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PRIVACY POLICY
 

1. Scope of This Privacy Policy
This Privacy Policy applies to natural persons whose personal data is processed by CGPH Group, including its affiliates and subsidiaries (hereinafter referred to as "CGPH").

For any questions or concerns regarding this Privacy Policy, you may contact us at info@cgphgroup.com.

CGPH complies with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, ensuring the confidentiality and security of your personal data.

References to "we" or "us" refer to CGPH and its group companies. References to "you" or "your" refer to clients, prospective clients, affiliates, agents, beneficial owners, and other representatives.
 

2. Categories of Personal Data
CGPH may collect and process the following categories of personal data:

  • Personal Identification Details: Name, civil status, nationality, place and date of birth, identity documents, and signature.

  • Professional Information: Email address, phone number, job title, and postal address.

  • Corporate and Legal Data: Information related to power of attorney, board membership, and business representation.

  • Marketing and Communication Data: Preferences regarding marketing communications, interactions with emails, advertisements, social media, and website activity.

  • Compliance and Regulatory Data: Politically Exposed Person (PEP) status, beneficial owner information, and due diligence documents.

  • Online and Digital Data: IP address, cookies, device information, browsing behavior, and interactions with digital content.
     

3. Legal Basis for Processing Personal Data
We process your personal data based on the following legal grounds:

  • Contractual Obligations: To provide services, execute contracts, and manage client relationships.

  • Legitimate Interests: To improve our services, conduct internal analytics, and enhance customer interactions.

  • Legal and Regulatory Compliance: To comply with anti-money laundering (AML), know-your-customer (KYC) regulations, and UK regulatory requirements.

  • Marketing and Business Development: To send promotional content, newsletters, and offers about our services and partners.

  • Consent-Based Processing: For activities such as email marketing campaigns, WhatsApp communications, and social media interactions where explicit consent is required.
     

4. Data Retention Policy
We retain personal data for as long as necessary for the stated purposes or as required by law:

  • Client and Accounting Data: Up to 10 years after the termination of a business relationship.

  • Compliance and KYC Data: Up to 10 years post-relationship in line with regulatory obligations.

  • Marketing Data: Retained until consent is withdrawn or for a maximum of 5 years after the last interaction.

  • Website and Analytics Data: Retained for up to 24 months for analytics and service improvements.


5. Data Sharing and Transfers
Your personal data may be shared within the CGPH Group to provide integrated services. Additionally, we may engage third-party providers for operational support, including:

  • Marketing Platforms: Google, LinkedIn, Facebook, Instagram, TikTok, Twitter, Mailchimp, ActiveCampaign.

  • Messaging & Communication Services: WhatsApp, Telegram, WeChat, SMS, email services, VoIP.

  • Payment Platforms: Stripe, PayPal.

  • Cloud and IT Services: Microsoft Azure, AWS, Google Cloud.

  • Analytics and Profiling Tools: Google Analytics, Meta Pixel, HubSpot, AI-driven marketing automation platforms.

Where personal data is transferred outside the United Kingdom, we ensure appropriate safeguards such as Standard Contractual Clauses (SCCs) and compliance with applicable regulations.
 

6. Data Security Measures
We implement strict security measures, including:

  • Encryption of data at rest and in transit.

  • Access controls to restrict unauthorized access.

  • Multi-factor authentication (MFA) for sensitive data.

  • Regular security audits to identify and mitigate risks.
     

7. Marketing, Profiling & Communication Preferences
We process your personal data for marketing purposes, including but not limited to:

  • Sending promotional communications via email, SMS, WhatsApp, Telegram, and other messaging apps.

  • Profiling and segmenting users using AI-driven tools and analytics for targeted offers.

  • Tracking interactions with advertisements, emails, and digital content for better customer engagement.

  • Marketing across CGPH Group companies and partners, allowing us to send communications about financial services, investment opportunities, and corporate solutions.

  • Remarketing and retargeting campaigns, displaying targeted ads across social media and partner websites.

Marketing Communications on Behalf of Third Parties CGPH may also send promotional content on behalf of partner companies within the financial, investment, and corporate services sectors. These communications will always be sent by CGPH, without disclosing your data to third parties for independent marketing purposes.

Opt-out Option You can opt out of marketing communications at any time by:

  • Clicking the "unsubscribe" link in our emails.

  • Contacting us at info@cgphgroup.com.

  • Disabling tracking cookies via the Cookie Preferences Panel on our website.

Opting out of marketing communications does not prevent us from sending transactional or legally required communications regarding your business relationship with CGPH.
 

8. Confidentiality, Non-Disclosure, and Client Rights

CGPH is committed to ensuring the confidentiality of all documents and information provided by clients during business interactions.

  • Restricted Use: All documents and information shared with CGPH will be used exclusively for managing client relationships and fulfilling contractual obligations.

  • Confidential Handling: Only authorized personnel will have access to such documents, ensuring compliance with strict internal security policies.

  • Non-Disclosure Commitment: CGPH will not disclose client-provided information to third parties unless required by law or expressly authorized by the client.

  • Retention Policy: Sensitive documents will be stored securely for the duration required by law or regulatory obligations and will be deleted upon expiration of the retention period.

  • Client Rights:

    • Right to access, rectify, or erase personal data.

    • Right to restrict processing or object to automated decision-making.

    • Right to data portability.

    • Right to lodge a complaint with the ICO (Information Commissioner's Office) in the UK.
       

9. Amendments to This Privacy Policy
We may update this Privacy Policy periodically. The revised version will be published on our website with the effective date indicated.

Effective Date: 04 February 2025
 

10. Applicable Law and Jurisdiction
This Privacy Policy is governed by the laws of England and Wales, and any disputes shall be subject to the exclusive jurisdiction of the courts of England and Wales.
 

For further information, contact: CGPH Group Email: info@cgphgroup.com

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