Privacy Notice

This privacy notice (“Privacy Notice“) sets out how GSR uses and protects your personal data and information. This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a copy of the policy here: https://www.gsr.io/privacy-notice/

• IMPORTANT INFORMATION
• WHO WE ARE? (click here)
• WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT AND ABOUT WHOM? (click here)
• PROSPECTIVE CLIENTS (click here)
• NEW, CURRENT AND/OR FORMER CLIENTS (click here)
• MARKET PARTICIPANTS (click here)
• THIRD-PARTY SUPPLIERS (click here)
• ENQUIRERS (click here)
• VISITORS TO OUR WEBSITE AND OFFICES (click here)
• SUBSCRIBERS TO THE NEWSLETTER (click here)
• HOW IS YOUR PERSONAL INFORMATION COLLECTED? (click here)
• LEGAL GROUNDS FOR PROCESSING (click here)
• HOW WE USE YOUR PERSONAL INFORMATION AND WHY? (click here)
• IF YOU FAIL TO PROVIDE YOUR PERSONAL INFORMATION (click here)
• CHANGING THE PURPOSE FOR WHICH WE PROCESS YOUR PERSONAL INFORMATION (click here)
• DIRECT MARKETING (click here) 
• THIRD-PARTY MARKETING (click here)
• OPTING OUT OF MARKETING (click here) 
• COOKIES (click here)
• DISCLOSURES OF YOUR PERSONAL INFORMATION (click here) 
• INTERNATIONAL TRANSFERS (click here) 
• DATA SECURITY (click here)
• DATA RETENTION (click here)
• YOUR LEGAL RIGHTS (click here)
• THIRD PARTY LINKS (click here)
• CHANGES TO YOUR PERSONAL INFORMATION (click here)
• PERSONAL INFORMATION OF MINORS (click here)
• CONTACT DETAILS (click here) 
• COMPLAINTS (click here) 
• JURISDICTION SPECIFIC TERMS (click here) 

Annex 1 Terms applicable to the British Virgin Isles (click here)

Annex 2 Terms applicable to Hong Kong (click here)

Annex 3 Terms applicable to Singapore (click here)

Annex 4 Terms applicable to Spain (click here)

Annex 5 Terms applicable to Switzerland (click here)

Annex 6 Terms applicable to the United States of America (click here)

Annex 7 Supplier and Vendors (click here)

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1. Important Information [return to Privacy Notice index]

1. Who are we? [return to Privacy Notice index]

The GSR group of companies (“GSR Group“) is made up of different legal entities.

Details of which GSR Group companies this Privacy Notice is issued on behalf of, their roles and location, can be found below.

Country	GSR company	Role
British Virgin Islands	GSR International Trading Ltd (company number: 2076404) is a company established under the laws of the British Virgin Islands whose registered office is at Craigmuir Chambers, Road Town, Tortola, VG 1110, British Virgin Islands.	Controller – Conducts hedging activity on behalf of GSR Markets Limited on derivatives exchanges.
Hong Kong	GSR Holdings Limited (67744542) a company established under the laws of Hong Kong whose registered office is at Suite 5508, 55th Floor, Central Plaza, 18 Harbour Road, Wanchai, Hong Kong.	Controller – to provide the Services.
Hong Kong	GSR Markets Limited (67897929) a company established under the laws of Hong Kong whose registered office is at Suite 5508, 55th Floor, Central Plaza, 18 Harbour Road, Wanchai, Hong Kong.	Controller – to provide the Services.
Singapore	GSR Markets Pte. Limited (company number: 201940723H) is a company established under the laws of Singapore, whose registered office is 6 Shenton Way 3 #25-08 OUE Downtown, Singapore 068809	Controller – to provide the Services.
Spain	SSR Benalmadena XXI, S.L. (company no: 0B88172705 is a company established under the laws of Spain with its registered office at Edificio Eurocomsur, Oficina 6, C / Mauricio Moro Pareto, 2. Malaga 29006	Controller – to provide the Services.
Switzerland	GSR Markets Switzerland GmbH (company number: CHE-492.771.099) is a company established under the laws of Switzerland and whose registered office is c/o Zedra Trust Company (Suisse) SA, Zweigniederlassung Zug, Baarerstrasse 77, 6300 Zug	Controller – to provide the Services.
United Kingdom	GSR Capital Limited (company no: 5355412479) is a company established under the laws of England and Wales with its registered office at C/O Zedra Booths Hall, Booths Park 3, Chelford Road, Knutsford, Cheshire, United Kingdom, WA16 8GS.	Controller – to provide the Services.
United Kingdom	GSR Markets UK Limited (company no: 14832367) is a company established under the laws of England and Wales with its registered office at C/O Zedra Booths Hall, Booths Park 3, Chelford Road, Knutsford, Cheshire, United Kingdom, WA16 8GS.	Controller – to provide the Services.
United Kingdom	GSR International Limited (company number 12569409) is a company established under the laws of England and Wales with its registered office at C/O Zedra Booths Hall, Booths Park 3, Chelford Road, Knutsford, Cheshire, United Kingdom, WA16 8GS	Controller – to provide the Services.
United States of America	GSR Digital LLC (EIN number: EIN 87-4034670) is a company established under the laws of the State of Delaware, USA and whose registered office is c/o Corporation Service Company, 251 Little Falls Drive, Wilmington, DE 19808 (“GSR Delaware”)	GSR Delaware is responsible for providing a privacy notice to you about the Services.

GSR’s business is that of dealing in, with and across cryptocurrencies, cryptocurrency trading platforms and across cryptocurrency markets globally. It includes (a) the provision and administration of various trading services and instruments to Clients, (b) engaging with Clients, exchanges, token issuers, miners and other market participants, (c) the provision of market liquidity as a market maker, and (d) the provision of our Website and Newsletter. 

This Privacy Notice is issued on behalf of the GSR Group so when we mention “GSR”, “we“, “us” or “our” in this Privacy Notice, we are referring to the relevant company in the GSR Group responsible for processing your data. 

GSR is a “controller”. This means that GSR is responsible for deciding how it holds and uses Personal Information about you. 

We are required by law to make a privacy notice available to you containing certain information to make you aware of how and why your Personal Information will be used (namely for the provision of Services to Clients, engaging with Third-Party Suppliers and providing both the Website and Newsletter as applicable) and how long it will be retained for. This Privacy Notice contains that information.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Information about you, so that you are aware of how and why we are using that information and what your rights are under the relevant data protection legislation.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights (Section 11), you can contact the DPO via dpo@gsr.io or via the contact form on our Website (Contact us – GSR Markets). 

• What type of Personal Information do we collect and about whom? [return to Privacy Notice index]

Personal Information, or personal data or personally identifiable information, means any information about an individual from which that person can be identified, directly or indirectly. Personal Information includes pseudonymised data which is data that has been masked or obfuscated, or replaced with another unique identifier, but it is nevertheless still possible to identify an individual. Personal Information does not include data where the person’s identity has been removed so the data has been anonymised. There are certain special categories of data which is classified as a more sensitive type of Personal Information and which require a higher level of protection (“Special Categories of Data”) such as, information about your health, racial or ethnic origin, sexual orientation, or trade union membership. Information about criminal convictions should be treated to the same standard as Special Categories of Data, and for that reason, shall be included with the definition of ‘Special Categories of Data’.

 

Where the context allows below, when we refer to:

• A ‘Client’ (where it is an institution), to ‘Market Participants’ and/or to ‘Third-Party Suppliers’ we may also collect Personal Information about their staff and officers;  
• A ‘Client’ (where an individual) we shall include reference to any representative or agents of an individual, where relevant;  
• The ‘Website’, it shall include reference to visitors to our Website; and/or,
• The ‘Newsletter’, it shall include those having signed up to receive it. 

We may collect the following categories of Personal Information:

1. For prospective Clients with whom we are not yet taking steps to enter into a contractual relationship, we may collect use, store and transfer (to the extent permitted by applicable law): 

• Identity Data such as your first name, last name and your marital status; 
• Contact Data such as your address, email address, telephone number or Telegram account name (or other social media platform account name); 
• Profile Data includes information such as your job title and work experience and otherwise related to your professional profile (such as directorship / positions / professional networks), information related to company ownership (including other shareholders and/or beneficial owners), business partners, representatives or agents; information about financial status and background; your knowledge of and experience in investment matters; your related interests and preferences; and/or,

and any other data you share with us. 

[return to Privacy Notice index]

1. For new Clients with whom we are taking steps to enter into a contractual relationship, Clients we have a current contractual relationship and/or former Clients with whom we have had a prior contractual relationship, we may collect, use, store and transfer (to the extent permitted by applicable law):

• Identity Data includes first name, last name, any previous names, family details (such as marital status, name of spouse or partner, children) or nominated person(s)), title, date of birth, gender, country of domicile, username and any internal identifiers we assign to you;
• Contact Data includes your principal contact, business and/or billing address, email address, telephone numbers (including for your nominated person(s)) or Telegram account name (or other social media platform account name); 
• Profile Data includes information such as your job title, professional profile (such as directorship / positions / professional networks); information related to company ownership; your background, knowledge of and experience in financial services, in trading of investments products and services, and, your understanding of the associated risks involved; your related interests and preferences; 
• Verification Data includes any documentation to confirm and verify your identity, for example only, documents; information that we may collect, includes (but is not limited to) identification documents (such as a national identity card, passport, driving licence residence permit or social security number or analogous document) and Personal Information contained in such documents (including but not limited to: address, nationality, date of birth, country of issue and photos or images of you); any relevant publicly available Personal Information to verify your identity;
• Financial Data: includes financial information, BIC code, Swift number, IBAN, bank account numbers and sort codes or other payment routing number, any assigned identifiers for accounting purposes, information relating to your assets, wallet address, financial statements, statements of account; 
• Transaction Data includes details and records relating to transactions that are fiat to digital, digital to digital, and digital to fiat; details of Services you have taken; details of digital assets or digital instruments traded; associated transaction records; 
• Technical Data includes internet protocol (IP) address, login data, browser type, version and browser language, time zone setting and general location, browser plug-in types and versions, operating system and platform, device information (for example, device type and device identity), application log information and other technology on the devices you use; 
• Communication Data includes details of our interactions with you and the Services you use, correspondence (including electronic interactions across various channels such as e-mails, social media platforms or other messaging applications and technologies) across any device used to communicate with us, and any other records of interactions (in the case of any telephone calls between you and us this may include phone log information such as your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls), as well as CCTV when attending our place of business; 
• Special Categories of Data such as your biometric information, political opinions or affiliations, religious or philosophical beliefs, and, to the extent legally permissible, information relating to criminal convictions or offences; 
• Marketing and Communications Preference Data includes any marketing or services communications preferences that you have provided to us; and/or,

and any other data you share with us.

[return to Privacy Notice index]

1. For Market Participants 

• Identity Data includes first name, last name, any previous names and any internal identifiers we assign to you, such as your client number, and including any username or similar identifier provided to use that is a unique identifier of you;
• Contact Data such as your business address, email address, telephone number or Telegram account name (or other social media platform account name); 
• Profile Data includes information such as your job title and otherwise related to your professional profile (such as directorship / positions / professional networks), information related to company ownership and financial background, experience in financial services and in trading of investments products and services; 
• Verification Data includes any documentation to confirm and verify your identity, for example only, documents; information that we may collect, includes (but is not limited to) identification documents (such as a national identity card, passport, driving licence residence permit or social security number or analogous document) and Personal Information contained in such documents (including but not limited to: address, nationality, date of birth, country of issue and photos or images of you); any relevant publicly available Personal Information to verify your identity;
• Financial Data: includes financial information, BIC code, Swift number, IBAN, bank account numbers and sort codes or other routing number, any assigned identifiers for accounting purposes, information relating to your assets, wallet address, statements of account; 
• Transaction Data includes details and records relating to transactions that are fiat to digital, digital to digital, and digital to fiat; details of digital assets or digital instruments traded; associated transaction records (including counterparties); 
• Technical Data includes internet protocol (IP) address, login data, browser type, version and browser language, time zone setting and general location, browser plug-in types and versions, operating system and platform, device information (for example, device type and device identity), application log information and other technology on the devices you use; 
• Communication Data includes details of our interactions with you, including correspondence (via electronic interactions across various channels such as e-mails, social media platforms or other messaging applications and technologies) across any device used to communicate with us, and any other records of interactions (in the case of any telephone calls between you and us this may include phone log information such as your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls), as well as CCTV when attending our place of business;
• Special Categories of Data such as your biometric information, political opinions or affiliations, religious or philosophical beliefs, and, to the extent legally permissible, information relating to criminal convictions or offences, or the fact of a criminal record; and/or, and any other data you share with us.

[return to Privacy Notice index]

1. For Third-Party Suppliers with whom we are taking steps to enter into a contractual relationship, with whom we have a current or past contractual relationship, we may collect, use, store and transfer (to the extent permitted by applicable law):  

• Identity Data such as your first name, last name, marital status, country of domicile and any internal identifiers we assign to you; 
• Contact Data such as your business address, billing address (if different), email address, telephone numbers;
• Profile Data includes information such as your job title and your professional profile (such as directorship / positions / professional networks); information related to company ownership; 
• Verification Data includes any documentation to confirm and verify your identity, for example only, documents; information that we may collect, includes (but is not limited to) identification documents (such as a national identity card, passport, driving licence residence permit or social security number or analogous document) and Personal Information contained in such documents (including but not limited to: address, nationality, date of birth, country of issue and photos or images of you); any relevant publicly available Personal Information to verify your identity;
• Financial Data: includes financial information, BIC code, Swift number, IBAN, bank account numbers and sort codes or other routing number, any assigned identifiers for accounting purposes, statements of account, taxes (including tax identification information) and related financial information;
• Technical Data includes internet protocol (IP) address, operating system and platform, device information (for example, device type and device ID), system log information, application log information, and other access management and record keeping technology on the devices or applications you use to access or connect with our systems and/or applications; 
• Communication Data includes details of our interactions with you and the services you support or provide, correspondence (including electronic interactions across various channels such as e-mails, social media platforms or other messaging applications and technologies) across any device used to communicate with us, and any other records of interactions (in the case of any telephone calls between you and us this may include phone log information such as your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls), as well as CCTV when attending our place of business; and/or, and any other data you share with us.

[return to Privacy Notice index]

1. For Enquirers:

• Identity Data includes first name, last name, your marital status, any username and any internal identifiers we assign to you;
• Contact Data such as your address, email address, telephone number or Telegram account name (or other social media platform account name); 
• Verification Data includes any documentation to confirm and verify your identity, for example only, documents; information that we may collect, includes (but is not limited to) identification documents (such as a national identity card, passport, driving licence residence permit or social security number or analogous document) and Personal Information contained in such documents (including but not limited to: address, nationality, date of birth, country of issue and photos or images of you); any relevant publicly available Personal Information to verify your identity;
• Communication Data includes details of our interactions with you, including correspondence (via electronic interactions across various channels such as e-mails, social media platforms or other messaging applications and technologies) across any device used to communicate with us, and any other records of interactions (in the case of any telephone calls between you and us this may include phone log information such as your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls), as well as CCTV when attending our place of business; and/or, and any other data you share with us.

[return to Privacy Notice index]

1. For visitors to our Website, office premises, we may collect use, store and transfer (to the extent permitted by applicable law): 

• Identity Data such as your first name, last name, and potentially your marital status; 
• Contact Data such as your address, email address, telephone number or Telegram account name (or other social media platform account name); 
• Technical Data includes internet protocol (IP) address, your login data, browser type, version and browser language, time zone setting and general location, browser plug-in types and versions, operating system and platform, device type and ID, and other technology on the devices you use to visit our Website, submit an enquiry, feedback or a complaint;
• Communication Data includes details of our interactions with you via our Website, including correspondence (via electronic interactions across various channels such as e-mails and various mobile device applications, including Telegram), and any records of telephone calls between you and us (which may include phone log information such as your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls); 
• Profile Data includes your interests and preferences;
• Usage / Behavioural Data includes information about how you interact with and use our Website, e-mails and/or data that we gather through your use of them (which in may include data transmitted by your browser or device you are using and automatically recorded by our server, the referrer URL (web page that you were on when you clicked a link that sent you to our Website), details of when your current or previous sessions started including date and time of the access, content you view or engage with, the name of the accessed file as well as the transmitted data volume and the performance of the access); and/or, and any other data you share with us.

[return to Privacy Notice index]

1. For individuals subscribing to the Newsletter, we may collect use, store and transfer (to the extent permitted by applicable law):

• Identity Data such as your first name, last name; 
• Contact Data such as your business name, email address, telephone number and Telegram account name; and/or,
• Profile Data includes your interests and preferences, 

and any other data you share with us.

In some cases, we collect information from public registers (depending on the Service you receive from us and the country of the GSR entity with which you have a contractual relationship), public administration or other third-party or public sources, such as (for example only) wealth screening services, credit reference agencies, fraud prevention agencies, and other companies in the GSR Group. 

Where you are an institutional, corporate or investor Client, Market Participant or Third-Party Supplier, before providing GSR with any information about your directors, representatives, staff, shareholders, or any beneficial owner, you should provide a copy of this Privacy Notice to those individuals.

We may process Personal Information for analytics and measurement (including machine learning) for example by looking at information we obtain via cookies and tracking technologies. Please refer to our Cookie Notice. 

We also collect, use and share aggregated data such as statistical or demographic data which is not Personal Information as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage / Behavioural Data to calculate the percentage of users accessing a specific Website feature to analyse general trends in how users are interacting with our Website to help improve the Website and our service offering.

[return to Privacy Notice index]

• How is Personal Information collected? [return to Privacy Notice index]

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your Personal Information however you correspond with us whether by post, phone, email or otherwise. This includes Personal Information you provide when you:
  • contact us with enquiries, feedback or a complaint; 
  • complete our forms;
  • apply to become, or are on-boarded as, a Client;
  • instruct us to trade or otherwise use our Services;
  • engage in any discussions for the purposes of taking steps to enter into a contract with us;
  • and we discuss, operate and manage our commercial relationship, or prospective commercial relationship in any meeting;
  • communicate with us in any way, including (but not limited to) via electronic interactions across various channels such as e-mails, social media platforms or other messaging applications and technologies, and telephone;
  • subscribe to our Newsletter via the Website; and/or,
  • request marketing or informational material to be sent to you.

• Providers of digital transaction services and exchanges. Financial and Technical Data can be collected from Market Participants globally, including when engaging with GSR as trading counterparty or when buying, selling, or confirming the authenticity of any transaction;

• Automated technologies or interactions. As you interact with our technical and technology systems (including but not limited to our Website and social media applications and platforms), we may automatically collect Technical Data and Usage / Behavioural Data about your equipment, interaction and browsing behaviour, actions and patterns. Currently we use automated processing to collect Personal Information in connection with recruitment (please see our separate candidate privacy notice), identity confirmation and verification, as well as in connection with an instruction to trade and transaction processing.  We collect this Personal Information by using cookies and other similar technologies. Please see our Cookie Notice for further details.
• Commercial third parties. We may receive Personal Information about you from third parties. Such third parties may include (but are not limited to) analytics providers that provide technical services to us (for example, email customer relationship management platforms), which support us in conducting our business.
• Publicly available sources. Identity, Contact and Profile Data is collected from the following (non-exhaustive list of) publicly available sources:  
  • in the UK, such as:
    • His Majesty’s Revenue and Customs;
    • The Electoral Register;
    • Disclosure and Barring Service;
    • Credit Reference Agencies;
    • Companies House;
    • Crypto industry specific sources (such as, for example only: Crunchbase, Coingecko) and including crypto exchanges; 
    • Open-source intelligence; and, 
    • Comply Advantage; 
  • Any like, equivalent or similar source (without limitation in scope) of those sources as listed above for the UK, but applicable to any relevant jurisdiction; 
  • Anywhere in the world:
    • Professional societies, associations and/or business-related social media (for example only, such as LinkedIn);
    • Speeches at events or other speaking events; 
    • Published articles; 
    • Media reports;
    • News stories; and/or, 
    • Posts on social media platforms, for example only, X (formerly Twitter) and LinkedIn.

• Legal grounds for processing  [return to Privacy Notice index]

The law requires us to have a legal basis for collecting and using your Personal Information. We rely on one or more of the following legal bases:

• • Performance of a contract with you: Where we need to perform a contract, we have entered into with you, or we are about to enter into with you.
  • Legitimate interests: We may use your Personal Information where it is necessary to conduct our business and pursue our legitimate interests, for example to enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Legal obligation: We may use your Personal Information where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

• Consent: We rely on consent only where we have obtained your active agreement to use your Personal Information for a specified purpose, for example if you subscribe to our email newsletter.

• How we use your Personal Information, and why? [return to Privacy Notice index]

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances: 1. Where we need to perform the contract, we have entered into with you. 2. Where we need to comply with a legal obligation. 3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.  We may also use your personal information in the following situations, which are likely to be rare: 1. Where we need to protect your interests (or someone else’s interests). 2. Where it is needed in the public interest or for official purposes.

We have set out below, in a table format, a description of all the ways we plan to use (“Purpose”) the various categories of your Personal Information (“Type of Data”), and which of the legal bases (“Legal Basis”) we rely on to process Personal Information. We have also identified what our legitimate interests are where appropriate.

Table: Purposes for how we use your Personal Information

Purpose	Type of Data	Legal Basis
To register and on-board you as a new client. (This includes (as a non-exhaustive list) verifying your identity, assessing your application, for legal and regulatory compliance checks, for example, anti-money laundering regulations, counter terrorist financing and to prevent fraud).	Identity Data,  Contact Data,  Verification Data, Financial Data (where relevant), Profile Data, and, Special Categories of Data (where applicable).	Performance of a contract with you  Compliance with law Legitimate interests (to ensure that we can provide you the Services in a secure, efficient and compliant manner) Substantial Public Interest  Consent (to process data relating to political exposed persons, and criminal allegations, convictions or offences)
To supply our Services, maintaining user databases and recording how our Services are used.  (This includes crypto market trading (including OTC derivatives), algorithmic trading, risk management and the provision of portfolio solutions; sending service communications, administrative or account-related information; informing you of security issues or updates or providing other transaction-related information.)	Identity Data,  Contact Data,  Financial Data (where applicable),  Transaction Data,  Technical Data, Communication Data, and, Profile Data.	Performance of a contract Legitimate interests (to ensure that we provide the Services in an effective, secure and compliant manner)
Where you work for a Market Participant or Third-Party Supplier, to engage with you for the purposes of, or otherwise in connection with the receipt and use by us of your products and/or services for the purpose of running our business.	Identity Data,  Contact Data,  Verification Data, Financial Data (where applicable),  Technical Data (where applicable), Communication Data, and, Profile Data.	Performance of a contract with you  Compliance with law Legitimate interests (to ensure that we have the ability to supply effective, secure and compliant Services to Clients, and conduct, process and complete digital asset transactions).
To ensure quality control of our Website, Newsletter and Services	Identity Data Contact Data Financial Data Transaction Data Technical Data Communication Data Profile Data Usage/Behavioural Data, and, Any other Personal Information you volunteer	Performance of a contract  Legitimate interest (to use Personal Information to ensure we provide a good quality Service, have an effective working relationship with you / your organisation, and supply relevant Services in an efficient, secure and compliant way).
To manage our relationship with you and/or your organisation (Includes communicating with you with regards to the Services taken, handling requests, complaints, enquiries and other queries; notifying you about changes to our terms or Privacy Notice, managing your account(s); and processing of your Personal Information for the purposes of relationship management).	Identity Data Contact Data Verification Data, Financial Data (if applicable) Transaction Data (if applicable) Technical Data, Communication Data,  Profile Data, and, Marketing and Communication Preference Data	Performance of a contract with you  Necessary to comply with a legal obligation Legitimate interests (to maintain / enhance relationship as well as assess eligibility of Services, to achieve increased Client understanding and engagement and improve our Services; to facilitate the safe, effective and compliant operation of our business; to share, conduct, process and complete transactions with Market Participants; to engage with Third-Party Suppliers; and to keep our records updated, and, manage our relationship with you (including but not limited to the establishment and defence of legal claims)
To comply with our legal and regulatory obligations or in connection with the administration of our business, the provision and delivery of the Services to you / your organisation including operation of our systems and processes, engagement with Market Participants, provision of the Website and engagement of our Third-Party Suppliers.	Identity Data Contact Data Verification Data Financial Data Transaction Data  Technical Data Profile Data Usage / Behavioural Data Communication Data Special Categories of Data, and, Marketing and Communication Preference Data	Performance of a contract with you Legitimate interest (to comply with our legal obligations (including under Substantial Public Interest grounds), to detect and prevent the misuse of our Services, to maintain the security of our systems architecture, networks and staff, enforce compliance with law and legal rights, to protect the rights of third parties, to use in connection and (where appropriate) share with Third-Party Suppliers for the safe effective and compliant provision of our Services, to share with Market Participants to conduct, process and complete transactions, to use in connection with any enquiry, investigation, claim or query, and/or in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets)  Compliance with law (otherwise than as above, which may include data relating to criminal convictions or offences) Substantial Public Interest Consent (to process data relating to political exposed persons, and criminal convictions or offences)
To administer our security measures (including CCTV and building access controls).  (Data captured are securely stored, accessed on a need-to-know basis and typically (e.g. for CCTV images) are automatically overwritten after a short period of time).	Identity Data Contact Data Verification Data (if applicable) Communication Data and, Any other Personal Information you volunteer	Performance of a contract  Compliance with law Legitimate interests (to process your Personal Information so that we can keep our premises secure and provide a safe environment for your visit).
To administer and protect our staff, business, premises, the on-boarding portal and the Website, plus troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data	Identity Data Contact Data Verification Data (if applicable) Technical Data, (if applicable) Communication Data Any other Personal Information you volunteer	(a) Legitimate interests (to safely and effectively run our business, staff, premises, the provision of administration and IT services, network security (for example, to prevent or detect crime), and, for any business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To use data analytics help us understand and improve our Website and social media platform(s) (such as LinkedIn, X and/or Telegram) (We use your data to help us understand how you use / navigate our Website and social media, which parts are more or less popular, to improve the structure and navigation of the Website, improve user experience, and to measure the effectiveness of our communications and marketing). Please see ‘6.6 Cookies’ below to learn more about how we use cookies, web beacons, pixel tags and other technologies to help us understand more about the use and effectiveness of our Website. The relevant social media platform may also be a controller in respect of your Personal Information. For details about the relevant social media platform’s use your Personal Information, please see their privacy notice.	Identity Data Technical Data Communication Data Usage / Behavioural Data	Legitimate interests (to study and gain insights about how our Website and social media is used by Clients, to keep our Website secure effective and updated, to optimise user experience, to inform our marketing strategy to develop and growth our business, and, for training purposes)
We may send you marketing communications by email (We may use your Personal Information to send you (or the organisation you represent) marketing communications by email. Our marketing may include information about events, our newsletter, our Website, our Services, company news, market commentary and will always include functionality enabling you to the ability to unsubscribe or otherwise change your preferences).	Identity Data,  Contact Data, and, Usage / Behavioural Data, (where applicable), Profile Data, Marketing and Communication Preference Data	Legitimate interests (to send marketing content we think may appeal to Clients who have purchased our Services)  Consent (where you have signed up to receive the Newsletter)
If you have a general question or need help with our Services (There are various ways in which you can contact us (see Our Contact Details you can contact us via the Website at Contact us – GSR Markets.  If you have a technical issue concerning our Website, we may also collect and process Usage / Behavioural Data and Technical Data to help us diagnose any technical issues you have so we can resolve them in an efficient way. We use this information to manage and respond to your enquiry).	Identity Data,  Contact Data and  Communication Data Usage / Behavioural Data (where applicable) Any other Personal Information you volunteer	Legitimate interests (to help you with your enquiry, provide a good standard of service and improve our customer services) Consent

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your Personal Information. 

Additionally, we do use automated decision making in connection with:

• Identity verification: machine learning has been trained on data sets to create a software algorithm that has the ability to accurately assess, analyse and evaluate an identity document to authenticate it. This algorithm categorises the government issued identity, performs a suite of technical checks (for example only, image checks) and analyses the relevant security features, the information provided on the identity and then assesses whether there are any signs of tampering or forgery, and, provides a report for review on the authenticity of an identity document. Where the algorithm returns a result other than the government issued identity is authentic, such result is flagged for an internal manual review by a GSR employee; and/or,
• Transaction monitoring: where instructions to place a trade can be quarantined and flagged for review.  The automated decision making for transaction monitoring is more rules based than machine learning and is based around customisable pre-set parameters.  Once flagged, a transaction is reviewed by an appropriate GSR member of staff in the Legal & Compliance team to confirm or override the suggested automated decision taken (to conduct the trade or not). 

We also use automated decision making in connection with recruitment, for which, please see our separate candidate privacy notice. 

We comply in all material respects with the law applicable to automated processing and automated decision making.

Please also see our Cookie Notice for how and why we use which cookies.

• If you fail to provide your Personal Information or information about you  [return to Privacy Notice index]

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as provide with relevant Services) or otherwise decline to provide Services because we may be prevented from complying with our legal obligations (such as our compliance and background checks). 

• Changing the purpose for which we process your Personal Information  [return to Privacy Notice index]

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 

Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

• Direct marketing  [return to Privacy Notice index]

Currently we do not send marketing communications to you about our Services where you have purchased Services from us, and you have not opted out of receiving the marketing. We may do so in the future. 

Currently you will only receive information about our Services where you have either requested we send you the information or have signed up via the Website to our Newsletter. 

Please also see the table Purposes for how we will use your Personal Information above.

• Third-party marketing  [return to Privacy Notice index]

We will never sell your Personal Information to any third party for their own direct marketing purposes. 

• Opting out of marketing  [return to Privacy Notice index]

As above currently we do not send marketing communications to you about our Services. You may still receive service-related communications that are essential for administrative or customer service purposes, for example, trade order confirmations.

If you have subscribed to the Newsletter you can ask to stop sending it to you at any time by following the ‘Unsubscribe’ link or clicking the ‘Update Your Preferences’ link within any email sent to you. Clicking on ‘Update Your Preferences’ will enable you to adjust and tailor your preference profile by unchecking relevant individual boxes.

• Cookies  [return to Privacy Notice index]

For more information about the cookies, we use and how to change your cookie preferences, please see our Cookie Notice.

• Disclosures of your Personal Information [return to Privacy Notice index]

We only share Personal Information with others when we are legally permitted to do so. 

We may share your Personal Information where necessary (as set out below) for the purposes set out in the table Purposes for how we will use your Personal Information above. The list in the table below is non-exhaustive and there may be circumstances where we need to share Personal Information with other third parties.

 

Who we share with	When we share your Personal Information
Companies within the GSR Group	We may share Personal Information with the GSR Group to run our business and provide our Services.
Law enforcement or other government and regulatory agencies and bodies	We share Personal Information with law enforcement, other public, government and/or regulatory agencies and/or lawful authorities with jurisdiction or other third parties as required by applicable law or regulation. Occasionally, we may receive requests from third parties to obtain certain Personal Information to check that we are complying with applicable law and regulation, to investigate an alleged crime, or, in the course of establishing, exercising or defending legal rights. We will only fulfil requests in accordance with applicable law or regulation.
Third parties in transaction processing	We share Personal Information with third parties who assist us with transaction processing including with: a party acquiring interest in, or assuming risk in or in connection with, an asset or transaction, their representative or agents; an issuer or seller of digital assets or tokens (including third parties appointed by them) in which you have an interest, including where such assets are held by third parties for you; transaction recipients, beneficiaries, account nominees, intermediaries and/or their agents; and/or, Exchanges, market counterparties clearing or settlement systems and other third-party financial services institutions.
Professional advisers and consultants	We share Personal Information with auditors, lawyers, insurers, accountants and other professional services firms or consultants who advise and assist us in relation to the lawful and effective management of our organisation, as well as in relation to any dispute we may become involved in.
Third-party business acquirers	Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Privacy Notice.
Third-Party Suppliers	We share Personal Information with third party service providers with whom there is a commercial relationship and who are contractually bound to confidentiality, such as cloud services providers, providers of software-as-a-service, error tracking software, analytics software, information technology, identity management, public databases, ID verification partners, credit reference services, anti-fraud databases, data analysis, insight analytics, data back-up, security and storage services, logistics, Website hosting and management, marketing and communication providers (such as  third-party post/email marketing and customer relationship specialists who help us in managing our marketing database, sending marketing communications and account-related communications) and others. (The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and Personal Information may be stored in any one of them).

• International transfers [return to Privacy Notice index]

We may have to share your data with third parties, including Third-Party Suppliers and other entities in the GSR Group of companies. We require third parties to respect the security of your Personal Information and to treat it in accordance with the law.  We may transfer your Personal Information outside the UK. If we do, you can expect a similar degree of protection in respect of your Personal Information.

We may share your Personal Information within the GSR Group and may share it with our Third-Party Suppliers (where necessary) in order to run our business, provide our Services and the Website.  

When you submit Personal Information to us you acknowledge that your Personal Information may be transferred outside the UK where it may be stored and processed by us, the GSR Group and/or our Third-Party Suppliers for the purposes set out in this Privacy Notice.

When transferring your Personal Information outside the UK, we will, where required by applicable law, implement at least one of the safeguards set out below which give your Personal Information the same protection it has in the UK. 

Adequacy decisions	We may transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the UK Government.
Standard Contractual Safeguards	Where we use certain service providers, we may use specific contractual clauses approved by the ICO (the UK International Data Transfer Agreement, or the Addendum to the EU standard contractual clauses, when EU standard contractual clauses are used).

Please contact us if you would like further information on the specific mechanisms used by us when transferring your Personal Information outside the UK. 

Outside of the UK, the countries in which the GSR Group currently operates include: British Virgin Islands, Hong Kong, Japan, Singapore, Spain, Switzerland, and/or the United States of America.

• Data security [return to Privacy Notice index]

We have put in place appropriate security measures to prevent any accidental or unlawful destruction, loss, alteration, from any unauthorised disclosure of, or access to your Personal Information however it is transmitted, stored or otherwise processed. 

In addition, we limit access to your Personal Information to those of our staff and other third parties who have a business need to know. They will only process your Personal Information on our instructions, and they are subject to a duty of confidentiality and to keep your Personal Information secure. 

Before we share your Personal Information with any member of the GSR Group or a Third-Party Supplier we take steps to put contractual arrangements and security mechanisms in place that ensure they meet our data protection, confidentiality and security standards and obligations so that your Personal Information remains secure. 

Each GSR Group company and Third-Party Supplier must comply with a list of technical and organisational security measures, irrespective of their location, including measures relating to: (i) information security management; (ii) information security risk assessment and (iii) information security measures (e.g., physical controls; logical access controls; malware and hacking protection; data encryption measures; backup and disaster recovery management measures). 

We do not allow any other business to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

We have put in place procedures to deal with any suspected or actual Personal Information breach and will notify you and any applicable regulator of a breach where required to comply with law.

• Data retention: How long will you use my Personal Information for? [return to Privacy Notice index]

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying or complying with any legal, regulatory, compliance, tax, accounting, reporting or internal policy requirements (which comply with the minimum requirements of applicable law and regulation) and/or risk management purposes. 

To determine the appropriate retention period for Personal Information, we consider: the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and/or the applicable legal, regulatory, compliance, tax, accounting or other requirements. 

If you are a prospective Client we shall keep your Personal Information for as long as you consent, otherwise for a maximum of twelve months from our last contact with you. 

We will keep your Personal Information for as long as you remain a Client in the case of new or current Clients, otherwise for as long as is required to meet our regulatory requirements or in compliance with applicable law. 

Once our relationship with you has ended (for example, after your account has closed or following a transaction, your application for a product is refused, or you decide not to go ahead with an application), we will only keep your Personal Information for a period that is appropriate, being a minimum of 5 years, and in some cases up to 10 years.  The same is true for any Personal Information relating to any Market Participants.

If you unsubscribe from our newsletter we endeavour to update our records within twenty-four hours. To learn more about how long cookies persist, please see our Cookie Notice.  We keep records of visitors to our offices in accordance with the requirements of local law. 

We may retain your Personal Information for a longer period in the event of an enquiry, feedback or complaint or if we reasonably believe there is any litigation (or the prospect of any litigation) in respect to our relationship with you. 

In some circumstances you can ask us to delete your data: see ‘Your legal rights’ below for further information.

In some circumstances we will anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

• Your legal rights [return to Privacy Notice index]

You have a number of rights under data protection laws in relation to your Personal Information. 

You have the right to:

• Request access to your Personal Information (“subject access request“). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Information in certain circumstances. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including were we carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your Personal Information for direct marketing purposes (see “Opting Out of Marketing” in Section 6.5 for details of how to object to receiving direct marketing communications). 
• Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Information (see the table in Section 6 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain of the Services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in one of the following scenarios:

• If you want us to establish the data’s accuracy;
• Where our use of your Personal Information is unlawful, but you do not want us to erase it;
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• You have objected to our use of your Personal Information, but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please see Contact details (Section 15). 

Please also note that the above rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse requests, which may include not providing some or all of the Personal Information that we hold about you. In the event that we cannot accommodate your request, we will inform you of the reasons why, subject to where there may be any legal or regulatory restrictions on us informing you. 

No fee usually required

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. 

 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated. 

• Third-party links [return to Privacy Notice index]  

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the Privacy Notice of every website you visit.

• Changes to your Personal Information [return to Privacy Notice index]

We are committed to keeping your Personal Information accurate and up to date. Therefore, if your Personal Information you gave us changes, for example a new email address, please inform us of the change as soon as possible.

•  Personal Information of minors [return to Privacy Notice index]

As above, GSR Services and the Website are not intended for use by, or targeted at, minors (individuals under the age of 18). We do not knowingly collect or process Personal Information of minors. If we receive Personal Information of minors, we will comply with all applicable laws and regulations relating to the processing of Personal Information of minors. Please contact us if you believe that a minor may have submitted Personal Information to us.

• Our contact details [return to Privacy Notice index]

If you have any questions about this privacy notice or about the use of your Personal Information or want to exercise your privacy rights, please contact the Data Protection Officer or their team in the following ways:

• Email address: dpo@gsr.io 
• Postal address: FAO The Privacy Team, 65 Curzon Street, 3rd Floor, London W1J 8PE United Kingdom

• Complaints  [return to Privacy Notice index]

You have the right to make a complaint at any time if you feel the processing of your Personal Information infringes applicable privacy and data protection law:

• In the case of the United Kingdom, you can complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). 
• We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority so, please contact us in the first instance.

• Updates to this Privacy Notice    [return to Privacy Notice index]

We reserve the right to update this Privacy Notice at any time, and we will make a new Privacy Notice available to you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information. 

Privacy Notice (General) v1.24 (November 2024) 

 

Annex 1 – British Virgin Islands 

Terms applicable in the British Virgin Islands 

In addition to the terms of the Privacy Notice if you are in the British Virgin Islands (“BVI”), in relation to the British Virgin Islands’ Data Protection Act, 2021 (“BVI DPA”) the following additional terms apply:

1. GSR International Trading Limited (“GSR BVI”) is a non-client, non-supplier or vendor facing trading entity.  
2. GSR BVI is a controller only as regards engaging with public sector organisations (such as BVI regulatory authorities). GSR BVI will otherwise be a processor in respect of the conducting of any other business including trading with any third parties or engaging in the conduct of any financial services business.
3. The BVI DPA applies indirectly to processors.  Where any trading counterparty controllers contractually oblige GSR BVI to comply with BVI DPA, GSR BVI shall comply with such obligations. 
4. GSR BVI only uses Personal Information for purposes that a reasonable person considers appropriate in the circumstances.  
5. Under BVI DPA, there is no legitimate interest condition as a lawful basis for processing Personal Information.  As such we shall use another ground as outlined in Section 6. 
6. For the purposes of this Annex 1, interpretation of the definition of ‘Data Subject’ shall include a natural person, whether living or deceased.
7. Whenever we transfer your Personal Information out of the BVI to a recipient in a country which does not have laws that provide the same level of data protection as provided for under the BVI DPA, we always ensure that the recipient complies with the requirements of the BVI DPA where applicable to ensure that a similar or comparable degree of protection is afforded to your Personal Information. 
8. Under the BVI DPA: 
   1. There is no separate right:
      1. To erasure (other than rectification) of your Personal Information;
      2. To data portability; and/or
      3. Not to be subject to automated decision making, 
   2. There are the additional Data Subject rights to bring civil proceedings in the BVI High Court for damage or distress caused by contravention of the DPA.

but we reserve the right to choose, without an obligation, to nevertheless endeavour to service such a request from you. Where we choose on a particular occasion to service any request under paragraphs 1.8.1-1.8.3 it shall not act to set any precedent whatsoever. 

1. If you have any questions about this Privacy Notice or about the use of your Personal Information, or you want to exercise your privacy rights, please contact the Data Protection Officer and their team in the following ways:
   1. Email address: dpo@gsr.io 
   2. Postal address: FAO The Privacy Team (London), 65 Curzon Street, 3rd Floor, London W1J 8PE, United Kingdom 
2. As at the date of this Privacy Notice, whilst the supervisory authority under the BVI DPA has been founded, it has not yet been staffed. If you feel the processing of your Personal Information infringes the BVI DPA at any time, please contact us and let us know. We would appreciate the chance to deal with your concerns before you approach an appropriate authority and ask that you contact us in the first instance.

[return to Privacy Notice index]

 

Annex 2 – Hong Kong

Terms applicable in Hong Kong

In addition to the terms of the Privacy Notice if you are in Hong Kong, the following additional terms apply:

1. To the extent that Hong Kong’s Personal Data (Privacy) (Amendment) Ordinance 2021 (“PDPO”) applies direct to GSR, GSR will comply with the PDPO in all material respects. 
2. Under the PDPO, you do not have an express right:
   1. To erasure (other than rectification or correction);
   2. To restrict or object to the processing of Personal Information;
   3. To data portability; 
   4. To withdraw consent; and/or,
   5. Not to be subject to automated decision making,

but we reserve the right to choose, without an obligation, to nevertheless endeavour to service such a request from you. Where we choose on a particular occasion to service any request under 1.1.1-1.1.5 it shall not act to set any precedent whatsoever. 

1. You do have the right to:
   1. access your Personal Information, and/or, 
   2. rectify / correct your Personal Information where it is inaccurate or incomplete.
2. Under the PDPO we have forty (40) days to respond to any subject access request.
3. GSR may, but is not obliged to, charge an individual a fee in order to recover the costs of responding to a subject access request but such fee shall not be excessive.
4. Whenever we transfer your Personal Information out of Hong Kong to a recipient in a country which does not have laws that provide the same level of data protection as under Hong Kong’s Personal Information (Privacy) Ordinance (PDPO), we always ensure that the recipient complies with the requirements of the PDPO where applicable to ensure that a similar or comparable degree of protection is afforded to your Personal Information (including but not limited to a level no less than the recommended model clauses).
5. If you have any questions about this Privacy Notice or about the use of your Personal Information, or you want to exercise your privacy rights, please contact the Data Protection Officer and their team in the following ways:
   1. Email address: dpo@gsr.io 
   2. Postal address: FAO The Privacy Team (London), GSR Markets Suite 5508, 55th Floor, Central Plaza, 18 Harbour Road, Wanchai, Hong Kong 
6. We would appreciate the chance to deal with your concerns before you approach an appropriate authority and ask that you, please contact us in the first instance. However, you can complain at any time if you feel the processing of your Personal Information infringes the PDPO by writing to the Office of the Privacy Commissioner for Personal Data, the Hong Kong regulator for data protection issues (www.pcpd.org.hk). We would appreciate the chance to deal with your concerns before you approach an appropriate authority and ask that you contact us in the first instance.

[return to Privacy Notice index]

 

Annex 3 – Singapore

Terms applicable in Singapore

In addition to the terms of the Privacy Notice if you are in Singapore, the following additional terms apply:

1. To the extent that the Personal Data Protection Act of 2012 (No. 26 of 2012) of Singapore (“PDPA”) applies directly to GSR, GSR will comply with the PDPA in all material respects. 
2. “Personal Information” in the Privacy Notice shall include the definition of personal data under the PDPA. The PDPA does not apply to Personal Information about a deceased individual, except as regards the disclosure and protection of the Personal Information about an individual who has been dead for ten (10) years or less.
3. The PDPA does not apply to business contact information supplied solely for business purposes, such as: name, position, title, telephone number, address, email address or fax number. The PDPA however still governs business contact information provided by individuals solely in their personal capacity. Where the purposes are mixed (that is, for both business and personal purposes), the Act does not apply.
4. For the purposes of interpreting ‘consent’ in the Privacy Notice, your consent can either be:
   1. Express consent arising after being provided with the information in this Privacy Notice; 
   2. Deemed consent by conduct arising where you voluntarily provide Personal Information in connection with the purposes as outlined in this Privacy Notice; or, 
   3. Deemed consent by contractual necessity where the disclosure of Personal Information is necessary for the performance or conclusion of a transaction.
5. Where consent is the legal basis for processing, we are entitled to rely on deemed consent, for example where:
   1. you voluntarily provide information (deemed consent by conduct); and/or,
   2. where you have been notified of the collection, use or disclosure for which your Personal Information shall be processed in this Privacy Notice, and you have not sought to opt-out of such collection use or disclosure of your Personal Information (deemed consent by notification).
6. Under the PDPA, we can collect, use or disclose Personal Information about you without your consent for the following non-exhaustive list of purposes:
   1. Business improvement purposes (by the collecting GSR company or within the GSR Group); and,
   2. Legitimate interests (excluding marketing purposes).
7. We will only use personal identification numbers if required by law or where necessary to verify your identity to a high degree of accuracy.
8. Under the PDPA you have a right (which may not be unqualified in all cases):
   1. To access your Personal Information (including information about the ways in which that Personal Information has been or may have been used or disclosed by GSR within a year before the date of your request);
   2. To rectification/correction of your Personal Information, including notifying organisations to which your Personal Information was disclosed within a year prior to your request; and,
   3. Under the PDPA we have forty (40) days to respond to any subject access or rectification request. 
9. Under the PDPA you do not have a right:
   1. To data portability. Although there are a set of provisions in the PDPA relating to a right of data portability, they are currently not in force. When the right becomes law, GSR shall comply with that PDPA requirement, 
   2. To restrict processing, 
   3. To object to the processing of Personal Information

We reserve the right to choose, without an obligation, to nevertheless endeavour to service any such request under 1.8.1-1.8.3. Where we choose on a particular occasion to service any such request it shall not act to set any precedent whatsoever. 

1. GSR may, but is not obliged to, charge an individual a minimal fee in order to recover the costs of responding to a subject access request. Before doing so GSR shall provide you with a written estimate of the fee.
2. Whenever we transfer your Personal Information out of Singapore to a recipient in a country which does not have laws that provide the same level of data protection as under PDPA, we always ensure that the recipient provides a comparable degree of protection of your Personal Information, including to the extent appropriate, use of the model contract clauses adopted and approved by the Association of Southeast Asian Nations. We may also transfer your Personal Information with your consent, including deemed consent, in appropriate circumstances, and also transfer where necessary for the performance of a contract. 
3. If you have any questions about this Privacy Notice, about the use of your Personal Information or you want to exercise your privacy rights, please contact the Data Protection Officer and their team in the following ways:
   1. Email address: dpo@gsr.io 
   2. Postal address: FAO The Privacy Team (London), GSR Markets Pte. Ltd, 1 Wallich Street #17-02, Singapore 078881
4. You can complain at any time if you feel the processing of your Personal Information infringes the Singaporean Personal Data Protection Act by contacting the Personal Data Protection Commission, the Singaporean regulator for data protection issues (www.pdpc.gov.sg ). We would appreciate the chance to deal with your concerns before you approach an appropriate authority and ask that you contact us in the first instance.

[return to Privacy Notice index]

 

Annex 4 – Spain

Terms applicable in Spain 

In addition to the terms of the Privacy Notice if you are in Spain, the following additional terms apply:

1. To the extent Spanish privacy and data protection law over and above GDPR applies directly to GSR, GSR will comply with Spanish law in all material respects. 
2. Your subject access rights are not unqualified under Spanish law.  Because GSR is a financial entity that is subject to anti-money laundering regulations, GSR has an obligation to both block data (i.e., not comply with a request for rectification or erasure) and adopt technical and organisational measures to prevent the processing of blocked data (unless otherwise directed by a competent authority with jurisdiction).  This obligation to block only applies once any retention period applicable to the Personal Information has expired, and such block must remain in place for no less than a further three (3) years. 
3. We may transfer your Personal Information outside of Spain. When transferring your Personal Information outside of Spain, we will, where required by applicable law, implement at least one of the safeguards set out below which give your Personal Information the same protection it has in Spain. 

Adequacy decisions	We may transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission.
Standard Contractual Safeguards	Where we use certain service providers, we may use specific contractual clauses approved by the European Commission (the EU standard contractual clauses).

1. Please contact us if you would like further information on the specific mechanisms used by us when transferring your Personal Information outside of Spain. 
2. If you have any questions about this Privacy Notice, about the use of your Personal Information or you want to exercise your privacy rights, please contact the Data Protection Officer and their team in the following ways:
   1. Email address: dpo@gsr.io 
   2. Postal address: FAO The Privacy Team (London), Edificio Eurocomsur, Oficina 6, C / Mauricio Moro Pareto, 2. Malaga 29006 
3. You can complain at any time if you feel the processing of your Personal Information infringes GDPR and/or the local implementing Spanish law (‘LOPDGDD’ – Ley Orgánica 3/2018, de 5 de diciembre, de Protección de Datos Personales y garantía de los derechos digitales) by contacting the Agencia Española de Protección de Datos, the Spanish regulator for data protection issues (www.aepd.es), which is also GSR’s lead supervisory authority within the EU.  We would appreciate the chance to deal with your concerns before you approach an appropriate authority and ask that you contact us in the first instance.

[return to Privacy Notice index]

 

Annex 5 – Switzerland

Terms applicable in Switzerland

In addition to the terms of the Privacy Notice if you are in Switzerland, the following additional terms apply:

1. To the extent that the Federal Act on Data Protection of 25 September 2020 and its ordinances, (i.e., the Ordinance on Data Protection and the Ordinance on Data Protection Certification 2023) (“FADP”), applies to GSR and its business activities, GSR will comply with the FADP in all material respects. 
2. Under there is no requirement for GSR to disclose the legal basis for the processing of your Personal Information to you.  The legal bases provided in Section 6 of the Privacy notice, are provided to you for informational purposes only.
3. GSR may process your Personal Information where it:
   1. Only uses Personal Information for purposes that a reasonable person would recognise as appropriate and reasonable in the circumstances, and otherwise respects any objections you have;
   2. Is in good faith and proportionate;
   3. Does not violate your legal rights; and/or,
   4. Processes your Personal Information:
      1. With your consent;
      2. Where there is either an overriding private or public interest; and/or,
      3. Where required or permitted and in compliance with Swiss law.
4. In responding to an access request by you, there are a limited set of circumstances where GSR is not obliged to provide data, including: 
   1. Where you already have the information;
   2. Where the processing is required under Swiss law; 
   3. Where there is an overriding third party interest and no data is shared with third party controllers (except for GSR Group companies), and/or,
   4. Where providing the information defeats the purpose of the processing.
5. Where an automated decision has been taken, that has a legal consequence or otherwise materially and negatively impacts you, you can request that a person review the decision. However, no information on automated decision-making about you has to be provided by GSR to you where the decision: 
   1. is taken with your explicit consent; and/or,
   2. occurs directly in connection with the conclusion or performance of an agreement with you, where the outcome of the automated decision-making process is in your favour or approving something you have requested.
6. In addition to your rights as provided for in the main part of the Privacy Notice, where you have requested your Personal Information be corrected or rectified, you also have the right for the relevant Personal Information to be marked as disputed.
7. Under the FADP we have thirty (30) days to respond to any legal rights request.
8. GSR may, where not prohibited under the FADP, charge a fee of up to CHF 300 if the fulfilment of the request would involve a disproportionate effort. GSR will notify you of the amount of contribution required (if applicable) before fulfilling the request and you will have ten (10) days to accept our offer.
9. Whenever we transfer your Personal Information out of Switzerland to a recipient in a country which does not have laws that provide the same level of data protection as under FDPA, we always ensure that the recipient complies with the requirements of the FDPA where applicable to ensure that a similar or comparable degree of protection is afforded to your Personal Information.
10. If you have any questions about this Privacy Notice or about the use of your Personal Information, or you want to exercise your privacy rights, please contact us in the following ways:
    1. Email address: dpo@gsr.io 
    2. Postal address: FAO The Privacy Team (London), GSR Markets Switzerland GmbH, Office 26, Grafenauweg 8, 6300 Zug, Switzerland.
11. You can complain at any time if you feel the processing of your Personal Information infringes the Swiss Federal Act on Data Protection by contacting the Federal Data Protection and Information Commissioner, the Swiss regulator for data protection issues (www.edoeb.admin.ch). We would appreciate the chance to deal with your concerns before you approach an appropriate authority and ask that you contact us in the first instance.

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Annex 6 – United States of America

Terms applicable in United States of America

1. For the purposes of this Annex 6, the following amended definitions shall apply:
   1. “business” shall be used interchangeably with and instead of the term ‘controller’, and any reference to ‘business’ in this Annex shall also include reference to a ‘controller’; 
   2. a “service provider” (which under the California Consumer Privacy Act 2018 (“CCPA”) shall include references to a ‘contractor’) is defined as an entity that processes Personally Information at the direction of a ‘business’, and any reference to ‘processor’ in this Privacy Notice shall also include reference to a service provider (and under the CCPA, a contractor).
2. In the United States of America (“US”):
   1. Most state laws generally allow processing of Personal Information by default, without a requirement to state the legal basis for processing Personal Information, so the legal bases outlined in this Privacy Notice are provided for information purposes only; and,
   2. We do not need your consent to de-identify your Personal Information for our further use.
3. We will not share your non-public information with any third party, otherwise than:
   1. To comply with any rule, regulation, law, or otherwise any direction of a competent authority with jurisdiction;
   2. To perform a contract between us or to enter into a contract between us;
   3. Where within our legitimate interests (having regards to your rights and freedoms); or, 
   4. With your consent. 
4. Under CCPA we limit our collection, use, retention, and sharing of personal information to what is reasonably necessary and proportionate to achieve the purposes for which the personal information was collected or processed, or for another disclosed purpose that is compatible with the context in which the personal information was collected, and not further processed in a manner that is incompatible with those purposes. In the past 12 months we have collected the categories of Personal Information as outlined in paragraph 1.3 above for our business purposes, as defined by Cal. Civ. Code 1798.140(e).  
5. We do not:
   1. Use automation software or tools to: 
      1. Screen or assess applicants or employees for “honesty”, “integrity”, or similar characteristics; or,
      2. Decide whether or not to provide Services to you;
   2. Use artificial intelligence in our engagement of or with you;
   3. Sell, rent out, release, disclose, disseminate, make available, transfer, or otherwise communicate your Personal Information to another business or a third party for monetary or other valuable consideration. We only share your Personal Information with our GSR Group, and third parties as provided for in Disclosures of your personal information (). 
6. Depending on which US state you reside in, you may have various qualified rights relating to Personal Information that GSR collects and processes about you (see Your Legal Rights in (paragraph 11).  In addition, you have the right to:
   1. To opt out of commercial electronic mail messages (e.g., such as direct marketing emails and text messages). For the avoidance of doubt, we currently do not send you marketing emails where you have not consented to receive them.  We will not text or call your mobile number to market to you. We do not use fax. We do not engage in targeted advertising; 
   2. Direct GSR to stop selling or sharing your Personal Information. For the avoidance of doubt, we do not sell, rent out, release, disclose, disseminate, make available, transfer, or otherwise communicate your Personal Information to another business or a third party for monetary or other valuable consideration. We only share your Personal Information with our GSR Group and third parties to the extent where necessary to provide the Services, Website, Newsletter and deal with your enquiries, complaints and/or requests in the way that we do Disclosures of your personal information ( 7).  
7. If you are in California, then you may have the right: 

1. To direct GSR to stop sharing your Personal Information. Please also read about what happens where you fail to provide personal information (paragraph 6.1)
2. To limit our use and disclosure of your Sensitive Personal Information.  Please also read about what happens where you fail to provide personal information (paragraph 6.1), and,  
3. To avoid discrimination upon exercising the rights granted by the California Privacy Rights Act 2020.

1. For the purposes of this Annex 6 and interpretating ‘Technical Data’, the general location data that we collect is greater than 1,850 feet (unless we have your consent to collect and use more accurate location data about you).  
2. If you exercise your privacy rights (“Privacy Rights Request”): 

1. We will endeavour to respond to a request from you within the timeframes required by the law of the relevant US state. 
2. If we need more time or an extension, we will inform you in writing of the reason and extended time period.  Where a US state law prescribes a maximum response time period, any extra time or extended period we require, will comply with any relevant US state’s prescribed maximum response time period. 
3. Via:
   1. Email or other electronic means, we will deliver our written response to a verified email address associated with the request; or,
   2. Telephone, you will need to provide us with either your preferred (and verifiable) physical or email address, which we will then use to provide a written response to you. 

1. GSR may, but is not obligated to, charge an individual a fee in order to recover the costs of responding to a Privacy Rights Request. If we determine that the request warrants a fee (for example where it is excessive, repetitive, or manifestly unfounded), we will tell you why we made that decision and provide you with a cost estimate before completing your request. 
2. Depending on which US state you reside in (for example only, Connecticut), you may have the right to appeal where we decline your Privacy Rights Request. You must appeal within a reasonable time after your receipt of our decision. Following receipt of your appeal, then within any time period prescribed under the relevant states law, GSR will write to you clarifying what action it has taken or not taken, and an explanation of the reasons for the decision. If an appeal is denied, where required by state law, you can contact the relevant state attorney general to complain if you wish to.
3. As stated, we do not solicit or knowingly collect Personal Information from any person under 18 years of age. This includes anyone under the age of 13. If you are under 18 do not attempt to register for the services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 18, we will delete that information as quickly as possible. If you believe a child under 18 may have provided us their Personal Information, please contact the Data Protection Officer and their team via email dpo@gsr.io
4. Your Personal Information may be transferred to any other GSR Group company or any third party we engage to enable us to provide the Services. Please see Section 7: Disclosures of your Personal Information. Your Personal Information may be transferred to any other company in the Group, including to the UK and EU, and may be processed for purposes connected with your interaction with GSR. If GSR were to transfer your Personal Information to a recipient in a country whose laws provide a lower level of protection (both from a privacy and security perspective) as compared to the relevant US state(s) law(s), we require such recipient to comply with a standard no less than as is provided by the applicable US state(s) law(s).
5. We will comply with all federal and state laws relating breach notification requirements including but not limited to the requirement to notify, the contents of any notification, the parties to be notified and any required remedial steps. 
6. Some Privacy regulations in US states (for example only, California and Delaware), require GSR to indicate whether it honours your browser’s “Do Not Track” settings. GSR adheres to the standards set out in this Privacy Notice and does not respond to Do Not Track browser requests. To find out more about “Do Not Track,” please visit www.allaboutdnt.com. Our Third-Party Suppliers, such as web analytics companies and third-party networks may collect information about you and your online activities over time and across our Website. These third parties may not change their tracking practices in response to do not track settings in your web browser and we do not obligate these parties to honour do not track settings.  We utilise Google Analytics for our web analytics, and you can opt out of your usage data being included in our Google Analytics reports by visiting https://tools.google.com/dlpage/gaoptout. As stated, GSR does not engage in targeted advertising.  For more information on any third parties that process any Personal Information about you on our Website.
7. If we update this Privacy Notice, except to the extent that the processing is for a lawful reason, we will give you notice of the changes and the opportunity to opt out. 
8. If you have a question about this Privacy Notice, about the use of your Personal Information or want to exercise your privacy rights, please contact the Data Protection Officer and their team by:
   1. Email to: dpo@gsr.io 
   2. Post to: FAO The Privacy Team (London), GSR Markets, 347 5th Avenue, Suite 1402-700, New York, NY 10016
   3. Toll free telephone by calling: 888-560-8266.
9. We would appreciate the chance to deal with your concerns before you approach an appropriate authority and ask that you contact us in the first instance. 
10. If you want to make a complaint or if you feel your rights have been infringed, you can contact: 
    1. The relevant attorney generals of the states who have authority to enforce their state’s privacy laws (if any). In particular:
       1. Wyoming, Wyoming’s Attorney General can be contacted via https://ag.wyo.gov/. Wyoming does not currently have a law in place that specifically regulates data protection and consumer privacy. However, the Consumer Protection Unit of Wyoming’s Attorney General has the authority to examine, among other things, consumer privacy invasions.
       2. The California Attorney General (www.oag.ca.gov) and the California Privacy Protection Agency (www.cppa.ca.gov) share authority to enforce the CCPA.
    2. Otherwise for the following states the relevant State Attorneys (or district attorneys where empowered in some states to enforce the law, e.g., Colorado) for each of Colorado, Connecticut, Delaware (from 1 January 2025), Florida, Indiana (from 1 July 2026), Iowa (from 1 January 2025), Kentucky (from 1 January 2026), Maryland (from 1 October 2025), Minnesota (from 31 July 2025), Montana, Nebraska (from 1 January 2025), Nevada, New Hampshire (1 January 2025), New Jersey, Oregon, Rhode Island (from 1 January 2026), Tennessee (from 1 July 2025), Texas, Utah and Virginia have authority to enforce their state’s privacy laws. 
    3. the United States Federal Trade Commission (www.ftc.gov) in certain circumstances. 

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Annex 7 – Suppliers and Vendors by jurisdiction

The following suppliers and vendors are engaged:

Who	Why
Anchorage	Custody solution for digital assets.
AODocs	Cloud document management system
Atlassian (Confluence)	Workforce collaboration and knowledge sharing tool
Atlassian (Jira)	Workforce collaboration and workflow tool
AWS (Cloud services, security and data storage)	Networking and security, storage service, compute service,
ClickHouse	Database management system
Coinbase Prime	Brokerage platform
Complyadvantage	SaaS-based risk intelligence platform
Copper Technologies	Custodian for digital assets.
Data Platform	Data warehouse, analytics and business intelligence.
Elliptic	Blockchain analysis tool used for anti-money laundering (AML) by compliance, including wallet screening and transaction monitoring.
Fireblocks	Custodian for digital assets.
Google	Data analysis reporting, Workspace, security features, MI
Influx DB Cloud	Time Series database
Metamask	Digital asset wallet.
Okta	Manages login authentication.
Overwatch (algorithmic order logging & execution)	The User Interface of GSR’s internally developed trading toolkit and the internally developed trading toolkit for PnL and Risk tracking.
Phantom	Digital asset wallet.
Prevalent	Third party vendor risk management provider
Salesforce (Service Desk & Service Management)	CRM tool for Sales, Customer Service, Marketing, Commerce & IT
Slack	Messaging platform
Softledger	Cloud accounting software
Solidus	GSR’s KYC portal for client documentation submission and onboarding workflow management; also used for transaction monitoring and market surveillance.
Trading Connectivity	Order gateways and market data feeds
Trading Engines	Engines required to facilitate trading activities
TRM Labs, Inc.	Digital risk management & compliance platform
Trust Wallet	Digital asset wallet.