Privacy Policy

Version: 2.0
Published: 7 June 2026

1. Who we are

This website is operated by Roxton Holdings Inc.

Roxton Holdings Inc. is incorporated and registered in the Republic of Seychelles as an International Business Company under Certificate No. 009992.

Registered office:
1st Floor, Oliaji Trade Centre
Rue de Possession
PO Box 1377
Victoria, Mahé
Republic of Seychelles

Website: roxtonholdings.com
Privacy enquiries: webcompliance@roxtonholdings.com

In this Privacy Policy, “Roxton Holdings”, “we”, “us” and “our” refer to Roxton Holdings Inc.

2. Purpose of this website

This website provides information about Roxton Holdings and its activities.

We do not use this website to sell personal data, display advertising, profile visitors or conduct automated decision-making.

3. Personal information we collect

We collect personal information only where it is reasonably necessary to respond to an enquiry, carry out a requested verification or operate and protect the website.

Information submitted through forms or by email

If you contact us through the website or by email, we may receive the information that you choose to provide, such as:

• your name;
• your email address;
• your telephone number, if provided;
• the organisation that you represent, if relevant;
• the subject and content of your enquiry;
• documents or files that you choose to upload through a verification form; and
• any other information that you choose to include in your correspondence.

Please do not submit personal information that is unnecessary for the purpose of your enquiry.

Technical information

When you visit the website or submit a form, limited technical information may be processed automatically by our website hosting, security, form-processing and spam-protection systems. This may include:

• your internet protocol address;
• browser type and browser user-agent information;
• device type;
• date and time of access;
• pages requested;
• the referring page or website; and
• information required to identify and prevent malicious activity, spam or misuse of the website.

Where Akismet spam protection is enabled for a form, information submitted through that form, together with relevant technical information, may be sent to the Akismet service for the purpose of identifying and preventing spam.

We do not use this technical information to create advertising profiles or to track visitors across unrelated websites.

4. How we use personal information

We may use personal information to:

• respond to enquiries;
• carry out a verification requested through the website;
• review documents voluntarily submitted to us;
• maintain a record of business correspondence where reasonably necessary;
• protect the security and proper operation of the website;
• prevent spam, fraud or misuse; and
• comply with legal, regulatory or administrative obligations.

We do not use personal information submitted through this website for unrelated marketing purposes without first obtaining any consent required by law.

5. Spam protection

We use Akismet to help protect this website against spam and malicious submissions.

Where Akismet is enabled for a form, relevant information may be sent to the Akismet service for automated spam checking. This may include information entered into the form, such as your name, email address and message, together with technical information such as your internet protocol address, browser user-agent information, referring page and the address of this website.

Akismet is operated by Automattic. The information is processed for the legitimate purpose of protecting the website against spam, fraud and misuse.

You can find further information about how Akismet processes data in Automattic’s privacy information for visitors to users’ websites.

6. Lawful basis for processing

Where the UK GDPR applies, we process personal information only where we have a lawful basis to do so.

Depending on the circumstances, this may include:

• legitimate interests, where it is reasonably necessary to respond to an enquiry, operate the website securely or maintain appropriate business records;
• steps taken at your request before entering into a contract, or the performance of a contract, where your enquiry relates to a proposed or existing business relationship;
• legal obligations, where we are required to retain or disclose information by law; and
• consent, where consent is specifically requested and is the appropriate lawful basis.

7. Sharing personal information

We do not sell personal information.

We may share limited personal information only where reasonably necessary with:

• website hosting, email, security and form-processing providers acting on our behalf;
• Automattic, where Akismet spam protection is used to assess a form submission for spam or malicious content;
• professional advisers, where necessary;
• counterparties or service providers involved in responding to a request or carrying out a verification, where appropriate; and
• courts, regulators, law-enforcement authorities or other public bodies where disclosure is required or permitted by law.

Where we use service providers, we require them to process personal information only for the relevant purpose and to protect it appropriately.

8. International processing

Roxton Holdings is incorporated in the Republic of Seychelles and may work with service providers or advisers in more than one country.

Where personal information is transferred internationally, we take reasonable steps to ensure that it is handled securely and in accordance with applicable data-protection requirements.

9. How long we keep personal information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected.

As a general rule:

• routine enquiries that do not lead to an ongoing business relationship will normally be deleted within 12 months after the correspondence has concluded;
• verification requests and associated documents will be retained only for as long as reasonably necessary to complete the verification and maintain an appropriate record of the outcome;
• information relating to an ongoing business relationship may be retained for the duration of that relationship and for an appropriate period afterwards; and
• information may be retained for longer where necessary to comply with legal obligations, resolve a dispute, prevent fraud or protect our legitimate interests.

10. Cookies

This website does not use cookies for advertising, behavioural profiling or cross-site tracking.

The website may use limited cookies or similar technologies that are necessary for the secure and effective operation of the website. These may include cookies used by WordPress, website-security systems or form-processing services.

WordPress may also use cookies for website administrators when they log into the website. These administrative cookies do not ordinarily affect general visitors.

If we introduce analytics, advertising or other non-essential cookies in the future, we will update this Privacy Policy and, where required, request consent before those cookies are used.

You can control or delete cookies through your browser settings. Disabling essential cookies may affect the operation of certain website features.

11. Links and embedded content

This website may contain links to third-party websites. Those websites operate under their own privacy policies, and we are not responsible for their privacy practices.

If we embed third-party content in the future, such as a video or interactive feature, the provider may collect information or set cookies in accordance with its own privacy policy. Where required, such content will not be activated until the appropriate consent has been obtained.

12. Your rights

Depending on the law applicable to your circumstances, you may have the right to:

• request access to the personal information that we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to delete personal information where there is no continuing lawful reason to retain it;
• ask us to restrict the use of your information in certain circumstances;
• object to processing based on legitimate interests;
• withdraw consent where processing is based on consent; and
• request the transfer of information in a portable format where the relevant legal conditions apply.

To exercise any of these rights, please email webcompliance@roxtonholdings.com.

We may need to request information to confirm your identity before responding.

13. Complaints

Please contact us first if you have any concern about the way in which we handle personal information. We will seek to resolve the matter promptly.

Where the UK GDPR applies, you also have the right to make a complaint to the UK Information Commissioner’s Office.

14. Security

We take reasonable technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

However, no method of transmitting information over the internet is completely secure. Please avoid submitting information that is unnecessary for your enquiry.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to the website, our practices or applicable law.

The latest version will be published on this page with its publication date.