This privacy policy explains how Gibraltar Relocation (gibraltarrelocation.com) collects, uses, and protects your personal data. We follow the EU General Data Protection Regulation (GDPR), the Spanish Organic Law 3/2018 on Data Protection (LOPDGDD), the Spanish Information Society Services Law (LSSI), and the Gibraltar Data Protection Act 2004.
1. Who we are
This website is operated by Norry Holdings Ltd, a company registered in Gibraltar.
- Company number: 125231
- Registered office: Suite 4, 2nd Floor The West Wing, Montarik House, 3 Bedlam Court, Gibraltar GX11 1AA
- Director: Ethan Roworth
- Site email: info@gibraltarrelocation.com
- Data protection contact: ethanleo.rm@gmail.com
We are the data controller for any personal data you give us through this site.
2. What this site does
Gibraltar Relocation exists to help individuals, families, and businesses relocate to Gibraltar by connecting them with relocation specialists, legal advisors, and service providers.
3. What data we collect
When you fill in a form on this site (contact form, enquiry form, newsletter signup, etc.) we collect:
- Name
- Email address
- Phone number (optional)
- Type of relocation (individual, family, business)
- Nationality and current country
- Timeframe
- Message text
When you visit any page we also collect some data automatically:
- IP address
- Browser type and version
- Device type (desktop, mobile, tablet)
- Pages you visit and time spent
- Referrer (the site you came from)
- Approximate location (country level)
This automatic data comes from server logs and, if you accept cookies, from analytics tools.
4. Why we collect it (lawful basis)
We collect your data for these reasons:
- To answer your enquiry — when you fill in a form, we use the data to reply to you and to put you in touch with a relevant partner. Lawful basis: consent (when you tick the box) and legitimate interest (to follow up on your enquiry).
- To improve the site — we look at anonymous usage data to see which pages work and which do not. Lawful basis: legitimate interest.
- To send you updates — only if you tick the newsletter box. Lawful basis: consent.
- To comply with the law — we may need to keep records for tax or legal reasons. Lawful basis: legal obligation.
You can withdraw consent at any time by emailing info@gibraltarrelocation.com.
5. Who we share your data with
We share your data with the following types of organisations:
Partners (only when you enquire):
Relocation consultancies, immigration lawyers, tax advisors, property agents, and removal companies in Gibraltar. Enquiries are forwarded to the most relevant partner based on what you ask about.
We only share what is needed to follow up your enquiry. We do not sell your data to anyone, ever.
Service providers (data processors):
- Supabase — database and file storage (EU region)
- Vercel — website hosting (EU region)
- Mailcow on Hetzner — email infrastructure (Germany)
- HubSpot — customer relationship management (EU instance)
- Cloudflare — DNS and network security
- Microsoft Clarity — anonymous heatmaps and session recordings, only if you accept analytics cookies
Each provider has signed a data processing agreement with us. They cannot use your data for their own purposes.
6. International transfers
Norry Holdings Ltd is based in Gibraltar, which has an EU adequacy decision (so transfers between the EU and Gibraltar are treated as safe).
If you are a UK or Gibraltar user and your enquiry is forwarded to a partner in Spain, that is an intra-EEA transfer and no extra safeguards are needed. If any processor stores data outside the EEA, we rely on Standard Contractual Clauses approved by the European Commission.
7. How long we keep your data
- Enquiry data: 24 months from your last contact with us, then deleted unless you have become an active customer.
- Newsletter subscribers: until you unsubscribe.
- Server logs: 30 days.
- Accounting records: 7 years (Gibraltar tax law).
8. Your rights
Under GDPR and LOPDGDD you have the right to:
- Access — get a copy of the data we hold about you
- Rectification — correct anything that is wrong
- Erasure — ask us to delete your data ("right to be forgotten")
- Restriction — ask us to stop using your data while we sort something out
- Portability — get your data in a machine-readable format
- Object — say no to processing based on legitimate interest
- Withdraw consent — at any time, for anything you consented to
- Not be subject to automated decision-making — we do not do this anyway
To use any of these rights, email info@gibraltarrelocation.com or ethanleo.rm@gmail.com. We will reply within 30 days.
9. Cookies
This site uses a small number of cookies. The first time you visit you will see a cookie banner where you can accept or reject non-essential cookies. We use:
- Essential cookies — to remember your language and session. Always on.
- Analytics cookies — Microsoft Clarity. Only if you accept.
- No advertising or tracking cookies.
You can change your cookie choices at any time by clicking the cookie settings link in the footer.
10. Complaints
If you are unhappy with how we have handled your data, please email us first so we can try to fix it. You can also complain to a data protection authority:
- Spain (AEPD): Agencia Española de Protección de Datos, C/ Jorge Juan, 6, 28001 Madrid. Web: aepd.es
- Gibraltar (GRA): Gibraltar Regulatory Authority, 2nd Floor, Eurotowers 4, 1 Europort Road, Gibraltar. Web: gra.gi
- UK (ICO): Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Web: ico.org.uk
11. Changes to this policy
We may update this policy from time to time. The "Last updated" date at the top will change. If we make a material change (for example, sharing data with a new partner), we will email anyone we have an email address for and post a notice on the site for 30 days.
12. Contact
For any privacy questions:
- Email: info@gibraltarrelocation.com
- Data protection contact: ethanleo.rm@gmail.com
- Post: Norry Holdings Ltd, Suite 4, 2nd Floor The West Wing, Montarik House, 3 Bedlam Court, Gibraltar GX11 1AA