Privacy Policy

Effective Date: June 2025

Green Capital Private Advisers Ltd and its affiliated entities (“GCPA,” “we,” “our,” or “us”) are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, store, disclose, and protect your personal data when you use our client platform, https://private-trust.gcpagroup.com (the “Platform”), or interact with us in connection with our fiduciary, trust, investment, or banking services.

1. Who We Are

·       GCPA is a global fiduciary, trust, and investment advisory group that provides private financial services to clients, families, and institutions. The Platform is a secure environment for onboarding, account management, communications, and documentation exchange.

2. Information We Collect

·       a. Personal Identifiers: Full name, date of birth, government-issued ID/passport, address, phone number, email address, citizenship and residency status.

·       b. Account and Financial Information: Trust or account numbers, investment preferences, bank details, source of funds documentation, tax identification numbers and FATCA/CRS classifications.

·       c. Authentication and Compliance Data: IP address, device identifiers, access logs, uploaded KYC/AML documents, regulatory disclosures, risk profiles.

3. How We Use Your Information

·       To verify identity during onboarding and periodic reviews (KYC/AML);

·       To establish and manage fiduciary or investment accounts;

·       To maintain compliance with applicable financial laws and regulations;

·       To communicate with you regarding services, reporting, or required documentation;

·       To improve platform security and audit user activity;

·       To comply with tax reporting, sanctions screening, and cross-border disclosures.

4. Lawful Basis for Processing

·       Contractual necessity: for the performance of agreements;

·       Legal obligation: to meet financial, tax, or regulatory requirements;

·       Legitimate interest: in providing secure and compliant services;

·       Consent: where explicitly requested for optional features or marketing.

5. Data Sharing and Transfers

·       We may share your data with affiliates, partners, and regulated service providers within the GCPA Group;

·       Banks, custodians, or investment firms involved in account servicing;

·       Regulatory bodies (e.g., tax authorities, financial intelligence units);

·       IT providers assisting with platform hosting, cybersecurity, and document storage.

6. Data Security

·       Encrypted transmission (SSL/TLS);

·       Secure document storage and role-based access controls;

·       Periodic compliance audits and system penetration testing.

7. Data Retention

·       We retain your personal data for as long as necessary to:

·       Comply with legal obligations (e.g., 5–10 years for financial records);

·       Maintain your trust, fiduciary, or banking relationship;

·       Support legal claims or enforce our agreements.

8. Your Rights

·       Access or correct your personal data;

·       Request deletion or restrict processing;

·       Object to processing or withdraw consent (where applicable);

·       File a complaint with a supervisory authority.

·       To exercise any rights, please contact us at privacy@gcpagroup.com.

9. Cookies and Tracking

·       The Platform uses only essential cookies necessary for authentication and security. We do not use cookies for advertising or behavioral tracking.

10. Third-Party Links

·       The Platform may link to third-party services or systems (e.g., custodians or banking portals). We are not responsible for the privacy practices of those third parties.

11. Changes to This Policy

·       We may update this Privacy Policy from time to time. All changes will be posted on the Platform with a revised 'Last Updated' date. Continued use after such updates constitutes acceptance.