Privacy Policy of Gamma Capital Markets Limited
Gamma Capital Markets Limited ("we", "our", or "us") is committed to protecting the privacy and security of your personal data. This Privacy Policy describes how we collect, use, process, and disclose your information in connection with our global corporate site and the cross-border financial services we provide, including portfolio management services as per §20 Abs. 3 Nr. 2 KAGB. Our BaFin-ID is 10148358. Our registered address is Valletta, Malta. This policy applies to all visitors and users of our online platform.
1. Information We Collect
We collect various types of information, including personal data, to provide and improve our services. This includes:
- Information you provide directly to us: This includes data submitted via our contact form (such as your name and email address) when you express interest in our services or submit an inquiry.
- Information related to our services: For clients engaging in our financial services, including portfolio management, we collect necessary personal and financial data to fulfil our contractual obligations and regulatory requirements (e.g., identity verification, financial status, investment preferences).
- Automated data collection: When you visit our online platform, we may automatically collect certain information about your device and browsing actions, such as IP address, browser type, operating system, referring URLs, and interaction with our site content. This is primarily for analytical purposes to improve our services and user experience.
2. Legal Basis for Processing
We process your personal data based on the following legal grounds as per the General Data Protection Regulation (GDPR) and other applicable laws:
- Consent: Where you have given explicit consent for us to process your personal data for one or more specific purposes (e.g., direct marketing).
- Contractual necessity: Where the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract (e.g., providing portfolio management services).
- Legal obligation: Where processing is necessary for compliance with a legal obligation to which we are subject (e.g., anti-money laundering regulations, financial reporting).
- Legitimate interests: Where processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. This includes maintaining the security of our services, improving user experience, and conducting business analysis.
3. How We Use Your Information
We use the information we collect for various purposes, including:
- To provide, operate, and maintain our services, including our cross-border financial services and portfolio management.
- To respond to your inquiries and provide customer support.
- To perform identity verification and due diligence as required by law.
- To process transactions and manage your accounts.
- To improve and personalise your experience on our online platform.
- To monitor and analyse trends, usage, and activities in connection with our services.
- To detect, investigate, and prevent fraudulent transactions and other illegal activities.
- To comply with our legal and regulatory obligations, including those related to our BaFin-ID: 10148358.
4. Sharing and Disclosure of Information
We do not sell your personal data. We may share your information in the following circumstances:
- With service providers: We may share your data with third-party vendors, consultants, and other service providers who perform services on our behalf, such as IT infrastructure, customer support, and analytics. These parties are contractually obligated to protect your data and only use it for the purposes for which it was disclosed.
- For legal compliance and protection: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to comply with legal obligations, enforce our terms and conditions, or protect the rights, property, or safety of Gamma Capital Markets Limited, our clients, or the public.
- Business transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company, your information may be transferred as part of that transaction.
- With your consent: We may share your information with third parties when we have your explicit consent to do so.
5. International Data Transfers
As a global firm, your information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. When we transfer your personal data across borders, we implement appropriate safeguards as required by law (e.g., Standard Contractual Clauses) to ensure your data remains protected.
6. Data Security
We implement appropriate technical and organisational measures to protect your personal data from unauthorised access, alteration, disclosure, or destruction. We continually review and update our security practices to ensure the highest level of protection.
7. Your Data Protection Rights
Under GDPR and other applicable laws, you have the following rights concerning your 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 complete information you believe is 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 personal data, under certain conditions.
- The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions.
- The right to data portability: You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
- The right to withdraw consent: You have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
To exercise any of these rights, please contact us using the details provided below.
8. Data Retention
We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Our retention periods are determined based on the type of data, the purpose of processing, and applicable legal or regulatory obligations.
9. Cookies and Tracking Technologies
Our online platform uses cookies and similar tracking technologies to enhance your browsing experience, analyse site traffic, and understand where our visitors are coming from. You can manage your cookie preferences through your browser settings.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any significant changes by posting the new Privacy Policy on our online platform. We encourage you to review this Privacy Policy periodically.
11. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:
Gamma Capital Markets Limited
Valletta, Malta