Privacy Policy | Gamma Prime Introducer

1. Introduction

Gamma Prime Introducer LTD ("Company," "we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or engage with our services.

This policy applies to information collected through our website, email communications, and in the course of providing introducer services to qualified institutional investors and investment managers.

By using our website or services, you consent to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, please do not use our services.

2. Information We Collect

2.1 Personal Information You Provide

We collect personal information that you voluntarily provide to us when you:

Submit inquiries through our contact form
Communicate with us via email or phone
Engage our services
Provide documentation for KYC/AML compliance

This information may include:

Name and contact information (email address, phone number, mailing address)
Company or fund name and details
Investment objectives and preferences
Assets under management (AUM)
Investment strategy information
Professional background and credentials
Financial information necessary for accreditation verification
Identification documents (passport, driver's license) for KYC purposes

2.2 Automatically Collected Information

When you visit our website, we may automatically collect certain information about your device and browsing activity, including:

IP address
Browser type and version
Device type and operating system
Pages visited and time spent on pages
Referral source
Date and time of access

2.3 Cookies and Tracking Technologies

We may use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small data files stored on your device that help us understand how you interact with our site.

You can control cookie preferences through your browser settings. However, disabling cookies may limit your ability to use certain features of our website.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Service Provision

To respond to your inquiries and provide requested information
To facilitate introducer services and connect you with appropriate investors or investment managers
To assess your eligibility and qualification for our services
To manage ongoing client relationships

3.2 Regulatory Compliance

To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements
To verify accredited investor status and financial qualifications
To maintain records as required by securities regulations
To respond to regulatory inquiries and legal obligations

3.3 Communication

To send administrative information, updates, and service-related announcements
To provide market intelligence and relevant industry insights (with your consent)
To coordinate meetings and introductions

3.4 Website Improvement

To analyze website usage and improve user experience
To troubleshoot technical issues
To enhance website security

3.5 Legal Protection

To enforce our Terms of Service
To protect our legal rights and interests
To prevent fraud and unauthorized activity

4. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties. We may share your information in the following limited circumstances:

4.1 Facilitated Introductions

With your explicit consent, we will share relevant information with investment managers or institutional investors as part of facilitated introductions. This sharing is the core purpose of our introducer services.

4.2 Service Providers

We may share information with trusted third-party service providers who assist us in operating our website and delivering our services, including:

Web hosting providers
Email service providers
KYC/AML verification services
Professional advisors (legal, accounting, compliance)

These service providers are contractually obligated to maintain confidentiality and use your information only for specified purposes.

4.3 Regulatory and Legal Requirements

We may disclose your information when required by law or regulation, including:

In response to subpoenas, court orders, or legal processes
To comply with securities regulations and regulatory inquiries
To cooperate with government investigations
To protect our legal rights and defend against legal claims

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

5. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

Encryption of data in transit using SSL/TLS protocols
Secure storage of sensitive information
Access controls limiting employee access to personal information
Regular security assessments and updates
Confidentiality agreements with employees and service providers

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but maintain industry-standard safeguards.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods vary based on:

The nature of the information
Regulatory record-keeping requirements (typically 5-7 years for financial services)
Ongoing client relationships
Legal obligations and potential litigation

When personal information is no longer needed, we will securely delete or anonymize it in accordance with our data retention policies.

7. International Data Transfers

Our services operate across multiple jurisdictions, including the United States, United Kingdom, Switzerland, Singapore, and Hong Kong. Your personal information may be transferred to and processed in countries other than your country of residence.

When we transfer personal information across borders, we ensure appropriate safeguards are in place to protect your data in accordance with applicable data protection laws, including:

European Union General Data Protection Regulation (GDPR)
Hong Kong Personal Data (Privacy) Ordinance (PDPO)
Singapore Personal Data Protection Act (PDPA)
Other applicable data protection regulations

We use standard contractual clauses, adequacy decisions, and other approved transfer mechanisms to ensure lawful cross-border data transfers.

8. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

8.1 Right to Access

You have the right to request access to the personal information we hold about you and obtain a copy of that information.

8.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information.

8.3 Right to Erasure

You may request deletion of your personal information, subject to legal and regulatory retention requirements.

8.4 Right to Restriction

You may request that we restrict processing of your personal information in certain circumstances.

8.5 Right to Data Portability

Where applicable, you have the right to receive your personal information in a structured, machine-readable format and to transmit that data to another controller.

8.6 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes or based on legitimate interests.

8.7 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us at info@gammaprimeintroducer.com. We will respond to your request within the timeframe required by applicable law (typically 30 days).

9. Marketing Communications

We may send you marketing communications about our services, market intelligence, and industry insights if you have provided consent or where permitted by law.

You may opt out of receiving marketing communications at any time by:

Clicking the "unsubscribe" link in our emails
Contacting us at info@gammaprimeintroducer.com

Please note that even if you opt out of marketing communications, we may still send you service-related announcements and administrative messages.

10. Third-Party Websites

Our website may contain links to third-party websites for your convenience and information. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party websites you visit.

11. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected information from a child, we will take steps to delete that information promptly.

12. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:

The right to know what personal information we collect, use, and disclose
The right to request deletion of your personal information
The right to opt-out of the sale of personal information (note: we do not sell personal information)
The right to non-discrimination for exercising your privacy rights

To exercise these rights, please contact us using the information provided in Section 15 below.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We will notify you of material changes by:

Posting the updated policy on our website with a revised "Last Updated" date
Sending email notification to our clients and contacts (for material changes)

We encourage you to review this Privacy Policy periodically. Your continued use of our services after changes are posted constitutes your acceptance of the updated policy.

14. Data Protection Officer

For questions about data protection or to exercise your privacy rights, you may contact our privacy team at:

Email: info@gammaprimeintroducer.com

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Gamma Prime Introducer LTD
Unit 1113, 11/F
Peninsula Centre
67 Mody Road
Tsim Sha Tsui
Hong Kong

Email: info@gammaprimeintroducer.com