top of page
Privacy Policy
Anchor 1

We, G9CM LLC (“G9CM”, “we”, “us”, “our”), a company incorporated in the British Virgin Islands (BVI), are committed to protecting and respecting your privacy. This Privacy Policy, together with any other documents referred to in it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. For the purposes of this Privacy Policy: G9CM Ltd. is the data controller under applicable BVI law. For individuals located in the European Union/European Economic Area (E.U./E.E.A.) and the United Kingdom (U.K.), we process personal data in accordance with the EU and the UK General Data Protection Regulation (GDPR) where it applies. We are based in the British Virgin Islands, but we are active in, and may process data from, users and business contacts in the United States, United Kingdom, European Union, and other countries in the Middle East, Asia-Pacific or other regions.

​

I. INFORMATION – COLLECTION

I.1 In order to provide you with better service, we may collect and process the following data about you:

  • Information that you provide by filling in forms on our site g9cm.com or by using third-party software and services. This includes information provided at the time of registering to use our site, subscribing to our services, posting material, filling out forms, or requesting further services. We may also ask you for information at other times, for example, in connection with a promotion or when you report a problem with our site.

  • If you contact us, we may keep a record of that correspondence.

  • We may also ask you to complete surveys for research purposes, although you are not obliged to respond.

  • Details of transactions you carry out through our site (if any) and of the fulfilment of your orders.

  • Details of your visits to our site and the resources that you access (including, for example, traffic data, location data, weblogs, and other communication data).

I.2 We only retain personal data for as long as is necessary for the purposes for which it was collected, or as required by law. Data may be archived for as long as the purpose for which it was used still exists.

​

II. INFORMATION – USE

II.1 We may use your information in the British Virgin Islands and in other jurisdictions where we might operate (including the United States, United Kingdom, European Union, Middle East, Asia-Pacific, for purposes including but not limited to:

  • Ensuring that our website content is presented in the most effective manner for you and the device you are using, such as smartphones, laptops, or computers.

  • Providing you with newsletters, alerts, educational materials, or other information you requested or signed up for.

  • Performing our obligations under any contract between you and us or taking steps at your request prior to entering into such a contract.

  • Allowing you to participate in interactive features of our services.

  • Designing and conducting surveys and questionnaires for client profiling and segmentation, statistical analysis, and improving our products and services.

  • Complying with laws and regulations applicable to us in the British Virgin Islands and in other jurisdictions where we operate.

  • Handling legal proceedings, including collecting overdue amounts and seeking professional advice.

  • Researching, designing, and launching services or products, including seminars, events, and forums.

  • Promoting and marketing our services and products, subject to your right to opt out (see Section II.2 below).

  • Purposes directly related or incidental to the above.

Legal basis (for GDPR/EU and GDPR/UK users):
We process your data where we have a legal basis under GDPR, such as:

  • Your consent;

  • Performance of a contract with you, or to take steps at your request before entering into a contract;

  • Compliance with a legal obligation;

  • Legitimate interests (such as operating and improving our business, ensuring IT security, or preventing fraud), provided your interests and rights do not override ours.

II.2 Direct marketing
As we may use your data for direct marketing, we require your consent, which includes an indication of no objection for that reason, where this is required by law. In this regard:

  • Your name, contact details (address, contact number, email), products and services information, transaction patterns and behaviour, background and demographic data held by us may be used in direct marketing.

  • The following types of services, products, and subjects may be used in direct marketing: services and products related to our site or our affiliates (including marketing affiliate programmes); reward, loyalty or privileges programmes; promotional offers and related services; invitations to seminars, webinars, tele-seminars, conferences, live programmes or events, among others.

  • We may conduct direct marketing via telephone, email, direct mail, or any other means, and send electronic or physical newsletters.

Opt-Out: You may opt out of receiving promotional materials at any time by notifying us (see contact details below). If you do so, we will stop sending you marketing communications with or without charge, though we may still contact you for non-marketing purposes as required.

​

III. INFORMATION – DISCLOSURE

III.1 We treat your personal data as confidential but may disclose it to:

  • Personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services;

  • Our overseas offices (if any), affiliates, business partners, and counterparts;

  • Persons under a duty of confidentiality to us;

  • Persons to whom we are required to make disclosure under applicable laws and regulations in or outside the British Virgin Islands and other relevant jurisdictions;

  • Actual or proposed transferees, assignees, or participants in our services or business.

We only share your data with third parties where permitted by law and with appropriate confidentiality and data protection standards.

​

IV. COOKIES

IV.1 Our website uses cookies to distinguish you from other users. This helps us provide you with a better experience and allows us to improve our site. By continuing to browse the site, you agree to our use of cookies.

IV.2 A cookie is a small file of letters and numbers stored on your browser or device (if you agree). Cookies contain information transferred to your computer’s hard drive.

IV.3 We use the following types of cookies:

  • Strictly necessary cookies: Required for operation of our website (e.g., enabling login, shopping cart, or billing).

  • Analytical/performance cookies: Allow us to recognise and count visitors and see how they use our website (to improve site usability).

  • Functionality cookies: Used to recognise you when you return, personalise content, greet you by name, and remember your preferences.

  • Targeting cookies: Record your visit, pages visited, and links followed to make the website and advertising more relevant to your interests. This information may be shared with third parties for this purpose.

IV.4 Third parties (including advertising networks and analytics providers) may also use cookies over which we have no control. These are likely to be analytical/performance or targeting cookies.

IV.5 Our website uses Google Analytics, a web traffic analysis service provided by Google Inc. For more information, see: http://www.google.com/policies/privacy/partners

IV.6 You can block cookies by activating the browser setting that allows you to refuse all or some cookies. However, blocking all cookies (including essential ones) may affect your ability to use parts of our site.

IV.7 You can prevent Google’s collection and processing of data by using the Google Ads Settings page or by installing their browser plug-in: https://tools.google.com/dlpage/gaoptout

​

V. SECURITY

V.1 All information you provide is stored on secure servers provided by our service providers, such as Microsoft 365 and Wix.com.

Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services (if any in our case) to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall. All direct payment gateways offered by Wix.com and used by our company (if this is the case) adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. Where we have given you or where you have chosen a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential and therefore we ask you not to share a password with anyone. For more information about wix.com visit their website https://www.wix.com

V.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of data transmitted to our site; any transmission is at your own risk. Once received, we use appropriate procedures and security features to try to prevent unauthorised access.

​

VI. POLICY CHANGES

VI.1 We reserve the right to change this Privacy Policy at any time. Please review it regularly, as changes and clarifications will take immediate effect upon posting on the website.

​

VII. DATA TRANSFERS

VII.1 We may hold your data on servers in the United States, United Kingdom, European Union, or any other territory as necessary. We may also transfer your data to our overseas offices or persons listed in Section III.1, who may be located in or outside the regions where we are active.

VII.2 Where we transfer your personal data from the EU/EEA or UK to a country outside the EU/EEA or UK not deemed by the European Commission or the UK to provide an adequate level of protection, we will take appropriate safeguards as required by GDPR (such as Standard Contractual Clauses).

​

VIII. YOUR CONSENT AND RIGHTS

VIII.1 By using our services, making an application, contacting us, or visiting our website, you consent to the collection and use of your information as described in this Policy.

VIII.2 Under the laws of the British Virgin Islands and, where applicable, the EU GDPR, the UK/GDPR individuals have the right to:

  • Check whether we hold personal data about you and access such data;

  • Request correction of any inaccurate data;

  • Ascertain our policies and practices regarding personal data;

  • Object to the use of your data for marketing purposes (upon which we will cease such use);

  • Where GDPR applies: request deletion (the “right to be forgotten”), restrict processing, request data portability, and object to certain processing, including profiling and automated decisions;

  • Withdraw your consent at any time (without affecting the lawfulness of processing before withdrawal);

  • Lodge a complaint with a supervisory authority if you believe your data protection rights have been breached.

VIII.3 You can exercise these rights or make requests/objections by contacting us at: Email: eo@g9cm.com (No phone or fax is available for privacy requests.)

VIII.4 In accordance with applicable law, we may charge a reasonable fee for processing any data access request.

​

IX. GOVERNING LAW AND JURISDICTION

IX.1 This Privacy Policy Statement is governed by the laws of the British Virgin Islands, and you agree to submit to the exclusive jurisdiction of the courts of the British Virgin Islands. Nothing in this Policy limits the rights of data subjects under the EU GDPR, the UK GDPR or other applicable data protection laws.

​​

Effective Date: 01/01/2025.

​

bottom of page