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Privacy Policy

Electron Holdings Management Limited

Last updated: 01 July 2025

1. Introduction

 

Electron Holdings Management Limited (“Electron”, “we”, “our”, “us”) is committed to protecting the privacy of individuals whose personal data we process. This Privacy Policy explains how we collect, use, store, and protect personal data in accordance with:

  • The EU General Data Protection Regulation (EU GDPR)

  • The UK General Data Protection Regulation (UK GDPR)

  • The Data Protection Act 2018 (UK)

  • The Seychelles Data Protection Act (where applicable)

 

Electron is incorporated in the Republic of Seychelles and operates from Cyprus. Although we are not established in the United Kingdom, we process personal data relating to individuals in the UK and therefore comply with UK GDPR. We also process personal data from individuals located in other international jurisdictions where we conduct business.

2. Who We Are

 

Company name: Electron Holdings Management Limited

Registered Office: 102, Aarti Chambers, Mont Fleuri, Victoria, Mahé, Seychelles

Operating Address: Themidos 8, Apsis Building, Fourth Floor, Office 401, 6057 Larnaca, Cyprus

Email for all data protection enquiries: compliance@electronholdings.com

3. Personal Data We Collect

 

We collect personal data necessary for our business activities, including:

  • Identification documents (passports, national ID cards)

  • Proof of address

  • Contact details (name, email, phone, address)

  • Financial information for due diligence and KYC

  • Information supplied by brokers, introducers, and borrowers

  • Information needed to comply with anti-money laundering, sanctions, and Know Your Customer (KYC) requirements

  • Communication records and correspondence

  • Information relating to loan applications, compliance checks, or transactions

 

We process personal data relating to individuals located in:

  • The United Kingdom

  • The European Union

  • Cyprus and the Seychelles

  • The Middle East

  • Africa

  • North America

  • Asia

  • Other international markets where Electron conducts due diligence or assesses opportunities

 

We do not collect unnecessary or excessive information.

4. How We Collect Personal Data

 

We collect data from:

  • Direct interactions (emails, calls, forms)

  • Introducers, brokers, intermediaries

  • Public sources (Companies House, Land Registry, corporate registries)

  • Professional advisers

  • Compliance and risk-intelligence partners

  • Documentation submitted for lending or investment assessments

5. Legal Basis for Processing

 

We rely on the following lawful bases:

  • Contractual necessity

  • Legal obligation

  • Legitimate interests

  • Consent (only where explicitly required)

6. How We Use Personal Data

 

We use personal data for legitimate business purposes including:

  • Assessing lending, financing, or investment opportunities

  • Conducting due diligence, KYC, and AML checks

  • Verifying identities

  • Communicating with clients, brokers, advisors, and partners

  • Fulfilling legal and regulatory obligations

  • Protecting our legal and commercial interests

 

We do not sell or commercially trade personal data.

7. Sharing Personal Data

 

We may share personal data with:

  • Professional advisers (lawyers, accountants, consultants)

  • Banks, custodians, regulated financial institutions

  • Compliance and due diligence service providers

  • Brokers, intermediaries, or partners involved in a transaction

  • Regulatory or law enforcement authorities if required

 

All sharing is controlled and compliant with GDPR.

8. International Transfers

 

As a Seychelles-registered company operating internationally, personal data may be transferred outside the European Economic Area (EEA) or the United Kingdom.

 

When this occurs, we ensure adequate safeguards, including:

  • Standard Contractual Clauses (SCCs)

  • Adequacy mechanisms

  • Contractual protections

  • Secure encrypted transfer processes

9. Data Security

 

We apply robust technical and organisational measures to ensure the security of personal data, including encryption, restricted access, secure communication systems, and regular internal compliance checks.

10. Data Retention

 

We retain personal data only for as long as necessary to:

  • Meet legal and regulatory obligations

  • Support or defend legal claims

  • Manage transactional and compliance requirements

 

KYC and AML documentation is typically retained for 5–7 years, depending on jurisdiction.

11. Individual Rights

 

Depending on your location, you may have rights under EU or UK GDPR, including:

  • Right of access

  • Right to rectification

  • Right to erasure

  • Right to restrict processing

  • Right to data portability

  • Right to object

  • Right to withdraw consent (where applicable)

  • Right to lodge a complaint with the relevant supervisory authority

 

Requests can be made to compliance@electronholdings.com.

12. No Requirement to Register with the ICO

 

As Electron is not established in the United Kingdom, we are not required to register with the ICO or pay the UK Data Protection Fee.

 

The ICO does not issue a “Data Protection Certificate.”

Electron complies fully with EU GDPR and UK GDPR without such a certificate.

A Data Protection Compliance Statement is available on request.

13. Contact Information

 

For any questions regarding this Privacy Policy or your personal data, please contact:

 

Email: compliance@electronholdings.com

Operating Address: Themidos 8, Apsis Building, Fourth Floor, Office 401, 6057 Larnaca, Cyprus

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