Privacy Policy

Gihon Services Limited (“we” or “GSL”) treats the privacy of its clients, website users and other individuals very seriously and we take appropriate security measures to safeguard your personal information. This policy explains how GSL uses any personal information (i.e., any information that relates to you and that identifies or can be used to identify you, including without limitation your name, email, address, or other digital identifiers relating to you, such as IP addresses, cookies or web server logs) that you share with us, including how we collect, process, protect and share personal information.

The data controllers of your personal information will be GSL. If you have any questions regarding GSL’s use of your personal information, or this policy, please contact us using the Contact form. 

We rely on various legal bases under applicable data protection legislation in order to process your personal information, including our legitimate interests, contractual necessity and as required by law. Section 2 of this policy explains the applicable legal basis under which we process your personal information for each purpose.

If we require your personal information due to a legal requirement or obligation, or in order for us to perform a contract with you, we will make you aware of this at the time we collect your personal information (unless we are restricted from doing so by law, rule or regulation), and the possible consequences of you failing to provide this personal information.

1. How we obtain your personal information

Information you provide to us
We collect your personal information when you decide to interact with us and we only collect the information reasonably necessary to carry out our business (see section 2 of this policy which explains why we use your personal information). You can provide us with personal information via email, mail and telephone, which includes, without limitation, address, job title, position and email address.

Information provided by third parties
We may also process limited personal information in relation to actual or prospective clients of GSL. This personal information is obtained via third parties (i.e., the company in question).

2. Why we use your personal information

We will use your personal information for the following purposes on the following legal bases:

Purpose and Legal Basis

To provide you with the services or financial products you have requested: Contractual necessity

To keep a record of your relationship with us: Legitimate interest

To verify your identity: Legal purposes and legitimate interest

To conduct due diligence activities in connection with an actual or prospective transaction with which GSL is involved: Legitimate interest

Fraud and abuse prevention: Legal purposes and legitimate interest

Litigation management and conducting internal audits and investigations: Legal purposes and legitimate interest

To send you information about GSL and to keep you informed of our products and services in which you might be interested (if you have provided your consent to us doing so, or based on our legitimate interests where we have an existing relationship with you and we wish to contact you about similar products and services in which you may be interested): Consent or legitimate interest

No automated decision making, including profiling, is used when processing your personal information.

3. Who we share your personal information with

We share your personal information with our consultants and certain service providers as necessary to fulfil the purposes set out in this policy, including, without limitation, Google (who provide email and cloud storage services) and Squarespace (website hosting), and professional advisors (including, without limitation, any legal, compliance, accounting and financial advisors). We ensure that key parties that provide a service to, or for us, meets our standards for data security.

We will share your personal information with governmental and regulatory bodies (e.g., the FCA, SEC, FINRA, IRS and HMRC) where required for legal, investigatory, regulatory, national security or for the purposes of public importance.

We will also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, or other disposition of all or a portion of our business, assets or shares.

4. How we keep your personal information secure

We are committed to protecting the personal information you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access and improper use.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in section 2 of this policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact us using the Contact form.

5. Transfer of your personal information

To the extent we transfer your personal information to countries located outside of the European Economic Area (“EEA”), such transfers will be made in accordance with applicable data privacy laws.

To the extent any personal information is transferred from a GSL entity within the EEA to a GSL entity outside the EEA, this transfer is legitimised and your personal information is adequately protected under the terms of the EU controller-to-controller model contract clauses.

6. Your rights

You have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. We have explained these individual rights and controls below. To exercise these rights and controls, please contact us using the Contact form.

·       Access: You have the right to ask for a copy of the personal information that GSL holds about you free of charge. However, we may charge a ‘reasonable fee’ if we consider that your request is excessive to help us cover the costs of locating the information you have requested.

·       Correction: You may notify us of changes to such your personal information if it is inaccurate or it needs to be updated.

·       Deletion: If you consider that we should not be holding or processing your personal information any longer, you may request that we delete it. Please note that this may not always be possible due to legal obligations

·       Restrictions on use: You may request that we stop processing your personal information (other than storing it) if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information override your own rights.

·       Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.

·       Portability: If you wish to transfer your personal information to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.

·       Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, and you no longer wish to consent to us doing so, you may contact us to let us know that you withdraw that consent.

7. Cookies

Our website uses cookies to enhance your browsing experience. A cookie is a small text file of data stored by our website within your browser. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

If you have previously browsed to our website and no longer wish to accept cookies, please be aware that some cookies may have already been set. You may delete these cookies at any time via your browser by following these instructions: http://www.aboutcookies.org/Default.aspx?page=2

You can control cookies via your browser settings by following the instructions at http://www.aboutcookies.org/Default.aspx?page=1 however if you choose to block cookies then your browsing experience may be affected.

8. How to contact us

For any questions regarding GSL’s processing of your personal information (including your rights as explained at section 6 of this policy) please contact us using the Contact form.

9. Complaints

Should you wish to lodge a complaint with regards to how your personal information has been processed by GSL, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.