Privacy Policy

Electron Holdings Management Limited, trading as Electron Family Office (“Electron”, “we”, “us”), is the controller responsible for the personal data we collect and use as described in this policy. Company No. 118138. We are incorporated in Seychelles and operate from Cyprus. We apply the data protection laws relevant to our processing, including the EU GDPR, UK GDPR and local laws where applicable.

Where a wholly owned subsidiary is involved in a financing transaction, we will identify that company and explain any separate responsibilities it has for personal information in the relevant privacy information.

Registered office

102, Aarti Chambers, Mont Fleuri, Victoria, Mahé, Seychelles.

Operating address

Themidos 8, Apsis Building, Fourth Floor, Office 401, 6057 Larnaca, Cyprus.

Data protection enquiries

compliance@electronfamilyoffice.com

An initial website enquiry asks for your name, email, asset category, financing amount and currency, and a brief summary. Nature of enquiry is optional. We then request information proportionate to the preliminary assessment. Detailed identity, financial and transaction documents are requested through the appropriate follow-up and due-diligence process.

Depending on the enquiry and transaction, information may include identity and address documents; residence or incorporation details; ownership, authority and beneficial ownership; financial circumstances, source of funds or wealth; correspondence; and information relevant to identity, anti-money laundering, sanctions and fraud checks.

Asset information is personal data where it identifies, or can be linked to, an individual. The information requested depends on the proposed collateral and stage of assessment.

Securities

Security name, ticker or exchange, holding size and value, ownership, restrictions or pledges, custodian details and relevant brokerage or custody statements.

Digital assets

Asset and network, units and value, ownership or control, custody arrangements, transfer restrictions, staking or DeFi use. Relevant follow-up may include public wallet addresses, blockchain transactions and screening results.

Real estate

Property address and type, ownership, approximate value, existing secured borrowing and the most recent available historic valuation. Further property records may follow.

Aviation and marine

Asset description, registration or flag, location, owner, value, use and existing finance. Valuations, surveys, maintenance and other technical records may be requested later.

Provide only information relevant to the enquiry. Unrelated holdings and transactions may be redacted from statements, while keeping the owner’s identity and relevant assets visible. Never send private keys, seed phrases, passwords or recovery codes. Public wallet information does not give us permission to access or control a wallet.

We obtain information directly through forms, email, calls and documents; from borrowers, asset owners, brokers, introducers and other authorised representatives; from professional advisers, custodians and relevant service providers; and from public company, property, asset and other registers. Relevant due diligence may also use compliance, fraud, sanctions and risk-intelligence sources, and publicly available blockchain information.

If you provide another person’s information, ensure you are entitled to share it and give them this policy. We also provide privacy information to people whose data we receive indirectly, within the applicable timeframe unless a lawful exception applies. Contact us if you would like details of the source of your information.

Where the EU or UK GDPR applies, the basis depends on the purpose and your relationship with us. We use personal data only where we have an applicable lawful basis.

Enquiries and assessment

To respond, assess collateral and consider financing. We rely on steps you request before a contract where you would be the individual borrower; for corporate contacts and representatives, our legitimate interest in assessing and managing financing enquiries.

Facilities and transactions

To document, administer and manage financing, collateral and repayments. The basis is performance of our contract with an individual, or our legitimate interests in administering a corporate transaction and communicating with those involved.

Checks and compliance

To verify identity, ownership and authority and carry out relevant compliance checks. We rely on legal obligations where they apply; otherwise, on our legitimate interests in assessing risk and preventing fraud or misuse, where appropriate.

Security and legal rights

To protect systems and information, maintain relevant records, resolve disputes and establish or defend legal claims. We rely on applicable legal obligations or our legitimate interests in protecting the business and those dealing with it.

Optional cookies and marketing

Where consent is required, we obtain it separately. You can withdraw it at any time. Responding to an enquiry does not depend on agreeing to optional marketing or cookies.

When relying on legitimate interests, we consider necessity and balance our interests against your rights and reasonable expectations. Reading or acknowledging this policy is not blanket consent to every use of your information.

Some information is needed to assess an enquiry, comply with a legal requirement or enter into and manage a facility. We explain what is needed at the relevant stage. If necessary information is not provided, we may be unable to progress the enquiry or financing. Optional website fields can be left blank.

Financing may be provided directly by Electron or through a wholly owned subsidiary, including a company established specifically for the transaction. Where necessary, we may share relevant personal information with that subsidiary to assess, document and administer the financing. We will identify the company and explain its role in handling your information in the relevant transaction documents and privacy information.

Where necessary for the purposes above, recipients may include website hosting and form services, email and document-storage providers, IT and security providers, identity and compliance-screening services, professional advisers, banks, payment providers and custodians. Information may also be shared with the borrower, asset owner and their authorised advisers or intermediaries as appropriate to the transaction, or with regulators, public authorities and courts where required or lawfully permitted.

We limit sharing to what is relevant. Providers acting on our instructions are subject to appropriate contractual requirements. Other recipients, such as professional advisers or regulated institutions, may act as independent controllers and provide their own privacy information. We do not sell personal data.

Our operations involve Cyprus and Seychelles. Service providers and transaction participants may process information in other countries. Where an EU or UK restricted transfer is involved, we use an applicable adequacy decision or appropriate safeguards and complete the assessments required for the transfer. Contractual safeguards may include EU standard contractual clauses and, for UK transfers where relevant, the UK International Data Transfer Agreement or UK Addendum.

Contact compliance@electronfamilyoffice.com for information about relevant destinations and safeguards, including a copy of applicable safeguards with confidential information redacted where necessary. Security measures such as encryption support protection but do not replace a required legal transfer mechanism.

For an incomplete or unsuccessful enquiry, we consider whether discussions remain active, whether information is still needed to explain an assessment or respond to follow-up, and any applicable legal, regulatory or claims requirements. We review the need to retain it and delete or anonymise information when it is no longer required. This does not mean that every initial enquiry is kept for the same period as a completed transaction.

Due-diligence, KYC and AML records are typically retained for 5–7 years, depending on the applicable jurisdiction and requirement. The starting point and period depend on the record and obligation. Facility, accounting and legal records are retained for the relevant contractual, statutory and claims periods. A dispute, investigation or legal hold may require longer retention.

We use technical and organisational measures appropriate to the information and risks, including access restrictions and suitable protections for storage and communication. Access is limited to those who need it for their role. No internet transmission or system can be guaranteed completely secure. Ask us for the appropriate channel before sending detailed identity or financial documents.

Website services may collect technical information such as IP address, device and browser details, pages viewed and security logs. We use necessary technologies to operate and protect the site and remember choices. Where optional analytics or other technologies are used, the consent controls explain their purpose, providers and duration. Technologies requiring consent are used only after the relevant choice.

Use the separate cookie preferences button to review or change optional preferences. You can reject optional technologies and still make an enquiry. Necessary technologies cannot be disabled through those controls. Browser settings can also limit cookies, although some site functions may be affected.

Depending on the applicable law and circumstances, you may request access to your data, correction, erasure, restriction or portability. You may withdraw consent without affecting processing already carried out lawfully. You may also have rights relating to automated decisions, including profiling. These rights are subject to applicable conditions and exceptions; for example, some records may need to be retained to meet legal obligations.

YOUR RIGHT TO OBJECT: You may object to processing based on legitimate interests on grounds relating to your situation. You may object to direct marketing at any time.

To exercise your rights, email compliance@electronfamilyoffice.com. We may request information proportionate to verifying your identity and understanding your request. We respond within the applicable legal timeframe. You can unsubscribe from marketing through the message or contact us directly.

Please contact compliance@electronfamilyoffice.com with a privacy question or concern. You also have the right to complain to the competent data protection authority, including the authority where you live, work or where an alleged infringement occurred, where applicable.

Cyprus: Commissioner for Personal Data Protection — www.dataprotection.gov.cy

United Kingdom: Information Commissioner’s Office — ico.org.uk/make-a-complaint

We review this policy when our services or data practices change. The latest version is published on this page with its revision date. Where required, we provide further notice of material changes before using information for a new purpose.