Privacy Policy

Last updated: 13th May 2022

This privacy policy describes the types of data that Holowesko Partners Ltd. (“Holowesko”, “we”) collects about users (“you”) of this  (the “Site”), and how Holowesko uses, shares, and protect personal information. Please read the following carefully to understand Holowesko’s data practices.

Company name: Holowesko Partners Ltd.

Address: Shipston House, Lyford Cay, P.O. Box N-7776-78, Nassau, Bahamas


What data do we collect about you?

Information You Give Us. Personal information we collect from you includes:

  • contact information, e.g. first name, last name and email address; and
  • any information you provide to us within any messages you send to us via the contact form on the Site or our contact e-mail address noted above.

Information Automatically Collected. We may automatically record certain information about how you use our Site such as your Internet Protocol (IP) address, device and browser type, operating system, and other statistics.  We use this information to administer the Site.

How do we use cookies?

We use cookies or similar technologies solely for the purpose of administering the Site. The Site does not respond to Do Not Track signals. For more information on our use of cookies, please see our Cookie Policy .

How do we use your personal information?

We use your personal information for the following purposes:

  • to administer, improve and optimize the Site, including enhance the security;
  • to respond to your requests submitted via the Site’s contact form or our email address noted above;
  • to contact you with personalized marketing and advertising about our products and services;
  • to comply with applicable laws and regulations;
  • for our legitimate interests related to our operations; and
  • any other purposes that may arise from time to time and for which we will obtain your specific consent.

We undertake these processing activities as necessary to achieve our legitimate interests or comply with applicable laws. When relying on legitimate interests we make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by applicable law).

Additionally, we may also rely for a given purpose on your specific or informed consent. Where we rely on your consent, you have the right to withdraw it anytime in the by contacting us at (though this will not affect the lawfulness of any processing undertaken before your withdrawal)

How do we share your personal information?

We do not share or sell the personal information that you provide us with other organizations without your express consent, except under the following circumstances:

  • Compliance with Laws and Law Enforcement, Protection and Safety. We may share personal information for legal, protection, and safety purposes.
  • Professional Advisors, Business Partners and Service Providers. We may share information with those who need your information to perform their work or services for us or on our behalf.
  • For business transfers. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • With affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates may include other companies that we control or that are under common control with us.
  • Other. You may permit us from time to time to share your personal information with other companies or entities of your choosing.

Do we transfer your personal information internationally?

Your personal information may be transferred to or from the United States, the Bahamas or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction. Your consent to this privacy policy followed by your submission of such information represents your agreement to such transfer.

We will take steps that are reasonably necessary to ensure that your personal information is treated securely and appropriately safeguarded in accordance with this privacy policy and applicable data protection or privacy laws.

Please contact us at if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA/UK.

How is your personal information secured?

We employ appropriate technical and organizational measures designed to protect the security of all information submitted through the Site.

How long is your personal information retained?

We retain your personal information only for as long as is necessary for the purposes set out in this privacy policy and to the extent permitted by applicable legal requirements.

What are your rights?

To the extent applicable under data protection or privacy  laws of your jurisdiction, you may have specific rights in relation to the personal information we hold about you and how that personal information is processed by Holowesko. If you would like to exercise any rights afforded to you under applicable data protection or privacy laws, please contact us at

You have the right (subject to certain limitations) to (a) confirm that Holowesko is processing your personal information, and how; (b) to access or rectify the personal information we keep about you; (c) to restrict, object to, or erase the processing of your personal information, e.g. where there is no longer a legal ground for us to hold it; and (d) in some circumstances, transfer/port any information we hold about you to a specified third party.

If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at You also have the right to lodge a complaint with the appropriate regulatory body/supervisory authority, in particular in the country where you reside, place of work or of an alleged infringement of the law. Contact details are available for EU data protection authorities here, and for the UK here.

CCPA Privacy Policy

This privacy policy section pertains to the California Consumer Privacy Act (CCPA), and it supplements the other provisions of this privacy policy. This privacy policy section applies solely to all Site visitors and users who reside in the State of California. 

What categories of personal information do we collect?

The following is a list of categories of personal information, defined under the CCPA, which we may collect or may have been collected from California residents within the last twelve months.

  • Category A: Identifiers. Examples include a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, or email address.
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples include a name, signature, address, telephone number, driver's license number, or financial information.
  • Category D: Commercial information. Examples include records and history of products or services purchased or considered.
  • Category F: Internet or other similar network activity. Examples include records of interactions between you or your device and our Site.

Disclosure of personal information for business purposes or commercial purposes

We may disclose and may have disclosed in the last twelve months the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers.
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  • Category D: Commercial information.
  • Category F: Internet or other similar network activity.

No sale of personal information

We do not sell personal information. As defined in the CCPA, a sale of personal information broadly includes any communication or transfer of your personal information to another business or third party for monetary or other valuable consideration (e.g., a nonmonetary benefit).

No collection or sale of personal information of minors under 16

We do not knowingly collect personal information from minors under the age of 16 through our Site, and we do not sell the personal information of consumers we actually know are less than 16 years of age. If you believe that a child under the age of 16 has provided us with personal information, then please contact us with sufficient detail to enable us to delete that information.

Your rights under the CCPA

The CCPA provides California residents with the following rights:

  • The right to know. Under the CCPA, you have the right to request that we disclose what personal information about you we collect, use, disclose, and sell, including the categories of third parties who may have purchased or received your data, and the specific pieces of information which we hold. If we deliver our response electronically, then the information enclosed must be delivered in an easily usable (portable) format.
  • The right to opt-out of the sale of personal data. You have the right to direct us to not sell your personal information.
  • The right to delete personal data. You have the right to request the deletion of your personal data, subject to statutory exceptions. Once we receive and verify your request, we will delete your personal information from our records, unless an exception applies.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer’s rights under the CCPA.

Exercising your rights under the CCPA

In order to exercise any of your rights under the CCPA, please contact us at with a request that provides sufficient information for us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Please include sufficient details for us to properly understand, evaluate and respond to your request.

We will confirm receipt of your request within 10 days. In response to a verifiable request, we will attempt to deliver the required information free of charge within 45 days. If we need additional time to respond to your request, then we will notify you and respond within 90 days of the request. Any disclosures by us will cover only the 12-month period preceding our receipt of the request.

Changes to this policy

We will update this privacy policy when necessary, including to reflect customer feedback and changes to this Site. When we post changes to this privacy policy, we will revise the “last updated” date at the top of the statement. We encourage you to periodically review this privacy statement to learn how Holowesko is protecting your information.