opens, verification attempts, and submissions, including the IP address and time of each declaration.

We use analytics cookies only if you accept them, and we do not use analytics on the client intake. See our Cookie Policy.

Information from other sources

We may obtain information from public records, corporate registries, sanctions and watch lists, adverse-media searches, referrals, counterparties, and due diligence providers.

Sensitive information

Some information collected through the client intake, such as government identification numbers and financial account details, may be treated as sensitive under applicable law. We collect it only to verify identity and meet our legal and compliance obligations, and we do not use it to infer characteristics about you.

2. How We Use Personal Information

• To respond to inquiries and communicate with you.
• To issue and manage client intake invitations and verify that the person completing the intake is the invited recipient.
• To evaluate potential engagements, including strategic fit and conflicts of interest.
• To conduct know-your-customer, anti-money-laundering, sanctions, politically exposed person, and adverse-media screening.
• To perform, manage, and document engagements.
• To operate, secure, and maintain the Site, and to prevent spam, fraud, and abuse.
• To understand how the Site is used, where you have consented to analytics cookies.
• To comply with law, legal process, and record-keeping obligations, and to establish, exercise, or defend legal claims.

Limits on use. We use identification documents, financial information, and compliance declarations collected through the client intake only to verify identity, assess the potential engagement, and meet our legal and compliance obligations. We do not use them for marketing, to train artificial intelligence models, or for any unrelated purpose.

Screening results. If sanctions or background screening returns a possible match, we will, where the law permits, give you an opportunity to clarify before we make a decision.

We do not sell personal information, and we do not use it for targeted advertising. We do not currently send marketing newsletters. If we do in the future, every message will include an unsubscribe option.

3. Confidentiality of Client Intake Information

We treat all information and documents you submit through the client intake as confidential.

• Only named, authorized Rubinov Global staff can access client intake information.
• We will not use or disclose your intake information to advise or act for anyone else, even if we decline the engagement.
• We will not disclose that you contacted us or applied to become a client, and we will not use your name, logo, or matter in any marketing, case study, or client list without your written consent.
• We do not request confidential business information until any applicable non-circumvention and non-disclosure agreement (NCNDA) has been signed. The NCNDA is sent separately so you can review it with your counsel.

Information sent through the public inquiry form is a first contact. It is handled as described in this policy but is not subject to the confidentiality commitments in this section.

4. How We Share Personal Information

We share personal information only as follows:

• Our personnel who need it for the purposes above. Client intake information and documents are accessible only to named, authorized Rubinov Global staff.
• Service providers acting on our behalf, including providers of website and data hosting, email delivery, form spam protection, website analytics (only with your consent), malware scanning of uploaded files, electronic signature, and IT and security services. Every service provider that handles client intake information must keep it confidential and secure, may use it only to provide services to us, and must store it in the United States.
• Professional advisers, such as our lawyers, accountants, and auditors, who are bound by duties of confidentiality.
• Counterparties or other third parties, only with your consent.
• Regulators, law enforcement, and courts, where required by law, including sanctions and anti-money-laundering laws, or where necessary to protect rights, property, or safety.
• A successor organization in connection with a merger, financing, reorganization, or sale of our business, which must honor the commitments in this policy.

5. Where We Store Information

Rubinov Global is based in the United States. The Site and the client intake are hosted in the United States, and client intake information and documents are stored in the United States. If you are located outside the United States, your information will be transferred to and processed in the United States, where data protection laws may differ from those in your country. Where the law requires, we will use an appropriate transfer mechanism.

6. How Long We Keep Information

We keep personal information only as long as needed for the purposes described in this policy, including legal, regulatory, tax, audit, and dispute-resolution requirements. Our standard retention periods are:

At the end of the applicable period, we delete or de-identify the information, unless we must keep it longer to comply with law or to resolve a dispute.

Deletion on request. If no engagement follows, you may ask us to delete your client intake information and documents. We will do so once any legally required retention period has ended, and we will confirm the deletion to you in writing.

7. How We Protect Information

We use administrative, technical, and physical safeguards appropriate to the information we hold. These include encryption in transit and at rest; malware scanning of uploaded files; single-recipient, expiring invitation links with email verification; automatic session time-outs; access limited to named, authorized personnel; and audit logging. No method of transmission or storage is completely secure. Please do not send sensitive documents by email; use the secure client intake or another method we approve.

If a security incident occurs. If we become aware of a security incident that affects your personal information, we will notify you promptly, and in any event within the time the law requires, and tell you what happened and what we are doing about it.

8. Your Choices and Rights

Cookies. You can accept or reject analytics cookies, and change your choice at any time, using "Cookie Preferences" in the Site footer.

Privacy rights. Depending on where you live, you may have the right to request access to, correction of, deletion of, or a copy of your personal information; to restrict or object to certain processing; and to withdraw consent where we rely on it.

How to make a request. Email to@rubinovglobal.com with "Privacy Request" in the subject line, or write to us at the address below. We will verify your identity before responding and will respond within the time the law requires. An authorized agent may submit a request for you with proof of authority.

Appeals. If we decline your request, you may appeal by replying to our decision with "Privacy Appeal" in the subject line. Where applicable, you may also contact your local data protection authority.

Concerns and complaints. If you have a concern about how we have handled your information, email to@rubinovglobal.com with "Privacy Concern" in the subject line. We will acknowledge it within 5 business days and respond in full within 30 days.

Limits. We may keep information where the law requires it, for example anti-money-laundering records, or where it is needed to establish or defend legal claims. We will not discriminate against you for exercising your privacy rights.

9. Children

The Site is intended for business audiences and is not directed to anyone under 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will delete it.

10. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or the law. The effective date at the top shows the current version. Where the law requires, we will give additional notice of material changes.

11. Contact Us

Rubinov Global LLC, 290 N Olive Ave, Unit 510, West Palm Beach, FL 33401

Email: to@rubinovglobal.com (subject: "Privacy Request") | Telephone: (561) 571-5451