Privacy & Cookie Policy
Effective Date: June 4, 2025
Company: Clifton Vogel
Corporate Seat: Tokyo, Japan
Our Commitment To Discretion
At Clifton Vogel, we understand that the protection of personal data and absolute confidentiality are foundational to serving our global private clients, corporate entities, charities, and multi-generational families. This Privacy and Cookie Policy outlines how we collect, process, secure, and manage data when you interact with our digital platform, in strict accordance with Japanese and international data protection laws.
1. Information We Collect
To provide sophisticated asset coordination, direct account custody, and cross-border wealth solutions, we may process both personal and non-personal data:
- Identity and Contact Data: Name, email address, corporate or charitable affiliation, geographic location, and telephone numbers submitted via our secure inquiry channels.
- Family and Legacy Context: Voluntary data shared regarding family wealth structures or multi-generational account tracking (e.g., indicators regarding the presence of next-generation accounts).
- Financial and Account Data: Necessary documentation required to open and maintain direct financial accounts, including passport copies, tax identification numbers, and source of wealth verifications.
- Technical and Usage Data: IP addresses, browser types, operating systems, and anonymous interaction metrics collected during your visit to optimize site performance.
2. Legal Basis and How We Use Your Data
Clifton Vogel processes data strictly to fulfill your requests, execute corporate mandates, or satisfy regulatory requirements:
- To Manage Direct Custody and Accounts: Processing your personal and corporate details to establish, secure, and maintain direct, segregated financial accounts under our management.
- To Initiate and Manage Relationships: Processing your secure inquiries to establish customized wealth advisory, corporate treasury, or family office onboarding.
- To Personalize Platform Experience: Tailoring our static institutional insights and private market overview access based on your specific profile (e.g., charity, endowment, or private family head).
- Compliance and Corporate Governance: Meeting strict statutory obligations regarding anti-money laundering (AML), tax reporting harmonization, and cross-border jurisdictional verification.
We never sell, lease, or commercially trade your personal information or institutional data to any third party.
3. Global Data Transfers and Storage
As a boutique firm serving an international clientele from Tokyo, Japan, your data may cross international borders.
- International Standards: We store data using enterprise-grade, encrypted cloud environments. Cross-border transfers comply fully with Japan’s APPI and the European Union’s GDPR standard contractual clauses.
- Direct Custody Isolation: Because Clifton Vogel holds your assets directly in segregated accounts, all underlying client account documentation, trade histories, and balance details are ring-fenced within our proprietary, highly secure systems, isolated entirely from external commercial networks.
4. Data Retention and Absolute Security
We retain personal and corporate data only as long as necessary to fulfill the operational purposes outlined or to comply with Japanese corporate and financial record-keeping laws.
- Encryption Measures: All communications, form submissions, and user interactions on this site are shielded by advanced Transport Layer Security (TLS/SSL) encryption.
- Access Control: Internal access to any client data or account records is strictly limited to authorized Clifton Vogel partners bound by absolute professional secrecy and confidentiality agreements.
5. Your Legal Rights
Depending on your residency and local jurisdictions (such as the EU/UK or Japan), you possess the following rights regarding your data:
- Access and Rectification: The right to request a copy of the personal information Clifton Vogel holds about you or your entity, and to correct any inaccuracies.
- Erasure (“Right to be Forgotten”): The right to request the total deletion of your data, provided it does not conflict with Japanese statutory financial and asset retention laws.
- Restriction and Objection: The right to restrict specific types of non-essential data processing or withdraw consent at any time.
To exercise any of these rights, please contact our Compliance Office directly via our secure Private Intake section or via the corporate contact details provided below.
6. Cookie and Tracking Framework
To preserve the clean, premium minimalist layout of our platform, Clifton Vogel utilizes cookies conservatively. We avoid aggressive commercial or ad-retargeting scripts.
What are Cookies?
Cookies are small, secure text files placed on your device to ensure website functionality, security, and smooth user navigation.
How We Use Cookies
- Essential Cookies: Strictly necessary to run the site securely, support encrypted traffic, and remember your choices (such as locale or language settings).
- Analytical Cookies: Anonymized metrics that tell us how visitors move through our pages, helping us optimize scannability without identifying individuals.
Managing Your Preferences
You can completely control, disable, or clear cookies via your individual browser settings. However, disabling all cookies may degrade certain secure navigation features on our platform.
7. Updates to This Policy
Clifton Vogel reserves the right to modify this policy to align with changing global data compliance standards. Any structural updates will be posted directly to this page with a revised effective date.
8. Contact Information
For formal privacy inquiries, data subject requests, or regulatory questions, please correspond with our corporate headquarters:
Clifton Vogel Legal & Compliance Department
Tokyo, Japan
info@cliftonvogel.com