Privacy Policy

This Privacy Policy applies to Rowe & Wren LLC, a United States limited liability company, doing business as "Portunus" and "PortunusAI" ("Portunus," "we," "us," or "our").

This Privacy Policy explains how we collect, use, disclose, and protect personal information when you access or use our website, platform, and related services (collectively, the "Services").

Our Services are offered globally. If you are located outside the United States, your information may be transferred to, stored, and processed in the United States or other jurisdictions as described below.

1. Legal Bases for Processing

Where required by applicable data protection laws, including the EU General Data Protection Regulation and UK GDPR, we process personal data only when we have a lawful basis to do so. These legal bases include:

• Performance of a contract – to provide our Services, process eligibility assessments, generate documentation, and manage user accounts.
• Consent – where you have explicitly agreed to our processing (for example, marketing communications).
• Legitimate interests – to operate, improve, and secure our Services, provided those interests are not overridden by your rights.
• Legal obligation – to comply with applicable laws, regulations, or lawful requests from authorities.

Where we rely on consent, you may withdraw it at any time by contacting us using the information provided below.

2. Data Controller

For the purposes of applicable data protection laws, Rowe & Wren LLC (dba Portunus) is the data controller of your personal information.

If you are located in the European Union or United Kingdom, you have the right to lodge a complaint with your local data protection authority if you believe we have infringed your rights.

3. Information We Collect

Personal Information

When you use our services, we may collect the following personal information:

• Name, email address, and contact information
• Passport and citizenship information
• Business information and investment details
• Financial information necessary for E-2 visa preparation
• Documents you upload for your visa application
• Payment and billing information

Automatically Collected Information

• IP address and device information
• Browser type and operating system
• Usage data and analytics
• Cookies and similar tracking technologies

4. How We Use Your Information

We use the information we collect to:

• Provide and improve our E-2 visa preparation services
• Process your visa application materials and documents
• Communicate with you about your account and services
• Process payments and billing
• Comply with legal obligations and requirements
• Analyze and improve platform performance
• Send you updates, marketing communications (with your consent), and service announcements
• Protect against fraud and unauthorized access

5. Information Sharing and Disclosure

We may share your information with:

Service Providers

Third-party service providers who assist us in operating our platform, including payment processors, cloud storage providers, and analytics services. These providers are contractually obligated to protect your information.

Legal Requirements

We may disclose your information when required by law, court order, or government regulation, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

We do not sell your personal information to third parties.

6. Data Security

We implement industry-standard security measures to protect your information, including:

• Encryption of data in transit and at rest
• Secure authentication and access controls
• Regular security audits and monitoring
• Employee training on data protection
• Secure document storage systems

However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security of your information.

7. California Privacy Rights

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

Your rights include the right to:

• Request access to the personal information we collect about you
• Request correction of inaccurate personal information
• Request deletion of your personal information
• Opt out of the sale or sharing of personal information
• Not be discriminated against for exercising your privacy rights

Categories of personal information collected may include identifiers (such as name and email), professional information, usage data, and documents you upload in connection with our Services.

We do not sell personal information. We may share personal information with service providers for business purposes only.

How to exercise your rights: You may submit a request by emailing privacy@portunusai.com with the subject line "California Privacy Rights Request."

We may verify your identity before processing your request.

8. Your Privacy Rights

Depending on your location, you may have the following rights:

• Access: Request access to your personal information
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information
• Portability: Request a copy of your data in a portable format
• Object: Object to processing of your information
• Opt-out: Opt out of marketing communications

To exercise these rights, please contact us using the information provided below.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience, analyze usage, and provide personalized content. You can manage cookie preferences through your browser settings, but disabling cookies may limit certain platform features.

10. Third-Party Links

Our platform may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

11. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

12. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place to protect your information in compliance with applicable data protection laws.

13. Data Retention

We retain your personal information for as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. When no longer needed, we securely delete or anonymize your information.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new policy on this page and updating the "Last updated" date. Your continued use of our services after changes become effective constitutes acceptance of the revised policy.

15. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at: