1. DOCUMENT CONTROL
Author(s): Legal & Compliance
Last review date: 2026 – January
Next review date: 2027 – January
2. WHO ARE WE
The Deaglo Group consists of several legal entities, including Deaglo Holdings, Deaglo Financial Services, Deaglo Partners., Deaglo Technologies as ZeroVar. “Deaglo”, “we”, “our” or “us” refers to the Deaglo entity responsible for the collection and use of personal data depending on the applicable jurisdiction.
Deaglo may process certain personal data about you depending on the nature of your relationship with us. This processing is regulated under the following legislation (collectively, the Data Protection Laws):
- UK Data Protection Act
- General Data Protection Regulation (EU) 2016/679 (GDPR), including the Norwegian Law on the Processing of Personal Data
- e-Privacy Directive (2002/58/EC)
Singapore Personal Data Protection Act (PDPA)
- Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)
- New York Privacy Act
Deaglo acts as the data controller for the purposes of these laws.
3. WHAT DOES THIS PRIVACY NOTICE COVER?
This Privacy Notice (“Notice”) applies when you:
- directly or indirectly use our services as a prospective or existing client;
- visit or interact with our website or digital platforms;
- apply for employment or internship opportunities;
- are contacted through our direct marketing initiatives (email, phone, or other channels).
4. DATA PROTECTION PRINCIPLES
We take your privacy seriously and are committed to processing your personal data lawfully, fairly and transparently. Under the Data Protection Laws, the personal data we process must be:
- used lawfully, fairly and transparently;
- collected with your clear consent where required, using plain and accessible language;
- collected for explicit, legitimate purposes communicated to you;
- limited to what is necessary;
- accurate and kept up to date;
- retained only as long as necessary;
- stored and processed securely.
“Personal data” means any information relating to an identifiable individual.
5. PERSONAL DATA WE COLLECT ABOUT YOU
Depending on your interactions with us, we may collect and process the following categories of personal data:
Identity Data
Name, date/place of birth, gender, nationality, copies of identification documents (passport, driver’s licence), right-to-work documentation, and employment or education history where relevant.
Contact Data
Address, email, phone number, and emergency contact details.
Client-Related Data
Business information, your relationship with Deaglo, details related to your role, shareholdings, and professional contact details.
Financial Data
Bank account details, tax status, tax identification number, fiscal residence.
Compliance & Due Diligence Data
Information relating to KYC, AML, source of funds/wealth, beneficial ownership and other regulatory checks.
Usage Data
Website usage information, cookies, IP address, browser type, and other analytics data.
Criminal Conviction Data
Where permitted by law and only when necessary for regulatory compliance or employment screening.
6. HOW AND WHY WE COLLECT / USE PERSONAL DATA
We collect, use and store your personal data for the following (non-exhaustive) purposes:
- understanding your needs and tailoring our services;
- allowing access to website features or client interfaces;
- responding to enquiries and communicating with you;
- call recording for training, monitoring and security;
- performing identity verification, KYC, AML and other regulatory checks;
- improving website functionality, user experience and analytics;
- internal business administration;
- ensuring compliance with laws, regulations and internal policies;
- maintaining operational databases;
- sending marketing communications (where lawful and only where you have not opted out);
- evaluating candidates for employment opportunities;
- conducting background and pre-employment checks (where permitted);
- managing event registrations and sharing limited information with co-hosts or venues.
If you fail to provide information required by law or contract, we may be unable to provide certain services or proceed with an engagement.
7. WHO YOUR PERSONAL DATA MAY BE SHARED WITH
We may share your personal data with:
- Deaglo Group companies and affiliates;
- professional advisers, consultants and legal representatives;
- service providers, contractors and technology partners supporting our business operations;
- regulators, law enforcement or government bodies when required;
- event partners and venue operators (only where necessary for event administration).
We never sell your personal data, and all sharing is conducted in accordance with the Data Protection Laws.
8. HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We retain your data for the duration of our contractual relationship and thereafter only as long as required for:
- legal or regulatory obligations,
- resolving disputes,
- preventing fraud or financial crime.
When data is no longer required, it is securely deleted, anonymised or destroyed.
9. KEEPING YOUR PERSONAL DATA SECURE
We maintain appropriate technical and organisational measures to safeguard your personal data, including encryption, access controls and secure storage environments.
Access is restricted to personnel with a legitimate business need, each of whom is bound by confidentiality obligations.
We have incident response procedures in place and will notify you and relevant authorities of any data breach where legally required.
While we strive to protect your data, you acknowledge that transferring information over the internet carries inherent risks.
10. STORAGE, TRANSFERS AND RETENTION OUTSIDE THE UNITED KINGDOM
Your personal data may be transferred to and stored in jurisdictions outside the UK, including the EEA, the United States, and Asia-Pacific regions. Whenever we transfer data internationally, we ensure an adequate level of protection through mechanisms such as:
- Standard Contractual Clauses (SCCs),
- adequacy decisions,
- other lawful safeguards.
Only authorised third parties with a legitimate purpose will have access to your data.
11. MARKETING
We may send you information about our services and insights relevant to you. Marketing may be delivered via email, phone or post.
You will be asked to opt in to marketing communications when providing your contact information.
You can withdraw your consent or opt out at any time—see Section 12.
12. YOUR RIGHTS
You have the following rights under data protection legislation:
Right of Access
Request copies of your personal data and information on how it is processed.
Right to Rectification
Request correction of inaccurate or incomplete data.
Right to Erasure
Request deletion of your personal data under certain conditions.
Right to Restrict Processing
Request restriction of how your data is used.
Right to Object
Object to processing, including direct marketing.
Right to Data Portability
Request transfer of your data to another organisation or directly to you.
Requests can be made via the contact details in Section 14. We will respond within one month.
Some unsubscribe options may take a short time to process.
13. CHANGES TO THIS PRIVACY NOTICE
We may update this Notice periodically. Updates will be communicated through:
- direct email notifications (where applicable);
- notices displayed on our website.
Please review the Notice regularly for the most current version.
14. CONTACTING US
If you have any questions about this Privacy Notice or how we process your personal data, please contact:
Email: compliance@deaglo.com
Post: Deaglo Inc.– Compliance Team,
1078 Summit Ave, PMB 815, Jersey City, NJ 0730
15. COMPLAINTS
If you have concerns or complaints about how we process your personal data, please contact us using the details above. We will acknowledge and respond to your complaint within a reasonable timeframe.
If you are not satisfied with our response, you may contact the UK Information Commissioner’s Office (ICO) at:
Phone: 0303 123 1113Website: https://ico.org.uk/make-a-complaint/