Privacy Policy

GD Group Investments S.A. (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and disclose your personal data when you visit our website [www.gdgroupinvestments.com] (the “Website”) and when you use our contact form.

1. Who We Are

The data controller is GD Group Investments S.A., a company incorporated under Luxembourg law, having its registered office at 18, rue de l’Eau, L-1449 Luxembourg, R.C.S. Luxembourg B 70204.
To comunicate electronically: please use our form on the contact/homepage

2. Information We Collect

We may collect and process the following categories of personal data:

Identification and contact details: your name, company name, email address, and telephone number, as provided voluntarily through the contact form.
Technical and browsing data: IP address, browser type, operating system, date and time of access, and pages visited.
Cookies and log data necessary for the technical operation and security of the Website. Only essential cookies are used by default.

We do not intentionally collect special categories of personal data (such as data revealing racial or ethnic origin, political opinions, religious beliefs, or health data).

3. How We Collect Your Information

We collect your personal data directly from you when you voluntarily submit it through our contact form or communicate with us by email.

Technical data may be collected automatically when you access the Website (via cookies, log files, or analytics tools, if used).

4. Purposes and Legal Basis for Processing

Technical management and security of the Website – Legitimate interest (Art. 6.1.f GDPR);
Responding to your inquiries and requests via the contact form – Pre-contractual measures (Art. 6.1.b GDPR);
Compliance with legal obligations (e.g. recordkeeping, lawful requests) – Legal obligation (Art. 6.1.c GDPR);
Direct marketing – Sending updates, or information about our services, projects, or events – Consent (Art. 6.1.a GDPR);

You can withdraw your consent for marketing at any time by clicking the unsubscribe link in our communications or by contacting us via our contact on our homepage.

We do not carry out automated decision-making or profiling.

5. How We Share Your Information

We will not share your personal data with any third parties except as described in this Privacy Policy.

We may disclose your personal data to the following categories of recipients:

Service providers (e.g. hosting, IT support, or email delivery or other services necessary to operate our business), under written agreements ensuring confidentiality and data protection;
Other companies of the GD Group, for administrative purposes consistent with this Privacy Policy;
Public authorities or regulators, if legally required.

All such parties act as Data Processors under our instructions or as Independent Controllers where applicable.

6. International Transfers

Your personal data are primarily processed within the European Union (EU) and the European Economic Area (EEA).

If transfers outside the EEA occur (for example, to cloud providers or other group entities), they will be made under the safeguards provided by Articles 45-49 GDPR, such as EU Commission adequacy decisions or Standard Contractual Clauses or your explicit consent.

7. Data Retention

We retain your data only for as long as necessary to fulfil the purposes for which it was collected:

Browsing data: up to 6 months.
Contact form data: up to 12 months after the conclusion of our communication.
Marketing data: until consent withdrawal and, in any case, no longer than 24 months.
Longer retention may apply if required by law or for the establishment or defence of legal claims.

8. Data Security

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

9. Your Rights

Under Articles 15-22 GDPR, you have the following rights:

Access: obtain confirmation of whether we process your personal data and receive a copy;
Rectification: request correction of inaccurate or incomplete data;
Erasure (“right to be forgotten”);
Restriction of processing;
Objection: object to processing, including direct marketing;
Data portability;
Withdraw consent at any time (where applicable);- Lodge a complaint with the supervisory authority: CNPD – Commission Nationale pour la Protection des Données (www.cnpd.lu).

Requests can be sent via out contact form on our homepage.

We will respond within one month, as required by law.

10. Updates to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our Website, indicating the date of the most recent revision. Your continued use of our Website constitutes acceptance of any updates.

Last updated: [14/October/2025]

11. Contact Us

If you have any questions or concerns about this Privacy Policy or your personal data, please contact us at:

GD Group Investments S.A.18, rue de l’Eau, L-1449 Luxembourg R.C.S. Luxembourg B 70204

or contact us via our contact form on our homepage.