5 Circles | Payment & Banking Architecture
5 Circles | Payment & Banking Architecture

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Privacy Policy

1. Introduction

Welcome to business-consult.co (operating under 5 Circles). We are headquartered in Paphos, Cyprus, and specialize in providing strategic architecture, proxy due diligence, and high-risk structuring for global merchants.

Because our core service involves auditing and structuring your business for Tier-1 banking access, we process highly sensitive corporate and personal data. This Privacy Policy outlines how we collect, use, protect, and disclose your information in compliance with the General Data Protection Regulation (GDPR) and applicable data protection laws.

2. Information We Collect

To provide our specialized consulting and banking mediation services, we collect the following categories of data:

  • Basic Contact Information: Name, corporate email address, phone number, and business address.
  • Corporate & Operational Data: Information regarding your business model, corporate structure, and operational history.
  • Due Diligence & Compliance Documentation (Document Intake): AML manuals, KYC/KYB dossiers, content moderation guidelines, and track record documentation required to assess institutional readiness.
  • Ecosystem & Supply Chain Data: Information regarding your counterparties, Payment Service Providers (PSPs), Ultimate Beneficial Owners (UBOs), and liquidity providers (The Ecosystem Map).
  • Website Usage Data: Standard analytics, IP addresses, and browsing behavior when you interact with business-consult.co.

3. How We Use Your Information

We process your data strictly to execute our consulting mandates and secure your banking architecture. Your information is used to:

  • Conduct Proxy Due Diligence: We utilize your counterparty and PSP information to run “Whitelist Checks” through our network, identifying any potentially toxic entities in your supply chain before applying for banking services.
  • Format & Restructure Documentation: We analyze and revise your AML/KYC guidelines to ensure they meet the “Institutional Grade” standards expected by Top-Tier banks.
  • Facilitate Banking Onboarding: We compile your cleansed data into a pre-qualified dossier for final submission to partner institutions (e.g., Bivial AG).
  • Provide Ongoing Consulting: To communicate with you regarding provider matching, ecosystem clean-ups, and strategic placements.

4. Data Sharing and Disclosure

Our business model relies on acting as a bridge between your business and regulated financial institutions. Therefore, we share your data under strict confidentiality agreements with:

  • Financial Institutions & Banking Partners: We share targeted due diligence information and final dossiers with Tier-1 banks and licensed payment service providers to facilitate your onboarding and validate your ecosystem.
  • Legal and Regulatory Authorities: We may disclose information if required to do so by law or in response to valid requests by public authorities (e.g., FINMA, CySEC, or local law enforcement).

Note on Transparency: We do not sell your data to third-party marketers. Data is shared exclusively to validate your business architecture and secure your banking infrastructure.

5. Data Security & Retention

We treat your corporate and personal data with the same rigorous security standards expected by the financial institutions we partner with.

  • Security: We employ industry-standard encryption, secure data silos, and strict access controls to protect your sensitive compliance dossiers and UBO information against unauthorized access, alteration, or destruction.
  • Retention: We retain your data only for as long as necessary to fulfill our consulting mandates, manage ongoing referral agreements, and comply with our legal and regulatory obligations.

6. Your Data Protection Rights (GDPR)

Under the GDPR, individuals operating within our client entities have the following rights regarding their personal data:

  • The right to access: You have the right to request copies of your personal data.
  • The right to rectification: You have the right to request that we correct any information you believe is inaccurate or incomplete.
  • The right to erasure: You have the right to request that we erase your personal data, under certain conditions.
  • The right to restrict processing: You have the right to request that we restrict the processing of your data, under certain conditions.
  • The right to object to processing: You have the right to object to our processing of your personal data.
  • The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you.

7. Changes to This Privacy Policy

We may update our Privacy Policy periodically to reflect changes in global regulatory frameworks (such as MiCA or nAMLA) or updates to our internal processes. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Effective Date” at the top.

8. Contact Us

If you have any questions about this Privacy Policy, the data we hold on you, or if you would like to exercise one of your data protection rights, please do not hesitate to contact us.

  • Website: business-consult.co
  • Location: Paphos, Cyprus
  • Email: privacy@business-consult.co