Global Captive Management Ltd. Privacy Policy
This privacy policy applies to use of websites, interactive services, or email programs (“Services”) provided by Global Captive Management Ltd. and our affiliated companies (collectively, “GCM”, “we”, or “us”). By using any of our Services, you are agreeing to being governed by this Privacy Policy and our Terms of Use, which will govern any dispute concerning these Services.

Information We Collect
When you use our services, we may automatically collect information about your Internet service provider, your operating system, browser, type, domain name, Internet protocol (IP) address, your access times, the website that referred you to us, the pages and aspects of the Services you requested, the date and time of those requests. This information is only used to improve the services, you will remain anonymous unless you provide identifying information (“Personal Information”.)

Information Provided by You
When using our services, you will not be required to provide any personal information. In general, you can visit our website and utilize our services without telling us who you are or revealing any personal information. In some instances, you may be prompted to provide some information, such as an email address, name, address, or zip code in order to receive additional information regarding our services. We will only use the personal information you have shared with us for the purposes as stated in this Privacy Policy.

How We Use the Information
If you provide personal information, we may use that information to contact you. Additionally, we may use personal information to improve our marketing and promotional efforts, to analyze site usage, and to improve our content, layout, and services. Information collected automatically through cookies may be combined with your previously submitted personal information.

Legal Grounds for the Use of Your Information
GCM generally collects only the personal information necessary to fulfill your request. You may provide additional information on your own volition – such additional information is always optional.

The law of the Cayman Islands allows us to process personal information, so long as we have grounds under the law to do so. It also requires us to tell you what those grounds are. When we process your personal information, we will rely on one of the following processing conditions:

1. Performance of a Contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;

2. Legal Obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;

3. Legitimate Interests: we may process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or

4. Your Consent: we may occasionally ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting GCM at the address listed at the end of the Privacy Policy.

GCM only collects “sensitive” personal information when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards.

Cookies and Automatic Collection
Cookies are pieces of information that a website transfers to the hard drive on your computer for record-keeping purposes. We use cookies for our services to remember important information that will make your use more convenient. Some of the information collected may be linked to a specific IP address, but we do not try to identify the person using that IP address. You may set your browser to accept or reject most cookies or notify you when a cookie is set. It is up to you to allow us to set cookies, but if cookies is blocked you may not be able to view or access some of the features of our services.

How We Share Your Data
We will not sell, exchange, or otherwise distribute your personal information without your consent, except to the extent required by law or as identified in this Privacy Policy. Your information may be shared with our affiliates, agents or service providers, in a business transfer, or in certain legal matters which require such disclosure.

Links to Other Websites
Our services may have links to other websites that are not operated by us. If you visit one of these linked websites, you are then subject to the policies of the owner of the linked website and will no longer be protected by our Privacy Policy or Terms of Use. We are not responsible for the contents of those websites and have no control over what information they may or may not collect from you.

Data Security and Retention
We take reasonable steps to maintain physical, technical, and administrative security of any information you provide to use. However, transmission of information via the internet is not completely secure. While we will do our best to protect your information, we cannot guarantee the security of information you provide during the use of our services. Any transmission of information, including personal information, is at your own risk.

We will retain your personal information only as long as necessary in connection with your use of our services or as required by law. We may also retain some data for internal analysis purposes only. Such data will be retained for a short period of time, unless used to strengthen our security or improve functionality.

Transfers to Third Parties
We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. This would include, but not be limited to, transfers to our service providers, transfers in connection to our reorganization or sale, transfers to courts, tribunals, law enforcement or regulatory bodies, or transfers for audits.

Additionally, GCM may transfer certain personal information outside the Cayman Islands to outside companies working with us or on our behalf for the purposes described in this Privacy Policy. GCM may also store personal information outside of the Cayman Islands. If we do this your personal information will continue to be protected by means of contracts we have in place with those organizations outside the Cayman Islands. By providing personal information online, visitors are consenting to this transfer and/or storage of their personal information across borders.

GCM will not transfer the personal information you provide to any third parties for their own direct marketing use.

Use by Children
We will not knowingly allow anyone under the age of sixteen (16) to provide us any personal information online. GCM cares about protecting the privacy of children and believe children should always have the permission of their parents before transmitting any personal information over the internet. If you are under 16, please do not engage with our services or provide any personal information.

Your Rights
If you have submitted personal information to GCM, you have the following rights:

1. Access and Correction
2. Object to Processing
3. Removal

You may make a request or exercise these rights by contacting GCM at the address listed at the end of the Privacy Policy. GCM will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

Terms and Changes

In using our services, you agree to the terms of this Privacy Policy. To view further terms governing the use of our services, please visit our Terms of Use page.
As our Privacy Policy changes due to the evolution of digital technology, we will post changes here and indicate at the top the last date of update. Unless otherwise noted, all changes will be effective when posted.

Questions or Concerns
If you have any questions, concerns, or complaints about this Privacy Policy, they should be directed to GCM at the below address.

Global Captive Management LTD
Attn: Legal Department
Building 3, 2nd Floor
23 Lime Tree Bay Avenue
P.O. Box 1363
Grand Cayman, KY1-1108

In any event, you always have the right to lodge a complaint with the Office of the Ombudsman, Cayman Islands.