Personal Data Protection Policy 

Protection of your Personal Data is important to us. This Personal Data Protection Policy (“Policy”) outlines how we manage the Personal Data we hold. The Policy applies to all departments and business units across CGT Management Ltd and/or its related corporations and affiliates (“CGT Group”, “we”, “us” or “our”) collectively or singularly as the context requires.

We respect the confidentiality of Personal Data and privacy of individuals and are committed to complying with applicable data protection laws, including the European Union (“EU”) General Data Protection Regulation (“GDPR”) where applicable. Please read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which any member of the CGTC Group may have at law to collect, use or disclose your Personal Data. This Policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data.

For the avoidance of doubt, to the maximum extent permitted under applicable law, nothing in this Policy establishes any joint and several liability on the part of the CGTC Group members.

1. Your Personal Data 

1.1.     “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data alone; or (b) from that data combined with other information. Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us): 

a)     your name, photo identification, passport number or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you;

b)     information about your use of our websites and services, including cookies, IP addresses, subscription account details and membership details; 

c)     your employment history, education background, and income levels; and

d)     your payment related information, such as your bank account or credit card information, your credit history, and your digital token wallet addresses.

1.2.     In respect of our activities in the EU, Personal Data shall also include personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation, criminal convictions and offences, and other information defined as personal data under GDPR such as internet protocol addresses and cookie identifiers (insofar as such information is capable of identifying individuals either directly or indirectly).

2. Collection of Personal Data

2.1.     Generally, we collect your Personal Data in the following ways: 

a)     when you submit forms (including without limitation in respect of our whitelisting process), information or feedback relating to any of our products or services (including by use of our interactive IT touch screens such as iPads/Tablets), or submit any online queries;

b)     when you register for or use any of our services on websites or apps owned or operated by us or when you register as a member of websites owned and/or operated by us; 

c)     when you interact with our customer service officers or any of our staff, for example, via face-to-face meetings, telephone calls, letters, online forms (such as any “Contact Us” forms on our websites), web chat, social media platforms and emails;

d)     when you use or purchase our services or products; 

e)     when you establish any online accounts with us;

f)     when you request that we contact you; 

g)     when you respond to our request for additional Personal Data; 

h)     when you ask to be included in an email or other mailing list; 

i)     when you respond to our promotions and other initiatives; 

j)     when you respond to our market surveys; 

k)     when you submit a job application or a scholarship application; 

l)     when we receive references from business partners and third parties, for example, where you have been referred by them; 

m)     when you submit your Personal Data to us for any other reason; 

n)     when you browse our website. Please refer to the Cookie Policy below at paragraph 8 for more information. 

We may monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation, identity verification purposes, feedback, respond to your queries and requests and resolve complaints and other related purposes. Such monitoring or recording will be in accordance with applicable law. 

2.2.     If you provide Personal Data of a third party to us, you represent and warrant that the collection, use and disclosure of that Personal Data to us, as well as the further processing of that Personal Data by us for the purposes set out below, is lawful. 

2.3.     In respect of our activities in the EU, CGT Management Ltd, is the ultimate primary data controller for processing of the Personal Data.  

3. Use and Disclosure of Personal Data

3.1.     In general, we will, subject to applicable law, use and disclose your Personal Data for the following purposes: 

a)     provide you with the products or services that have been requested; 

b)     help us review, develop, improve, manage the delivery of and – to the extent this requires the use of Personal Data – enhance our products and services, including analysing future customer needs, conducting market research, customer satisfaction surveys and data analytics for example to enable us to understand and determine customer location, preferences and demographics (which does not involve automated profiling or result in automated decision-making activity which is regulated under the GDPR);

c)     communicate with you and respond to your queries, requests and complaints; 

d)     provide ongoing information about our products and services which may be of interest to you; 

e)     handle disputes and conduct and facilitate investigations and proceedings; 

f)     protect and enforce our contractual and legal rights and obligations (including repayment obligations) and for credit and internal risk management;

g)     prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks; 

h)     manage our infrastructure and facilitate business operations (including but not limited to billing, customer service and customer verification) and comply with internal policies and procedures; 

i)     facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any CGTC Group entity; and 

j)     comply with any applicable rules, laws and regulations, codes of practice or guidelines or assist in law enforcement and investigations by relevant authorities. 

3.2.     Generally, we process your Personal Data for one or more of the specific purposes identified in this Policy based on your consent obtained. Where GDPR applies, the legal basis for our processing of your Personal Data could also be that it is necessary for the legitimate interests pursued by us, or a third party which is described in paragraph 3.4 of this Policy. These legitimate interests include providing services to you where you are our client, managing the relationship between us and you and facilitating internal business purposes and administrative purposes. In some cases, the provision and processing of your Personal Data may be a statutory and/or contractual requirement, or may be necessary in order to perform any contract you have agreed with us or perform services that you have requested.

3.3.     In addition, we may use and disclose your Personal Data for the following purposes: 

(i)     undertaking KYC/AML checks and the whitelisting process;

(ii) verifying particulars and data provided;

(iii) providing you with goods and services that you have requested for;

(iv) communicate with you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you; 

(v) resolve complaints and handle requests and enquiries;

(vi) maintain any account and mailing lists you have with us and generally involving you in our community;

(vii) conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and

(viii) any other purpose related to the above. 

 3.4.     Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to third parties set out below. Such disclosure may be subject to additional legal requirements under applicable law, depending on the nature of such transfer to third parties. Your Personal Data will, in each case, only be disclosed to the extent necessary and proportionate.

The third parties are: 

a)     other entities within our corporate group;

b)     our joint venture/ alliance partners;

c)     our agents, contractors, third party service providers and specialist advisers who have been contracted to provide us with administrative, financial, research, operational or other services in pursuance of the purposes set out in this Policy, such as telecommunications, information technology, payment, processing, training, market research, storage and archival; 

d)     any third party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with us or not, and where permitted by applicable laws; 

e)     insurers or insurance investigators and credit providers; 

f)     any governmental credit agency, or in the event of default or disputes, any debt collection agencies or dispute resolution centres; 

g)     any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving our corporate group;

h)     our professional advisors such as our token sale advisors, auditors and lawyers; 

i)     relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; 

j)     anyone to whom we transfer or may transfer our rights and obligations, including, for example, where we obtain the services of a third party organisation to handle any aspect of the processing of your Personal Data for the purposes notified to you in accordance with this Policy; 

k)     banks, credit card companies and their respective service providers; and 

l)     any other party as may be consented to by you, as specified by you or as may be notified to you by us in subsequent notices.

In the event that your Personal Data is shared with a third party that acts with a member of our corporate group as joint controllers under GDPR, we will, to the extent required by law, provide you with additional information on the responsibilities of each joint controller, any particular means by which you can enforce your rights and the primary contact person for such requests in relation to your rights.

3.5     We require that organisations outside of our corporate group which handle or obtain Personal Data as service providers to us acknowledge the confidentiality of this data, undertake to respect any individual's right to privacy and comply with the GDPR and any other applicable data protection laws. As a requirement under these laws, we may be required to have specific agreements in place with such third parties to regulate and safeguard your data protection rights. We also require that these organisations use this information only for our purposes and follow our directions with respect to this information. 

4. Transfer of Personal Data

4.1     Your Personal Data may be stored in external servers located overseas. In addition, as described above, in carrying out our business, it may be necessary to share information about you with and between our related corporations and third party service providers, some of which may be located in countries outside your country of residence. Such countries may not afford a standard of protection similar to those in your country of residence. However, we will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected. In addition, we will ensure that such transfers comply with the requirements of the applicable data protection laws.

4.2 If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include user information among our assets transferred to or acquired by a third party. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal data according to this policy.

5. Retention of Personal Data

5.1     We may retain your Personal Data for as long as it is necessary for the purposes it has been collected, and (i) in most cases, up to 7 years; or (ii) in respect of our activities in the EU, up to 10 years, unless otherwise required by applicable law or in order to defend legal claims. Where we no longer require your Personal Data for those purposes, we will cease to retain such Personal Data in accordance with our internal retention policy.

6. Your Rights

6.1    You have the following rights, under applicable data protection laws (except where the exercise of these are restricted under applicable laws – for example, due to judicial proceedings or the carrying out of investigations), which can be exercised by contacting the relevant Data Protection Officer at the contact details provided in paragraph 11.1 below: 

(a)     you have the right to obtain from us confirmation as to whether or not your Personal Data is being processed and to request a copy of your information. Where legally required, we can provide your information in an easily accessible format and assist in transferring some of this information to third parties;

(b)     you are entitled to rectification of your Personal Data. We endeavour to ensure that all Personal Data we have about you is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with products and services you have requested;

(c)     in certain circumstances, you have the right to request to have your Personal Data deleted or the processing of which restricted;

(d)     if we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is necessary for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications or by contacting us at the details below;

(e)     to prevent any processing of Personal Data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;

(f)     to be informed about any use of your Personal Data to make automated decisions about you where such decisions produce legal effects or have similarly significant effects on you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and 

(g)     to lodge a complaint about the way in which your Personal Data is being used to a supervisory authority.

6.2     Where we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time. 

If you withdraw your consent to any or all purposes and depending on the nature of your request, we may not be in a position to continue to provide our products or services to you. 

6.3     Where mandated under the applicable data protection laws, your exercise of the rights described or referred to above shall be free of charge. In all other situations, we may charge a fee to cover the cost of verifying the request and locating, retrieving and copying any material requested. 

6.4     If you want to exercise any of your rights or if you wish to raise a complaint on how CGTC Group has handled your Personal Data, you may contact the relevant Data Protection Officer at the contact details provided in paragraph 11.1 below.

7.  Management and Security

7.1     We have appointed Data Protection Officers to oversee our management of your Personal Data in accordance with this Policy and the applicable data protections law. We train our employees who handle your Personal Data to respect the confidentiality of your Personal Data, and we regard breaches of all applicable data protection laws very seriously.

8. Cookie Policy 

8.1     We use “cookies” to collect information about you and your activity across our Website. A cookie is a small piece of data that our Website stores on your computer, and accesses each time you visit so we can understand how you use our Website and serve you content based on preferences you have specified. If you do not wish to accept cookies from us, you should instruct your browser to refuse cookies from our Website, with the understanding that we may be unable to provide you with some of your desired services without them. This policy covers only the use of cookies between your computer and our Website; it does not cover the use of cookies by any advertisers.


9. Third-Party Sites 

9.1     Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website, unless that is a mandatory requirement by applicable data protection laws and regulations. We encourage you to learn about the privacy policies of such third parties. Once you have left our website, you should check the applicable privacy policy of such third parties at their respective websites to determine how they will handle any information they collect from you. 

10. Governing Law

10.1     This Policy and your use of this website shall be governed in all respects by the laws of the British Virgin Islands. For the avoidance of doubt, the applicable data protection laws will apply to the processing of your Personal Data. 

11. How to contact us

11.1      If you have any questions about this Policy or any queries relating to your Personal Data, or you would like to obtain access and/or make corrections to your Personal Data records, please contact the relevant Data Protection Officers:

All countries 

Name: [insert], Group Data Protection Officer


12. Review of this Policy

12.1 This Policy will be reviewed from time to time by us. We may also from time to time update this Policy to take account of new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us. 

12.2 In the event of any inconsistencies between the English version and other translations of this Policy, the English version shall prevail.

Posted as of July 31, 2020