Privacy Policy

Effective Date: December 12, 2025

Entity: GGT Prime FZCO (“GGT Prime,” “Company,” “we,” “us,” or “our”)

1. Executive Summary & Regulatory Framework

GGT Prime is committed to maintaining the confidentiality, integrity, and security of personal and corporate data entrusted to us by our commercial counterparties, clients, and platform visitors. This Privacy Policy outlines our data governance standards and details how we collect, process, store, and protect information across our trade execution systems, online interfaces, and institutional communications.

Given the nature of international precious metals trading, GGT Prime operates in strict compliance with applicable data protection laws alongside governing statutory obligations related to Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Know Your Customer (KYC) compliance.

2. Information We Collect

To facilitate corporate transactions, execute precious metal contracts, and maintain regulatory compliance, we collect and process the following categories of data:

A. Customer Due Diligence (CDD) & Identity Data

  • Individual Information: Full legal name, nationality, date of birth, residential address, government-issued identification numbers (e.g., passport, national ID), and tax identification numbers.

  • Corporate Representative Data: Proof of corporate authority, corporate capacity documentation, Ultimate Beneficial Ownership (UBO) declarations, and registry documentation for corporate officers, directors, and signers.

B. Financial & Transactional Data

  • Operational bank account details, international wire transfer instructions, IBAN/SWIFT data, proof of funds (PoF), origin of funds declarations, trade execution logs, transaction histories, and settlement records.

C. Technical & Platform Interaction Data

  • IP addresses, browser types, operating systems, geographic location metrics, device identifiers, referral URLs, access timestamps, and session logs gathered during interface engagement.

3. Legal Basis and Purpose of Data Processing

We process personal data only when authorized under applicable statutory grounds. Primary operational objectives include:

  • Legal & Regulatory Obligations: Satisfying mandatory compliance obligations, including goAML reporting, identity verification, sanction list screening, and statutory audits.

  • Contract Execution: Facilitating, drafting, and performing obligations under Soft Corporate Offers (SCO), Sales and Purchase Agreements (SPA), Escrow Agreements, and trade settlements.

  • Risk Management & Fraud Prevention: Assessing counterparty credit/reputational risk, preventing fraudulent activities, and ensuring physical/digital supply chain integrity.

  • Operational Communications: Managing ongoing transaction logistics, account inquiries, administrative notifications, and security protocols.

4. Disclosure and Transfer of Information

GGT Prime does not sell, rent, or trade personal data to commercial third parties. Information may be shared under the following controlled circumstances:

  • Regulatory & Law Enforcement Authorities: Where required under statutory mandates, court orders, or official regulatory reporting obligations (e.g., financial intelligence units, tax authorities, and law enforcement agencies).

  • Institutional Financial Partners: Correspondent banks, depository institutions, escrow agents, trade finance facilitators, and precious metals vault facilities strictly for contract execution and compliance verification.

  • Third-Party Service Providers: Vetted IT infrastructure providers, secure cloud hosts, legal counsel, and independent auditors under strict Non-Disclosure Agreements (NDAs) and Data Processing Contracts.

  • Corporate Restructuring: In connection with a corporate merger, acquisition, joint venture, or asset disposition, subject to standard confidentiality protections.

5. International Data Transfers

Operating within international trade corridors may require the transmission of data outside your local jurisdiction. Where cross-border data transfers occur, GGT Prime ensures appropriate safeguards—such as Standard Contractual Clauses (SCCs) and contractual data protection covenants—are implemented to protect your information to the standards specified in this policy.

6. Data Security Measures

GGT Prime employs multi-layered technical, administrative, and physical security protocols designed to prevent unauthorized access, alteration, disclosure, or destruction of sensitive information:

  • Encryption Protocols: End-to-end encryption for sensitive data in transit (TLS 1.3) and at rest (AES-256 standards).

  • Access Control: Role-based access controls (RBAC) and Multi-Factor Authentication (MFA) limiting personal data access strictly to authorized compliance and administrative personnel.

  • System Safeguards: Perimeter firewalls, intrusion detection systems, continuous threat monitoring, and periodic vulnerability audits.

Note: While robust safeguards are maintained, no electronic system or internet transmission is completely immune to security breaches. Counterparties engage electronically at their own risk, subject to standard system protocols.

7. Data Retention Standards

Personal and financial data is retained only for as long as necessary to fulfill the operational purposes for which it was collected, or to comply with statutory record-keeping periods.

Due to regulatory mandates governing precious metals trading, Anti-Money Laundering frameworks, and corporate tax regulations, transaction logs, identity verifications, and contractual records are typically retained for a minimum period of five (5) to seven (7) years following the termination of a commercial relationship or completion of a trade transaction.

8. Data Subject Rights

Depending on your legal jurisdiction, you may hold specific statutory rights regarding your personal data, including:

  • Right of Access: Requesting confirmation of data processing and access to your personal information.

  • Right to Rectification: Requesting the correction of inaccurate or incomplete records.

  • Right to Erasure / Restriction: Requesting the deletion or limited processing of your data, provided such request does not conflict with mandatory statutory retention or compliance requirements.

  • Right to Object: Objecting to automated processing or direct communication activities.

To exercise any applicable statutory rights, formal requests must be submitted in writing to our Compliance Officer (see Section 11).

9. Cookies and Tracking Technologies

Our platform utilizes functional and analytical cookies to maintain session security, analyze network traffic, and optimize interface responsiveness. Users may modify browser settings to block or restrict cookies; however, limiting session cookies may affect platform function or restricted-portal access.

10. Amendments to This Policy

GGT Prime reserves the right to revise or update this Privacy Policy periodically to reflect structural changes in operational practices, corporate developments, or regulatory requirements. Material revisions will be posted directly to our web portal with an updated “Effective Date.”

11. Contact & Compliance Inquiries

For questions regarding this Privacy Policy, compliance inquiries, or to exercise data protection rights, please contact our compliance department:

GGT Prime Compliance Office

Email: info@ggtprime.ae

Official Web: https://ggtprime.ae