Data Protection Statement

With this Data Protection Statement we, Mirabello Consultancy Ltd (hereinafter Mirabello, we or us), describe how we collect and further process personal data. This Data Protection Statement is not necessarily a comprehensive description of our data processing. It is possible that other data protection statements are applicable to specific circumstances. The term “personal data” in this Data Protection Statement means any information that identifies, or could reasonably be used to identify any person.

If you provide us with personal data of other persons (such as family members, work colleagues), please make sure the respective persons are aware of this Data Protection Statement and only provide us with their data if you are allowed to do so and if such personal data is correct.

This Data Protection Statement is in line with the EU General Data Protection Regulation (GDPR). Although the GDPR is a European Union (EU) regulation, it may be relevant for us. The Swiss data protection legislation (FADP) is heavily influenced by EU law . In addition, companies outside the European Union or the European Economic Area (EEA) must comply with the GDPR in certain cases.

Controller

The “controller” of data processing as described in this data protection statement (i.E. the responsible person) is Mirabello Consultancy Ltd, unless we have informed you otherwise in certain cases. You can notify us of any data protection-related concerns using the following contact details: Klosbachstrasse 37 | 8032 Zurich | Switzerland | Tel: +41 (0)44 52 11 060 | mail@mirabelloconsultancy.com.

Collection and Processing of Personal Data

We primarily process personal data that we obtain from our clients and other business partners as well as other individuals in the context of our business relationships with them or that we collect from users when operating our websites, apps and other applications.

Insofar as it is permitted to us, we obtain certain personal data from publicly accessible sources (e.g.,, global databases, commercial registers, press, internet) or we may receive such information from our clients and their employees, from authorities, or other third parties (such as e.g., compliance companies). Apart from data you provided to us directly, the categories of data we receive about you from third parties include, but are not limited to, information from public registers, information in connection with your professional role and activities (e.g., in order to conclude and carry out contracts with you), information about you in correspondence and discussions with third parties, credit rating information (if we conduct business activities with you personally), information about you given to us by individuals associated with you (family, consultants, legal representatives, etc.) in order to conclude or process contracts with you or with your involvement (e.g., references, your delivery-address, powers of attorney), information regarding legal regulations such as anti-money laundering and export restrictions, bank details, information regarding insurance, our distributors and other business partners for the purpose of ordering or delivering services to you or by you (e.g.,, payments made, previous purchases), information about you found in the media or internet (insofar as indicated in the specific case, e.g., in connection with job applications, media reviews, marketing|sales, etc.), your address and any interests and other socio-demographic data (for marketing purposes), data in connection with your use of our websites (e.g., IP address, MAC address of your smartphone or computers, information regarding your device and settings, cookies, date and time of your visits, sites and content retrieved, applications used, referring website, localization data).

Purpose of Data Processing and Legal Grounds

We primarily use collected data in order to conclude and process contracts with our clients and business partners, in particular in connection with providing investment-migration advisory and coordination services to our clients and the procurement of products and services from our suppliers and subcontractors (e.g., foreign and domestic lawyers and law firms or experts), as well as in order to comply with our domestic and foreign legal obligations. You may be affected by our data processing in your capacity as an employee of such a client or business partner.

In addition, in line with applicable law and where appropriate, we may process your personal data and the personal data of third parties for the following purposes, which are in our (or, as the case may be, any third parties’) legitimate interest, such as:

providing and developing our products, services and websites, apps and other platforms, on which we are active;

communication with third parties and the processing of their requests (e.g., job applications, media inquiries);

advertising and marketing (including organizing events), provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time and we will place you on a blacklist against further advertising mailings);

market and opinion research, media surveillance;

asserting legal claims and defense in legal disputes and official proceedings;

the prevention and investigation of criminal offences and other misconduct (e.g., conducting internal investigations, data analysis to combat fraud);

ensuring our business operations, including our IT, our websites, apps and other appliances;

video surveillance to protect the domiciliary rights and other measures to ensure the safety of our premises and facilities as well as protection of our employees and other individuals and assets owned by or entrusted to us (such as e.g., access controls, visitor logs, network and mail scanners, telephone recordings);

possible corporate transactions and the transfer of personal data related thereto as well as measures for business management and compliance with legal and regulatory obligations as well as internal regulations of Mirabello.

If you have given us your consent to process your personal data for certain purposes (for example when registering to receive newsletters or carrying out a background check), we will process your personal data within the scope of and based on this consent, unless we have another legal basis, as long as we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.

Cookies | Tracking and Other Techniques Regarding the Use of our Website

We typically use “cookies” and similar techniques on our websites which allow for an identification of your browser or device. A cookie is a small text file that is sent to your computer and automatically saved by the web browser on your computer or mobile device, when you visit our website. If you revisit our website, we may recognize you, even if we do not know your identity. Besides cookies that are only used during a session and deleted after your visit to the website (“session cookies”), we may use cookies in order to save user configurations and other information for a certain time period (e.g., two years) (“permanent cookies”). Nevertheless, you may configure your browser settings in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies in order to understand how you use our services and content. If you block cookies, it is possible that certain functions (such as e.g., language settings, shopping basket, ordering processes) are no longer available to you.

We may use Google Analytics or similar services on our website. These are services provided by third parties, which may be located in any country worldwide (in the case of Google Analytics Google LLC is in the U.S., www.google.com) and which allow us to measure and evaluate the use of our website (on an anonymized basis). For this purpose, permanent cookies are used, which are set by the service provider. The service provider does not receive (and does not retain) any personal data from us, but the service provider may track your use of the website, combine this information with data from other websites you have visited and which are also tracked by the respective service provider, and may use this information for its own purposes (e.g., controlling advertisements). If you have registered with the service provider, the service provider will also know your identity. In this case, the processing of your personal data by the service provider will be conducted in accordance with its data protection regulations. The service provider only provides us with data on the use of the respective website (but not with any personal information on you).

We also use Microsoft Clarity, a service of Microsoft Ireland Operations Limited, Ireland, and Microsoft Corporation, USA, to understand how visitors use our website. Clarity records how you interact with our pages (for example clicks, scrolling and mouse movements), together with information about your device and browser, and uses this to create heatmaps and session replays; it sets cookies for this purpose. We use this information in our legitimate interest to improve our website, not to identify you. Microsoft may process the data in the USA and other countries (see "Datatransfer and Transfer of Data Abroad"). According to Microsoft, session replays are kept for 30 days, and heatmaps and a sample of replays for up to 9 months. You can block these cookies in your browser settings.

Mira, our AI Assistant

On our website we offer Mira, an assistant based on artificial intelligence that answers questions about citizenship, residency, relocation and related topics. Mira is an AI system, not a person. Its answers are generated automatically from our verified data, may contain errors and are general information, not legal, tax, financial or immigration advice. A Mirabello specialist confirms any specific case.

What we process: when you use Mira, we process the text of your questions and Mira's answers in order to answer you. We store your question, shortened to its first 200 characters, after automatically removing email addresses and long sequences of digits such as telephone, card or account numbers. Please do not enter such details, or identity-document numbers, in the chat. If you wish to be contacted, Mira asks for your name and email address and passes them to us only with your explicit consent.

Together with each stored question we record the language, which of our data sources Mira used, whether a consultation was requested, and which AI model generated the answer and at what cost. We do not store your IP address or Mira's answers, we do not set cookies for this purpose, and stored questions are not linked to one another or to your identity. If you rate an answer, we also record your rating and, where you choose one, the reason you selected, with that question and for the same period; we do not collect any written comment.

Free usage limit: to keep Mira available to everyone, the number of questions per visitor is limited. To count them, we keep a one-way, salted code derived from your internet connection and browser, from which your IP address cannot be recovered, for two days (daily count) and eight days (weekly count).

Why: we use this information to answer your question, to protect the service against misuse and, in our legitimate interest, to understand which topics people ask about, where our information is missing or unclear, and how to improve Mira, our website and our publications. We do not use it to identify you, to build a profile of you or for advertising, and we do not combine it with your client file unless you ask us to contact you.

Who receives it: to generate answers, your question and the relevant data are transmitted to AI service providers that we engage as processors, currently OpenAI Ireland Ltd, Ireland (with onward processing by OpenAI, L.L.C., USA), and, if that service is unavailable, Mistral AI SAS, France, or Google LLC, USA. Under these providers' terms for business use, they do not use the content we send them to train their AI models; they may keep it for a limited period to detect misuse. Our website and the stored questions are hosted by Cloudflare, Inc. (USA and a global network). If you ask to be contacted, your details are sent to our team by email through Resend and recorded in our client-relationship management system, HubSpot, hosted in its EU data centre. These providers may process data outside Switzerland and the EEA; see "Datatransfer and Transfer of Data Abroad".

How long: stored questions are deleted automatically after 120 days. Contact details you give us are retained as described under "Retention Periods for your Personal Data".

Mirabello Immigration Intelligence in AI Assistants

Mirabello Immigration Intelligence is available inside AI assistants such as ChatGPT, Claude and Grok through our server at mcp.mirabelloconsultancy.com, which runs on the infrastructure of our hosting provider, Cloudflare. When you use it there, your assistant sends our server only the details needed for the question you asked, such as a programme, a country code, your citizenship or a budget. We do not receive your conversation with the assistant; that conversation is governed by the privacy policy of the assistant's provider.

Usage statistics: we record which tool was used, whether it succeeded, the type of assistant and a technical session identifier provided by the assistant, in order to keep the service reliable and to understand which features are used. No name, email address or IP address is stored with them. They are kept for three months.

Planning questions: when you ask for a route plan, we keep the citizenship(s), tax residence, goal, budget and timeline you provided, without your name or contact details, for 90 days, in order to improve the planner and understand demand.

Briefing pages: a personalised briefing page you request is kept for 90 days so that you can open its link.

Consultation requests and property enquiries: only when you ask to be contacted and give your consent do we receive the details you provide, such as your name, email address, phone number, the programme or property of interest, budget and timeline. They are sent to our team by email through our email service provider, Resend, recorded in our client-relationship management system, HubSpot, hosted in its EU data centre, and retained as described under "Retention Periods for your Personal Data". The technical copy on our server is deleted after 90 days.

Change alerts: if you subscribe, we keep your email address or webhook address and your programme selection until you unsubscribe using the link we provide.

The planning and information tools work without any contact details. Nothing is sent to our team unless you request a consultation or an enquiry and give your consent. You can unsubscribe from alerts at any time and exercise the rights described under "Your Rights" by contacting us.

Datatransfer and Transfer of Data Abroad

In the context of our business activities and in line with the purposes of the data processing set out in Section 3, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients may be concerned:

our service providers (such as e.g., banks, insurance companies), including processors (such as e.g., IT providers);

suppliers, subcontractors (such as foreign and domestic lawyers and law firms or experts) and other business partners;

clients as well as their affiliates and opposing parties in Switzerland or abroad;

This includes the providers of the AI services we use to operate Mira, our AI assistant, as well as our website hosting provider and our client-relationship management provider, which may process data in the USA and other countries. Where such a country does not provide an adequate level of data protection, we rely on the standard contractual clauses of the European Commission, recognised by the Swiss Federal Data Protection and Information Commissioner, or on another legal safeguard.

Retention Periods for your Personal Data

We process and retain your personal data as long as required for the performance of our contractual obligations and compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, during the performance of the contract until it is terminated) as well as beyond this duration in accordance with legal retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against our company (i.d. particularly during legal prescription periods) or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention (e.g., for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be deleted or anonymized, as far as possible. In general, shorter retention periods, of no more than twelve months, apply for operational data (e.g., system logs). Data received through Mirabello Immigration Intelligence in AI assistants is retained as described in the section "Mirabello Immigration Intelligence in AI Assistants". Questions asked to Mira are retained as described in the section "Mira, our AI Assistant". Backup copies of our systems, which are encrypted, access-restricted and used only to restore our services, are deleted on a rolling schedule, at the latest after three years.

Data Security

We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse such as internal policies, training, IT and network security solutions, access controls and restrictions, encryption of data carriers and transmissions, pseudonymisation, inspections.

Obligation to Provide Personal Data To Us

In the context of our business relationship, you must provide us with any personal data that is necessary for the conclusion and performance of a business relationship and the performance of our contractual obligations. As a rule, there is no statutory requirement to provide us with data. Without this information, we will usually not be able to enter into or carry out a contract with you (or the entity or person you represent). In addition, the website cannot be used unless certain information is disclosed to enable data traffic (e.g., IP address).

Your Rights

In accordance with and as far as provided by applicable law (as is the case where the GDPR is applicable), you have the right to access, rectify and erase of your personal data, the right to restriction of processing or to object to our data processing in addition to right to receive certain personal data for transfer to another controller (data portability). Please note, however, that we reserve the right to enforce statutory restrictions on our part, for example if we are obliged to retain or process certain data, have an overriding interest (insofar as we may invoke such interests) or need the data for asserting claims. If exercising certain rights incurs costs for you, we will notify you thereof in advance. We have already informed you of the possibility to withdraw consent in Section 3 above. Please further note that the exercise of these rights may be in conflict with your contractual obligations and this may result in consequences such as premature contract termination or involve costs. If this is the case, we will inform you in advance unless it has already been agreed upon contractually.

In general, exercising these rights requires that you are able to prove your identity (e.g., by a copy of identification documents when your identity is not evident otherwise or cannot be verified in another way). In order to assert these rights, please contact us at the addresses provided in Section 1 above.

In addition, every data subject has the right to enforce his|her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).

Amendments to this Data Protection Statement

We may amend this Data Protection Statement at any time without prior notice. The current version published on our website shall apply.