Privacy Policy

1. Introduction

GoldBrick Capital ("GoldBrick", "we", "our", "us") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose and safeguard your information when you visit our website and engage with us about our securitisation vehicle and SPV structures. GoldBrick Capital Management S.à r.l., with its registered office in Luxembourg, acts as the data controller.

2. Information We Collect

We may collect information about you in a number of ways:

• Personal data: name, email address, telephone number, country of residence, investor classification and any other details you provide when you complete a contact form, request the Information Memorandum, or arrange an introduction.
• Usage data: browser type, IP address, pages visited, time spent on the site, referring URLs and similar analytical data collected through cookies and comparable technologies.
• Communication data: records of correspondence when you contact us by WhatsApp, email or telephone, including information relevant to investor suitability and onboarding.

3. How We Use Your Information

• To respond to your enquiries and arrange confidential introductions
• To provide the Information Memorandum and other offering documents you request
• To assess investor eligibility and carry out KYC and anti-money-laundering checks
• To administer subscriptions, reporting and ongoing investor relations
• To send updates and relevant communications where you have consented
• To analyse use of the website and improve our content and services
• To comply with our legal and regulatory obligations under Luxembourg, EU and applicable law

4. Legal Basis for Processing (GDPR)

For visitors in the European Economic Area and the United Kingdom, we process your personal data on one or more of the following legal bases: your consent; steps taken at your request before entering into a contract; our legitimate interests in operating and promoting a securitisation vehicle to eligible investors; and compliance with our legal and regulatory obligations, including anti-money-laundering law. Where processing is based on consent, you may withdraw it at any time.

5. Data Sharing & Third Parties

We do not sell your personal data. We may share it with the service providers and counterparties that support the vehicle, including the depositary, administrator, auditor, legal counsel, banking partners and KYC/AML and technology providers. These parties are bound by confidentiality and data-protection obligations and may only process your data on our instructions.

6. International Data Transfers

Because GoldBrick operates between Luxembourg, Switzerland and Dubai (United Arab Emirates), your data may be transferred to and processed in jurisdictions outside the EEA, including Switzerland and the United Arab Emirates, where data-protection laws may differ from those in your country. Where we make such transfers we put appropriate safeguards in place, such as standard contractual clauses, in line with applicable data-protection law.

7. Data Retention

We retain your personal data only for as long as necessary for the purposes set out in this policy, and for the periods required to meet our legal, regulatory and anti-money-laundering record-keeping obligations. Where data is held on the basis of consent, it is retained until you withdraw consent or ask us to delete it.

8. Your Rights

Subject to applicable data-protection law, you have the right to:

• Access and obtain a copy of your personal data
• Rectify inaccurate or incomplete data
• Request erasure of your personal data
• Restrict or object to the processing of your data
• Receive your data in a portable format
• Withdraw consent at any time and lodge a complaint with your supervisory authority

9. Cookies

We use cookies and similar technologies to operate the site and understand how it is used. For details of the cookies we set, please see our Cookie Policy.

10. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us at: