Privacy Policy

Welcome to the CTK Limited’s privacy policy. Please note that this Privacy Policy only relates to your use of our website, www.loansctk.gi (“Website”), and not to the use of any other website (for more information, please refer to the “Third-party links” section below).

Please read this Privacy Policy carefully, as it contains important information on who we are, how and why we collect, store, use and share personal information about you, your privacy rights, information on how to contact us and the supervisory authorities in the event you have a complaint and how the law protects you.

It is important that you read this privacy policy together with any other policy which may direct you to from time to time, as this privacy policy supplements other notices and privacy policies and is not intended to override them.

About us and our Privacy Policy

Purpose of this Policy

This Privacy Policy aims to give you information on how CTK Limited collects and processes your personal data, including any data you may provide to us when accessing the Website (as defined below) and using any of the services which we offer through the Website (“Services”). The Website is not intended for any person under 18 years of age (“Minors”), and we do not knowingly collect data relating to Minors. It is important that you read this Privacy Policy together with any other policy which may direct you to from time to time, as this Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Controller

We are CTK Limited, a company incorporated and registered in Gibraltar with company number 702138 whose registered office is at 293A Main street Gibraltar GX111AA. We are a small money lending business providing loan services. You may find more information about us at https://www.ctkloans.gi/about-us/. We operate the Website, trading under the name CTK Loans (referred to as, “we”, “us” or “our”).

We respect your privacy and are committed to protecting your personal data. We collect, use and are responsible for certain personal information about you. When we do so, we are regulated under the Gibraltar General Data Protection Regulation and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Our DPO

We have appointed a data protection officer (DPO)who is responsible for overseeing questions in relation to this Privacy Policy.

If you have any questions about this Privacy Policy, or our privacy practices, including any requests to exercise your legal rights, please contact our DPO by post, email or telephone.

Full name of legal entity: CTK Limited
Postal address: 293a Main street Gibraltar GX111AA
Email address of the DPO: loansctk@gibtelecom.net
Telephone number: +350 200 72050

You have the right to make a complaint at any time to the Gibraltar Regulatory Authority (“GRA”), the Gibraltar supervisory authority for data protection issues (https://www.gra.gi/data-protection). We would, however, appreciate the chance to deal with your concerns before you approach the GRA so please contact us in the first instance.

Changes to Privacy Policy

We keep our Privacy Policy under regular review, and you may find the date this Privacy Policy was last revised at the beginning of this document.

Third-party links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites (including any plug-ins, web applications and mobile applications) and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every website you visit.

The personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes your name, date of birth, gender, job title and company details.
Contact Data includes your billing and delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

No collection of personal data

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Your duty to update your data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by contacting us.

If you fail to provide personal data

Where we need to collect personal data by law, or to fulfil our regulatory obligations, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Directly from you

We may collect personal data directly from you when you:

register with you give us;
apply for a loan;
correspond with us by post, phone, email or otherwise;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; and/or

give us feedback.

Indirectly from and/or about you

We may also collect personal data indirectly by our use of:

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy loansctk.gi/cookie-policy/ for further details. If you are on one of our marketing list, we will be able to identify you when you use our website.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including but not limited to social media, search engines, Gibraltar Companies House, and screening data vendors.

Purposes and legal bases for which we use your personal data

When we use your personal information, we are required to have a legal basis for doing so. We will therefore only use your personal data when the law allows us to.

There are different legal bases upon which we may rely, and these will depend on the personal information in question and the specific context in which we collect it.

Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract (in this case, our Terms of Use) we are about to enter into or have entered into with you.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. In order to access our Website and Services you will first have to enter into a contract with us governing our relationship. The contract in question is the Terms of Use and is available at [insert hyperlink].

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best Services and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Where we need to comply with a legal obligation.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to (for instance, AML/CFT obligations under The Proceed of Crime Act 2015).

Please note that, generally, we do not rely on consent as a legal basis for processing your personal data However, please note that when we are processing on the basis of your consent, you have the right to withdraw that consent at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal ground which we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include, but shall not be limited to:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

Your consent.

To respond to any questions or queries you submit

(a) Identity

(b) Contact

Your consent

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. Please note that you have the right to opt-out of marketing communications at any time, and that you may do so through this Website [please insert hyperlink directing users to the opt-out option] or by contacting us.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.]

Cookies

You can set your browser (and some mobile devices) to refuse all or some browser cookies (including server logs and other similar technologies) or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We will share personal data with law enforcement or other authorities if required by applicable law.

We do plan to share your personal information with any other third party, and please rest assured that we would seek your express opt-in consent (and that we will provide you with all the relevant information) before we share your personal data with any third party.

International transfers

We may transfer your personal information obtained from this website outside of the Gibraltar for security purposes.

Whenever we transfer your personal data out of Gibraltar, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by Her Majesty Government of Government (or by the body of competence, as this may be from time to time). For further details, see the.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, and updates, please see https://www.gra.gi/data-protection/general-data-protection-regulation.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Gibraltar.

Data security

We have appropriate security measures in place to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are set out in the table above.

In some circumstances you can ask us to delete your data – please see the section below titled “Your legal rights” for further information about this.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under the General Data Protection Regulation, you have the right to:

Under certain circumstances, you may enjoy certain rights under data protection laws in relation to your personal data; these rights are as follows:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We will advise you if this is the case at the time you withdraw your consent.

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the guidance from the Gibraltar Regulatory Authority https://www.gra.gi/news/rights-of-individuals-under-GDPR

If you wish to exercise any of the rights set out above please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.