Privacy Policy

PLEASE READ THE FOLLOWING INFORMATION CAREFULLY to understand our practices regarding your personal data and information and how we will use it.

BY ACCESSING THE WWW.GSGASSET.COM WEBSITE, you acknowledge that you have read, understood and in consideration for our processing your expression of interest, you agree to the contents of this Privacy Policy. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Services.

1. ABOUT THIS PRIVACY POLICY

At GREAT SOUTH GATE we are committed to keeping your information safe and secure. Please read this privacy policy (“Privacy Policy”) so that you understand your rights in relation to this information, including how your information will be collected, used and processed.

GREAT SOUTH GATE Pte. Ltd. is incorporated in Singapore with company number 201907304w, whose registered address is at Six Battery Road, Level 30, Singapore 049909, (“GSGPL”) and its subsidiaries are collectively referred to in this Privacy Policy as “Great South Gate”, “we”, or “us”. By virtue of Article 27(2)(a) of GDPR, GSGPL is not required to appoint a data representative within the EU. We continuously monitor how we process personal information regarding person situated in the EEA and will update this section in the event that the exemption at Article 27(2)(a) no longer applies to GSG.

This Privacy Policy applies whenever you: (i) use our website; (ii) subscribe, sign up or opt in to receive any marketing materials or publications; (iii) create an account with us (a “Client Account”); (iv) use our Client portal (the “GSG Portal”); or (v) use any of the other services that we offer to our clients, (together the “Services”).

2. TYPES OF PERSONAL INFORMATION WE USE

We will collect and the following information about you:

  • Information you give us. This information about you that give us by: (a) creating a Client Account; (b) subscribing or opting in to receive any marketing materials or publications with us; (c) signing up to various third-party service providers as part of our Service; or (d) corresponding with us. The information you give us includes your name, address, e-mail address, passwords, photo identification, a utility bill or a bank/credit card statement and/or correspondence document from a Government Department.
  • Information we collect about you. With regard to your use of the Services, we will automatically collect the following information when you see the Services and undertake transactions using the Services: (a) technical information: including the internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; (b) session information: including transaction record data, full Uniform Resource Locators (URL), clickstream to, through and form our server (including date and time), items you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such us scrolling, clicks, and mouse-overs), methods used to browse away from the page; (c) location information: when you use a location-enabled device to access the Services, we may collect geographical location data or use various means to determine the location, such as sensor data from your device that may, for instance, provide data on nearby cell towers and wi-fi access spots; (d) trade history: when you validate trade or a trade is made in your Client Account, we will record that in the Clint Account log. We retain this information to validate trades, monitor trade history for fraud or illegal activity, and to ensure the integrity and security of the services. We collect this information when you visit our website, even if you do not have a Client Account with us.
  • Information required to comply with governmental rules, anti-money laundering (“AML”) or “know-your-customer” (“KYC”) policies. We will require you to provide information including scanned or depicted documents from you, such as a current government-issued, photo bearing identity card or a valid passport or a driving license bearing photo to show proof of identity as well as documentation that evidences your proof of address or documentation that evidence your proof of address or documents or online database information to confirm your identity. We also will collect information about your devices for fraud prevention, KYC or AML purposes and other information as may be required by applicable law. Such information will only be necessary if requested and may be required prior to activation of your Client Account.

3. HOW WE USE YOUR PERSONAL INFORMATION

We will use the information in the following ways:

Personal Information We use this information to: Legal Basis for Processing
Full Name

– verify your identity

– provide communications to you about your account and service information

– provide customer support if you request support

Pursuant to our obligations under applicable law to comply with AML/KYC requirements.

Passport/Identification Card

(shared with third party KYC/AML service provider)

– verify your identity Pursuant to our obligations under applicable law to comply with AML/KYC requirements.
Nationality – verify your identity Pursuant to our obligations under applicable law to comply with AML/KYC requirements.
Email Address, Phone Number

– provide communications to you about your account and service information

– mediate and resolve disputes

– provide customer support if you request support

Pursuant to our contract to provide the Services to you.
Internet Protocol (IP) Address and location information

– Verify your identity

– Control banned geo-locations

– Security measure for account login location

It is in our legitimate interests to ensure the integrity and security of the Services and to protect our users
Trading History

– monitor and improve our Services

– investigate prohibited or illegal activities, violations of this policy and our agreement with you, and prevent the same

Pursuant to our obligations under applicable law to comply with AML/KYC requirements.
Address – verify your identity Pursuant to our obligations under applicable law to comply with AML/KYC requirements.
Digital Asset Wallet Addresses

– process fees

– process transactions and send information about your transactions

– provide customer support if you request support

– mediate and resolve disputes

Pursuant to our contract to provide the Services to you.
Bank Account Information

– process fees

– process transactions and send information about your transactions

– mediate and resolve disputes

Pursuant to our contract to provide the Services to you.
Transaction Data (please note that payments may be processed by a third party and Great South Gate does not process your credit card information)

– process fees

– process transactions and send information about your transactions

 

Pursuant to our contract to provide the Services to you.
Session Information

– provide customer support if you request support

– mediate and resolve disputes

– monitor and improve our Services

– investigate prohibited or illegal activities, violations of this policy and our agreement with you, and prevent the same

– carry out bug-fix, remediation of technical issues and troubleshooting

It is in our legitimate interests to ensure the integrity and security of the Services and to protect our users
Session Technical Information

– provide customer support if you request support

– carry out bug-fix, remediation of technical issues and troubleshooting

– monitor and improve our Services

– investigate prohibited or illegal activities, violations of this policy and our agreement with you, and prevent the same

It is in our legitimate interests to ensure the integrity and security of the Services and to protect our users

4. COOKIES

In order to improve our products or services, we collect data by way of “cookies”. A cookie is a small text file containing small amounts of information which are automatically downloaded into your computer (or another electronic device) when you access to this Site. Cookies help us to measure the number of visits, average time spent, page views and other statistics relating to your access to this Site. This information allows us to better administer this Site and provide a more tailored and user-friendly service to our users. Cookies also enable you to use or access certain features or services of this Site. Each time you visit this Site from the same computer or device, the cookie will be retrieved from your computer or device, enabling this Site to recognise your computer or device as having previously visited the Site and thereby increase the functionality of the Site on your computer or device. Therefore, generally, we use cookies on to: (i) recognise your browser as a previous visitor and save any preferences that may have been set during your last visit to this Site; (ii) obtain information about your preferences, online movements and use of the Internet; (iii) track website analytics and carry out research and statistical analysis to help improve our content, products and services and to help us better understand our visitors’ or customers’ requirements and interests; (iv) customise and target our marketing and advertising campaigns and those of our partners more effectively by providing personalised interest-based advertisements; (v) measure and research the effectiveness of our interactive online content, features, advertisements, and other communications; (vi) make your online experience more efficient and enjoyable.

The information we obtain from our use of cookies will not usually contain your Personal Data. Although we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. In certain circumstances, we may collect personal information about you but only where you voluntarily provide it (e.g. by completing an online form) or where you subscribe to our Service through the Site. The information we obtain through the use of cookies may be combined with other Personal Data relating to you.

In most cases, we will obtain your consent in order to use cookies on this Site. The exception is where the cookies are strictly necessary for us to operate this Site and/or to provide you with a service you have requested. Most web browsers and devices can be set to notify you when you receive a cookie or to prevent cookies from being sent. If you use these features, you may limit the functionality we can provide you when you visit this Site. You are free to block, delete, or disable the cookies if your device permits so. You can manage your cookies and your cookie preferences in your browser or device settings. If you have recently disabled one or more cookies, we will stop using the disabled cookies to collect any further information. However, we may still use information collected from such cookies prior to your selecting the ‘disable’ preference setting.

Further information about cookies, including how to see what cookies have been set on your computer or device and how to manage and delete them, visit www.allaboutcookies.org and www.allaboutcookies.org.

5. CHILDREN

Our Services are not intended for children. Children must not use the Services for any purpose. We will not knowingly allow anyone under 18 to register for our Services or provide any personally identifying information.

6. HOW WE STORE AND SHARE YOUR PERSONAL DATA

We store and process your information in Singapore. Your personal data is also processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff are engaged in, among other things, the fulfilment of order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.

We may share your personal information with selected third parties in and outside your country, including: (i) third party service providers and partners including infrastructure hosting providers (in order to store data), identity verification service and investor status verification services (in order to facilitate the set-up of your account in accordance with applicable law), payment services (in order to process payments), and accounting services (in order to verify, monitor and secure transactions); (ii) related group companies, We share information with these entities in order to: (a) help detect and prevent potentially illegal acts and violations of our policies; (b) allow you to leverage information that you have provided to us to more efficiently set-up accounts with group companies and to allow you to use the products and services they provide that are supplied in connection with the Services; and (c) guide decisions about our products, services and communications; (iii) law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to: (a) comply with a legal obligation, process or request; (b) enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; (c) detect, prevent or otherwise address security, fraud or technical issues; or (d) protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction); and (iv) a third party that acquires all or substantially all of us or our business. We will disclose information to a third party in the event that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

7.  LINKS TO THIRD PARTY SITES

We may provide links to other third-party sites, applications and APIs as a convenience to you (collectively, the “Third Party Links”). Please exercise care when visiting or using any Third Party Links. The Third Party Links have separate and independent privacy policies, notices and terms of use which govern your use of such tools and their use of any information they collect. We recommend you read these policies carefully. We disclaim all liability for personal information you provide to any Third Party Links.

8. SECURITY

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our Services; any transmission of your information is at your own risk.

9. YOUR RIGHTS

You may access, review and edit your personal data at any time by logging in to your account using your credentials.

To disable your account and remove your personal information completely, please email us at Privacy@GSGasset.com with a request.  This request must comply at all times with our Terms and Conditions.

(i) Access, Correction & Deletion: You have the right to know whether we process personal information about you, and if we do, to access personal information we hold about you and certain information about how we use it and who we share it with. You can access and correct your personal information by logging into your account on the Services at any time. If we hold personal information about you that is not available by accessing your account, you can make a request for such information to Privacy@GSGasset.com. For certain information (such as your IP address) you also have the right to request that such information be deleted. To the extent you are not able to deletion your personal information by logging into your account on the Services, please contact us at Privacy@GSGasset.com.

(ii) Portability: You have the right to receive a copy of certain personal information we collect from you in a structured, commonly used and machine-readable format.  The relevant personal information is information you provided for the purposes of performing our contract with you (for example, your email address and transaction data). You can make a request for such information to Privacy@GSGasset.com at any time. If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

(iii) Restriction of Processing & Objection:

You have a right to require us to stop processing the personal information we hold about you, other than for storage purposes, in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or for another’s protection). You may request we stop processing and just store the personal information we hold about you where: (i) you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate; or (ii) we wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims.

Separately, at any time you have the right to object to our processing of personal information about you in order to send you marketing and related communications, including where we build profiles for such purposes and we will stop processing the personal information for that purpose.   If you object to certain processing, please contacting us at Privacy@GSGasset.com.

If we have collected your information by obtaining your consent, you also have the right at any time to withdraw that consent by contacting us.  Please email us at Privacy@GSGasset.com if you have any questions or wish to exercise your rights. 

10. RETENTION OF INFORMATION

We will retain your personal information as described below (except if otherwise required to be retained by applicable law): (i) Information you give us (Name, address, e-mail address and phone number, cryptocurrency wallet address, bank account information). This information is retained for the period for which you hold your account. (ii) Information we collect about you (website visit and browsing information for each session (including technical information), location information, IP address, transaction data). This information is retained for the period for which you hold your account and then deleted within 30 days of a lawful, valid request to exercise your legal rights to deletion of such information. (iii) Information we receive from others source or that is required to comply with AML or KYC policies (financial information, copies of personal identification documents (including copies of your passport and/or driver license) and photograph). This information is retained for the period for which such information must be retained under applicable law in the countries in which we operate.

11. MARKETING

We will only disclose your information to any third party for marketing with your consent. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data when you sign up for the Services. You can also exercise the right to withdraw your consent to such marketing at any time by email us at Privacy@GSGasset.com.

12. CHANGES TO THIS POLICY

We may amend this policy at any time by posting a revised version on the Website.   The revised version will be effective at the time we post it. We encourage you to periodically check this page for the latest information on our Privacy Policy.

13. GOVERNING LAW

Irrespective of the country from which you access or use this Form or our Services, to the extent permitted by law, this Privacy Policy shall be governed in accordance with the laws of Singapore without regard to choice or conflicts of law principles, and you hereby agree to submit to the exclusive jurisdiction of the courts of Singapore to resolve any claims or disputes which may arise in connection with this Policy.

14. CONTACT US

The responsibility for your personal data is with Great South Gate, who are your joint data controllers. Please contact either of the joint controllers at the correspondence address below:

Anduril Pte. Ltd., a company incorporated under the laws of Singapore whose registered address is Six Battery Road, Level 30, Singapore 049909.

If you have questions concerning this Privacy Policy, or you notice any bugs, errors or violations please feel free to send us an email at Privacy@GSGasset.com.