Privacy policy
Last updated: 2 November 2026This website is deliberately simple. It has no contact form, no accounts, no cookies and no analytics. This page explains what personal data we handle when you visit the site or write to us.
1. Who is responsible
The controller is Halley Diamond System Limited, Suite 4, 2nd Floor, The West Wing, Montarik House, 3 Bedlam Court, Gibraltar GX11 1AA, company number 116433. Contact for all privacy matters: info@cga.academy.
2. What data we handle
When you e-mail us. The "Write an e-mail" button simply opens your own e-mail program. Nothing is sent until you send the message yourself. If you do, we receive your e-mail address, your name if it appears in your message, the content of your message and anything else you choose to tell us, for example a phone number.
When you visit the website. Like every web server, our hosting provider automatically records technical data about each request in its server log: IP address, date and time, the file requested, the response code and the type of browser. We do not use this data to identify you.
What we do not do. The website sets no cookies, uses no analytics or advertising tools, and loads no scripts, fonts or images from third parties. The fonts are stored on our own server. If you click the link to cga.academy, you leave this website and the rules of that website apply.
3. Why we use the data, and on what legal basis
- Answering your message and, if you ask for it, arranging a conversation with one of our mentors. Legal basis: Article 6(1)(f) of the GDPR (our legitimate interest in answering enquiries), and where you ask us to take steps before joining, Article 6(1)(b). If you give us your phone number so that we call you, we use it for that purpose on the basis of your consent, Article 6(1)(a). You can withdraw this consent at any time.
- Server logs, to keep the website secure and running. Legal basis: Article 6(1)(f) (our legitimate interest in the security and operation of the website).
4. Who receives the data
- Our hosting and e-mail provider, Rackforest Zrt., Budapest, Hungary, which processes data on our behalf.
- A mentor of the community, if your message is about getting to know the community or the business and you expect a personal reply. We pass on only what is needed to answer you. Mentors are independent partners; they use your data only to reply to you.
We do not sell your data, and we do not transfer it outside the European Economic Area and Gibraltar.
5. How long we keep it
We keep your message for as long as needed to deal with your enquiry, and delete it no later than 12 months after our last contact, unless the law requires us to keep it longer or you have joined cga.academy (in which case the terms of that service apply). Server logs are kept by the hosting provider for a short period according to its own settings.
6. Your rights
You have the right to ask us for access to your data, to have it corrected or erased, to restrict or object to its use, and to receive it in a portable form. Where we rely on your consent, you can withdraw it at any time; this does not affect what we did before. To use any of these rights, write to info@cga.academy.
7. Complaints
You may complain to the Gibraltar Regulatory Authority (www.gra.gi), or to the data protection authority of the country where you live or work.
8. Changes
If we change how this website works, for example by adding a contact form or analytics, we will update this page before the change goes live.