Privacy Policy.

Last updated: 20 June 2026

1. Introduction

Drayton Family Office is committed to protecting the privacy and confidentiality of every individual who visits this website or engages with our advisory services. This Privacy Policy explains what information we collect, how we use it, and the rights available to you under applicable data protection law, including the EU General Data Protection Regulation (GDPR).

2. Who We Are

The data controller responsible for your personal information is Apogeu Proeminente Unipessoal LDA, trading as Drayton Family Office, a company registered in Portugal. For any data protection enquiry, please contact us using the details at the end of this policy.

3. Information We Collect

We collect information you provide directly to us, including when you:

• Submit a contact or enquiry form
• Complete our Confidential Intake Questionnaire
• Subscribe to our private market intelligence list
• Apply to our Athlete Portfolio Partnership (APP™)
• Correspond with us directly by email, telephone, or WhatsApp

This may include your name, contact details, location, wealth and portfolio information, advisory objectives, and any other information you choose to share with us in the course of an enquiry or engagement.

We also collect limited technical information automatically when you visit our website, such as IP address, browser type, device information, and pages visited, as set out in our Cookie Policy.

4. How We Use Your Information

We use the information we collect to:

• Respond to your enquiry and assess suitability for engagement
• Provide our advisory services where a mandate is agreed
• Send confidential market intelligence to qualified subscribers, where consented to
• Maintain the security and proper functioning of our website
• Comply with our legal and regulatory obligations

5. Legal Basis for Processing

We process personal information on the basis of your consent, the necessity of processing to take steps prior to entering into an advisory engagement, our legitimate interests in operating a discreet, qualification-based advisory practice, and compliance with legal obligations to which we are subject.

6. Sharing Your Information

We do not sell, rent, or trade your personal information. We may share information on a strictly confidential basis with:

• Specialist legal, tax, and financial advisors engaged as part of your mandate
• Our licensed entities, Interluxe Realty® (Portugal) and Interluxe Capital™ (Dubai), where relevant to your enquiry
• Service providers who support the operation of this website and our systems, under appropriate confidentiality obligations
• Regulatory or legal authorities where required by law

7. International Transfers

Given our operations across Portugal, the UAE, and other international markets, your information may be transferred to and processed in countries outside the European Economic Area. Where this occurs, we take appropriate steps to ensure your information receives an equivalent standard of protection.

8. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including the satisfaction of any legal, accounting, or reporting requirements.

9. Your Rights

Under applicable data protection law, you have the right to request access to, correction of, or deletion of your personal information, to object to or restrict certain processing, and to request portability of your data. To exercise any of these rights, please contact us using the details below.

10. Security

We maintain appropriate technical and organisational measures to protect personal information against unauthorised access, alteration, disclosure, or destruction, consistent with the confidentiality that defines our practice.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with a revised effective date.

12. Contact Us