Privacy Policy

Good Markets Holdings Ltd ("Good Markets", "we", "us", or "our") is committed to protecting and respecting your privacy. This policy explains what personal data we collect, why we collect it, how we use it, and the rights you have over it.

Good Markets Holdings Ltd is the controller of your personal data. We are a company registered in England and Wales under company number 09938653, with our registered office at 49 Grosvenor Street, London, W1K 3HP, United Kingdom.

This policy applies to visitors to this website, people who contact us, and individuals we deal with at organisations that are, or may become, our clients, counterparties, investors, or suppliers.

Information you give us. When you email or otherwise contact us, we collect the details you provide, such as your name, email address, telephone number, organisation, job title, and the content of your message.

Information about our business relationships. If you or your organisation are a client, counterparty, investor, or supplier, we may hold:

• Business contact details and correspondence.
• Financial information, such as transaction history, trading activity, and financial performance relating to services we provide to, or receive from, your organisation.
• Information we need to meet our legal and regulatory obligations, for example identity and verification information for anti-money laundering checks, where these apply.

Information collected automatically. When you visit this website, Google Analytics collects information about your visit, such as the pages you view, how you reached the site, your browser and device type, operating system, screen size, language, and approximate location (country or city). Our hosting provider may also record technical information, such as your IP address and browser type, in server logs to keep the site secure and working.

We do not intentionally collect special category data (such as health, religious, or biometric information) through this website.

Data protection law requires us to have a lawful basis for each way we use your personal data. We use it for the following purposes:

Where we rely on legitimate interests, we have considered whether those interests are outweighed by your rights and freedoms. You can ask us for more information about this assessment.

We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.

Cookies are small files placed on your device when you visit a website. This website only uses analytics cookies set by Google Analytics. We use them solely to produce aggregate statistics about how the website is used so that we can improve it. We do not use advertising cookies, and we do not use analytics data to build profiles of individual visitors.

Under the Privacy and Electronic Communications Regulations, as amended by the Data (Use and Access) Act 2025, analytics cookies used only for this purpose do not require your consent, provided we tell you about them and give you a simple way to object.

You can object to analytics cookies at any time, free of charge, by installing Google's browser add-on to opt out of Google Analytics, or by blocking or deleting cookies through your browser settings. The website will continue to work normally.

This website also loads fonts from Google Fonts. This does not set cookies, but your browser sends your IP address to Google to download the fonts.

We do not sell your personal data. We may share it with:

• Service providers who act on our behalf, such as website hosting, email, IT, and analytics providers (including Google), under contracts that require them to protect your data and only use it on our instructions.
• Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you.
• Professional advisers, such as lawyers, accountants, auditors, and insurers.
• Regulators, law enforcement, tax authorities, courts, and other public bodies, where we are required or permitted to do so by law, or to enforce or apply our terms of use and other agreements.
• A prospective buyer or seller, and their advisers, if we sell or buy any business or assets.

Some of our service providers, including Google, may process personal data outside the United Kingdom, for example in the United States. When this happens, we make sure the transfer is protected by an appropriate safeguard, such as a UK adequacy regulation (including the UK Extension to the EU-US Data Privacy Framework, where the recipient is certified under it), or the UK International Data Transfer Agreement or UK Addendum to the EU standard contractual clauses. You can contact us for more information about the safeguards we use.

We keep personal data only for as long as we need it for the purposes it was collected for, including to meet any legal, regulatory, tax, or reporting requirements.

• Enquiries that do not lead to a business relationship are kept for up to two years after our last contact with you.
• Records relating to clients, counterparties, investors, and suppliers are kept for the length of the relationship and afterwards for as long as the law requires, which for anti-money laundering and financial records is usually at least five to six years.
• Google Analytics data is kept for up to 14 months and is then deleted automatically.

We use appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to personal data is limited to the people and service providers who need it.

Under UK data protection law you have the right to:

• Access the personal data we hold about you and receive a copy of it.
• Rectify any incorrect or incomplete data we hold about you.
• Erase your personal data where there is no good reason for us to continue processing it.
• Restrict how we use your personal data, for example while we check its accuracy.
• Object to processing based on our legitimate interests, and to stop us using your data for direct marketing at any time.
• Data portability, meaning to receive data you provided to us in a structured, machine-readable format, or have it sent to another organisation, where the processing is based on consent or contract and carried out by automated means.

To exercise any of these rights, email [email protected]. We will respond within one month, and there is normally no charge. We may need to confirm your identity before we act on your request. Some rights are subject to limits, for example where we must keep data to comply with the law.

If you have any concerns or complaints about how we use your personal data, please contact us at [email protected] and we will do our best to resolve them.

This website and our services are intended for institutional and professional investors and are not directed at children. We do not knowingly collect personal data from anyone under 18.

Any changes we may make to our privacy policy in the future will be posted on this page with an updated date and, where appropriate, notified to you by email.

Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to [email protected] or by post to:

Good Markets Holdings Ltd
49 Grosvenor Street, London, England, W1K 3HP, United Kingdom