Last Updated: 30-OCTOBER-2024

This Privacy Policy describes how Gold Trust Limited (“Gold Trust,” “we,” “us,” or “our”) collects, uses, and shares personal information of users of our website [website address], mobile application (if applicable), and other online services (collectively, the “Services”).

1. Information We Collect

We collect the following types of information:

Information You Provide Directly to Us:
Account Information: When you create an account, we collect your name, email address, password, date of birth, nationality, phone number, and other information you provide during the registration process.
Know Your Customer (KYC) Information: To comply with legal and regulatory requirements, we may collect your address, government-issued identification (e.g., passport, driver’s license), proof of address, and other information necessary to verify your identity.
Transaction Information: We collect information about your transactions, including the amount, date, time, cryptocurrency used, real estate investments, and other details.
Communications: We collect information you provide when you contact us with questions or feedback (e.g., email address, the content of your communication).
Investment Profile: We may collect information about your investment goals, risk tolerance, and financial situation to personalize your experience and offer suitable investment opportunities.
Information We Collect Automatically:
Log Data: We automatically collect log data when you access and use the Services. This includes your IP address, browser type, operating system, referring URLs, device information, pages visited, and the dates and times of your visits.
Cookies and Similar Technologies: We use cookies, web beacons, and other similar technologies to collect information about your browsing activity. Cookies are small data files stored on your device that enable us to recognize you and remember your preferences. You can control the use of cookies through your browser settings.
Location Data: With your consent, we may collect information about your device’s location.
Information We Collect from Third Parties:
Identity Verification Services: We may use third-party identity verification services to verify your identity and comply with KYC/AML regulations. These services may provide us with information about your identity, address, and credit history.
Data Analytics Providers: We may use third-party data analytics providers to analyze your use of the Services and improve our offerings.

2. How We Use Your Information

We use your information for the following purposes:

To Provide and Improve the Services:
To create and manage your account.
To process your transactions.
To personalize your experience.
To provide customer support.
To improve the functionality and performance of the Services.
To Comply with Legal and Regulatory Requirements:
To verify your identity.
To comply with KYC/AML regulations.
To respond to legal requests and prevent fraud.
To Communicate with You:
To send you important notices and updates about the Services.
To respond to your inquiries and requests.
To send you marketing communications about our products and services (with your consent, where required by law).
For Research and Development:
To conduct research and analysis to improve our products and services.
To develop new features and offerings.

3. How We Share Your Information

We may share your information with the following categories of recipients:

Service Providers: We share information with third-party service providers who assist us with providing the Services, such as payment processors, identity verification services, data analytics providers, and cloud hosting providers. These service providers are contractually obligated to protect your information and use it only for the purposes for which we disclose it to them.
Legal Authorities: We ma

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y disclose your information to legal authorities if required by law or legal process, or if we believe it is necessary to protect our rights, property, or safety, or the rights, property, or safety of others.
Business Partners: We may share information with our business partners to offer you products and services that may be of interest to you (with your consent, where required by law).
In Connection with a Business Transaction: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.
With Your Consent: We may share your information with third parties with your consent.

4. Your Rights

You have the following rights regarding your personal information, subject to applicable law:

Right to Access: You have the right to request access to the personal information we hold about you.
Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.
Right to Erasure: You have the right to request that we erase your personal information, under certain circumstances.
Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal information, under certain circumstances.
Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit it to another controller, where technically feasible.
Right to Object: You have the right to object to the processing of your personal information, under certain circumstances.
Right to Withdraw Consent: If we are processing your personal information based on your consent, you have the right to withdraw your consent at any time.
Right to Lodge a Complaint: You have the right to lodge a complaint with a data protection authority if you believe that we have infringed your rights.

To exercise these rights, please contact us at [email address]. We may require you to verify your identity before processing your request.

5. Data Security

We take reasonable measures to protect your personal information from unauthorized access, use, or disclosure. These measures include:

Encryption of data in transit and at rest.
Firewalls and intrusion detection systems.
Regular security audits and vulnerability assessments.
Employee training on data security best practices.

However, no method of transmission over the internet or method of electronic storage is completely secure. Therefore, we cannot guarantee the absolute security of your information.

6. Data Retention

We will 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.

7. International Data Transfers

Your personal information may be transferred to and processed in countries other than your country of residence, including countries that may not have data protection laws that are as comprehensive as those in your country. We will take appropriate safeguards to protect your personal information in accordance with this Privacy Policy and applicable law.

8. Children’s Privacy

Our Services are not intended for children under the age of [age, e.g., 16]. We do not knowingly collect personal information from children under this age. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at [email address].

9. Links to Other Websites

Our Services may contain links to other websites that are not owned or controlled by us. We are not responsible for the privacy practices of these websites. We encourage you to review the privacy policies of any website you visit.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated Privacy Policy on our website and updating the “Last Updated” date. Your continued use of the Services a

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fter such changes constitutes your acceptance of the new Privacy Policy.

11. Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Gold Trust Limited
[Address]
[Email Address]
[Phone Number (Optional)]

Key Considerations and Customization:

Specific Data Practices: This is a general template. You MUST fill in the specifics of exactly what data you collect, how, where it’s stored, who has access, and for how long.
Jurisdictional Compliance:
GDPR (Europe): If you have users in the EU, you must comply with GDPR. This includes providing a clear legal basis for processing data (e.g., consent, contract, legitimate interest), providing detailed information about data transfers outside the EU, and honoring the rights of EU data subjects.
CCPA/CPRA (California): If you have users in California, you must comply with the CCPA/CPRA. This includes providing a “Do Not Sell My Personal Information” link, disclosing the categories of personal information you collect, and honoring the rights of California consumers.
Other Laws: Investigate and comply with all other applicable privacy laws, such as PIPEDA (Canada), LGPD (Brazil), etc.
Cookie Consent: Implement a cookie consent banner on your website to obtain users’ consent to the use of cookies, as required by GDPR and other laws. Provide users with the ability to manage their cookie preferences.
Third-Party Services: List all third-party services you use (e.g., Google Analytics, payment processors, email marketing platforms) and explain how they collect and use data. Include links to their privacy policies.
Security Measures: Be specific about the security measures you have in place to protect data.
Data Retention Policy: Define your data retention policy, including how long you retain different types of data and the criteria you use to determine retention periods.
Contact Information: Provide clear and accessible contact information for users to exercise their rights or ask questions about your privacy practices.
Regular Review: Review and update your Privacy Policy regularly to reflect changes in your data practices or legal requirements.