1. Who we are and what this policy covers
Last updated: November 2026
Golden Gate Advisors (“GGA,” “we,” “us”) helps accredited investors and their families evaluate EB-5 real estate investments in the United States. We are based in Dubai, United Arab Emirates.
This policy explains how we collect, use, share and protect your personal data when you:
- visit gga.ae;
- request an executive briefing, the investor brief or a strategy call;
- speak, message or correspond with us; or
- move forward with an investment and complete investor verification.
GGA is the controller of your personal data: we decide why and how it is used. If you have any question about this policy, write to eb5@gga.ae.
2. Information we collect
We collect only what we need to answer your request and, if you decide to invest, to support your investment and immigration process.
Information you give us
- Contact details: your full name, email address and country of residence. If you share them, we also keep your phone or WhatsApp number, city, nationality and preferred language.
- Investor status: your confirmation that you are an accredited investor under U.S. SEC Regulation D and that you understand the risks of an EB-5 investment.
- Conversation details: notes from calls and messages, such as your goals, timeline, budget, the family members who would join your EB-5 petition, and the questions you ask.
- Verification and due-diligence documents: only if you move forward with an investment (see section 4).
Information collected automatically
When you visit gga.ae, our hosting provider’s servers record technical data. This includes your IP address, browser and device type, the pages you view, and the date and time of your visit. We use it to deliver and secure the site.
Information from others
With your permission, we may receive information about you from your attorney, accountant or financial adviser, or from a partner who introduced you to us.
3. How we use your information
We use your information only for the purposes below. We do not sell your personal data, and we do not make decisions about you by automated means alone.
| Purpose | Information used | Legal basis |
|---|---|---|
| Respond to your briefing request and send the investor brief | Contact details, country of residence | Your consent, given when you submit the form |
| Schedule and hold strategy calls, and follow up | Contact and conversation details | Your consent; steps you ask us to take before an agreement |
| Confirm investor eligibility and complete identity, anti-money-laundering and source-of-funds checks | Investor status, verification documents | Legal obligation; performance of our agreement with you |
| Introduce you to the project sponsor, regional center and other parties needed for your investment | Contact, conversation and verification details | Performance of our agreement with you; your consent |
| Send updates on EB-5 offerings, deadlines and events | Contact details | Your consent, which you can withdraw at any time |
| Run and secure our website | Technical data | Our need to keep the site working and secure, or your consent where your local law requires it |
| Meet legal duties, answer lawful requests from authorities, and establish or defend legal claims | Any information relevant to the matter | Legal obligation; legal claims |
If we want to use your information for a new purpose, we will tell you first and, where required, ask for your consent.
4. Investor verification and due diligence
Companies that sell investments under U.S. SEC Rule 506(c) must take reasonable steps to confirm that every investor is accredited. EB-5 petitions must also show the lawful source of the invested funds. So if you decide to move forward, we, the project sponsor or a verification provider may ask for:
- Identity documents: passport, national ID and proof of address. For family members who will join your petition, we may also ask for passports and birth or marriage certificates.
- Proof of accredited status: for example, tax returns or income statements, bank or brokerage statements, a letter from your lawyer, accountant or licensed adviser, or a signed statement where the offering’s minimum investment allows it.
- Source-of-funds records: documents showing where your investment capital came from, such as bank, business, property-sale, gift or loan records.
- Screening results: anti-money-laundering, sanctions and politically-exposed-person checks.
We ask for these documents only when they are needed. We collect them through secure channels and share them only with the parties in section 5 who need them for your investment or petition.
5. Who we share your information with
We share your information only with the parties below, and only what each one needs. We never sell or rent your personal data, and we do not let others use it for their own marketing.
- Project sponsor and regional center: the regional center sponsoring the project you are evaluating, and the project’s developer, so they can answer your questions, hold follow-up calls and process your subscription.
- Professional advisers: your immigration attorney, and our own lawyers, accountants and auditors.
- Transaction and verification providers: escrow agents, fund administrators, accredited-investor verification services, and identity and anti-money-laundering screening providers.
- Service providers who work for us: website hosting, email, CRM, scheduling, video-call and secure document storage tools. They may use your data only on our instructions.
- Authorities: U.S. Citizenship and Immigration Services, the U.S. Securities and Exchange Commission, UAE regulators, courts or law enforcement, when the law requires it or to protect our legal rights.
- A buyer or successor: if GGA’s business is merged, sold or restructured, under the same protections described here.
6. International transfers
EB-5 is a U.S. program, so your information will be transferred from where you live and from the UAE to the United States. Some of our service providers may also store data in other countries.
We transfer personal data only where at least one of these applies:
- the destination country has been recognised as giving an adequate level of protection;
- the transfer is needed to carry out the investment or service you asked for;
- we have a written agreement with the recipient that requires it to protect your data; or
- you have given your express consent.
Where the law of your country requires separate consent before your data leaves it, we will ask for that consent first.
7. How long we keep your information
We keep personal data only as long as we need it, then delete it or make it anonymous.
| Information | How long we keep it |
|---|---|
| Briefing requests and call notes, if you do not invest | Until we no longer need them to respond to you or follow up, then deleted |
| Investor, verification and transaction records | For the life of your investment and EB-5 process, and afterwards for as long as anti-money-laundering, securities or tax law requires |
| Marketing preferences | Until you unsubscribe; we keep a record of your opt-out so we don’t contact you again |
| Website server logs | A short period set by our hosting provider for security purposes |
We may keep information longer if we need it to resolve a dispute or defend a legal claim.
8. Cookies and similar technologies
gga.ae does not currently use advertising or analytics cookies, tracking pixels or similar tools.
- Essential technology: our site uses only the cookies and server functions it needs to load pages securely. You can block cookies in your browser, but some parts of the site may not work.
- Fonts: our pages load fonts from Google Fonts, so Google receives your IP address and browser details when you visit. Google’s privacy policy governs that data.
If we add analytics or advertising tools, such as Google Analytics or the Meta Pixel, we will update this policy first. Where the law requires it, we will ask for your consent before setting those cookies, and you will be able to change your choice at any time.
9. Your rights
You can ask us at any time to:
- access the personal data we hold about you and learn how we use it;
- correct information that is wrong or incomplete;
- delete your information;
- restrict or stop how we use it, including for marketing;
- receive a copy of the information you gave us in a common electronic format;
- withdraw your consent, which does not affect what we did before you withdrew it; and
- ask for a human review of any decision made about you solely by automated means.
To make a request, email eb5@gga.ae. We may need to confirm your identity first. We will reply within the time the law requires.
We may be unable to delete some records, such as verification and transaction files, while anti-money-laundering, securities or tax law requires us to keep them. If that happens, we will tell you why.
If you are unhappy with how we handled your data, please contact us first. You can also complain to the relevant data protection authority in the UAE or in your own country.
If you live outside the UAE: many of the countries our investors come from, including Saudi Arabia, India, China, Brazil, South Africa, Nigeria, South Korea and Turkey, have their own data protection laws. Where those laws give you additional rights, we will honour them.
10. How we protect your information
We use technical and organisational safeguards to protect your information from loss, misuse and unauthorised access. These include encrypted (HTTPS) connections on gga.ae, access limited to the team members who need it, and confidentiality agreements with the partners and providers who handle your data.
No system is completely secure, so we cannot guarantee absolute security. If a breach affects your personal data, we will notify you and the relevant authorities as the law requires.
11. Marketing, family members and other websites
Marketing. We send updates about EB-5 offerings, deadlines and events only if you agreed to receive them. Every email includes an unsubscribe link, and you can also opt out by writing to eb5@gga.ae.
Family members. Our services are for adults, and we do not knowingly collect data directly from anyone under 18. If you give us details about your spouse or children for an EB-5 petition, please make sure they know you are sharing them. We use that information only for your application.
Other websites. Our site or emails may link to websites we do not control, such as project sponsors or government agencies. Their privacy policies apply when you visit them.
12. Changes to this policy and how to contact us
We may update this policy as our services or the law change. The date at the top shows the latest version. If a change significantly affects how we use your data, we will tell you by email or with a notice on our website before it takes effect.
For questions, requests or complaints about your personal data, contact us:
Golden Gate Advisors
- Dubai, United Arab Emirates
- Email: eb5@gga.ae