Privacy Policy
APPLICATION OF THIS PRIVACY POLICY
SOOR CAPITAL MANAGEMENT (DIFC) LIMITED is committed to protecting the Personal Data of the individuals we encounter in conducting our business. Our Privacy Policy have been designed to ensure that your Personal Data is protected. This Privacy Policy explains how and why SOOR CAPITAL MANAGEMENT (DIFC) LIMITED, its representatives and authorized administrators ("we" "us" "our") will collect, process and disclose the Personal Data of Customers/Vendors/ Employees ("you" "your") and provides information about your rights.
We work hard to respect and maintain personal privacy and accordingly align this policy with the Dubai International Financial Centre Data Protection Law (DIFC Law No.5 of 2020, as amended)("DPL") when collecting, holding, processing or using Personal Data in the Dubai International Financial Centre ("DIFC").
"Personal Data" means any information referring to a natural living person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one (1) or more factors specific to biological, physical, biometric, physiological, mental, generic, economic, cultural or social identity.
"Special Categories of Personal Data" means Personal Data revealing or concerning (directly or indirectly) racial or ethnic origin, communal origin, political affiliations or opinions, religious or philosophical beliefs, criminal record, trade-union membership and health or sex life and including genetic data and biometric data where it is used for the purpose of uniquely identifying a natural person.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. THIS PRIVACY POLICY MAY BE MODIFIED FROM TIME TO TIME.
COLLECTION OF PERSONAL INFORMATION
We may collect personal information from you through your use of the website, when you request information from us, when you engage with us for employment or for any services, or as a result of your relationship with any of our clients.
We may request, and collect from you, personal information and other information. Depending on the information or services you request, we may ask you to provide your name, phone numbers, address, email address, passport details, and other such personal information.
By providing us with any personal information, you are consenting to the use of your personal information as contemplated in this privacy policy. If you do not want us to use your personal information for any of these purposes, please do not provide us with your personal information.
In addition to the personal information you knowingly provide to us, with regard to each of your visits to our website, we may automatically collect the following information:
• Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, location; browser plug-in types and versions, operating system; and
• Information about your visit; services you viewed or searched for; page response times, download errors, length of visits, page interaction information (such as scrolling, clicks, and mouse-overs).
COOKIES AND SIMILAR TECHNOLOGIES
Our website uses cookies and similar tracking technologies to distinguish you from other users and to improve your browsing experience. A cookie is a small file placed on your device when you visit our website.
We use the following types of cookies:
• Essential cookies: Required for the website to function properly. These cookies are necessary for the website to function and cannot be switched off in our systems.
• Functional cookies: Enable enhanced functionality and personalization. These cookies allow the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages.
• Analytics cookies: Help us understand how visitors interact with our website by collecting and reporting information anonymously. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site.
• Marketing cookies: Used to track visitors across websites for advertising purposes. These cookies may be set through our site by our advertising partners and are used to build a profile of your interests and show you relevant advertisements on other sites.
You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some services and functionalities may not work.
For more information about how we use cookies and how you can manage your preferences, please see our Cookie Banner when you visit our website.
PURPOSES
We will only use your personal information for our legitimate business purposes, including:
• To process and respond to inquiries, and provide our services;
• To manage our relationship with you and our clients;
• To market our services;
• To compile anonymous statistics, such as website usage statistics and statistics on the effectiveness of invitations and other emails; and
• Where otherwise required by law.
LEGAL BASIS FOR PROCESSING YOUR INFORMATION
SOOR CAPITAL MANAGEMENT (DIFC) LIMITED processes your personal data on the following legal bases:
• Consent: Where you have given clear consent for us to process your personal information for a specific purpose.
• Contract: Where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
• Legal obligation: Where our use of your personal information is necessary for us to comply with the law (not including contractual obligations).
• Legitimate interests: Where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).
Depending on the specific circumstances, we may rely on one or more of these legal bases when processing your personal information. Where we rely on consent for processing, you have the right to withdraw that consent at any time.
SHARING YOUR INFORMATION
We may disclose your personal information to a recipient (i) for the purposes of outsourcing one or more of the purposes-related functions described above; (ii) to confirm or update information provided by you; (iii) to inform you of events, information about our services, and other important information, or (iv) for other purposes disclosed at or before the time the information is collected.
In relation to any other third parties we will only disclose your information where you have given your consent or where we are required to do so by law, or where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights.
CROSS-BORDER TRANSFER OF YOUR INFORMATION
It may sometimes be necessary for us to share your personal information with other Entities around the world or for such SOOR CAPITAL MANAGEMENT (DIFC) LIMITED offices to share your information with Partner Offices in the DIFC. It may also be necessary for us to share your personal information with associated professional services firms around the world, who provide services to us or on our behalf (including data storage facilities or online storage located within or outside the United Arab Emirates, which may be operated by independent service contractors). This will entail a transfer of personal information from within the Dubai International Financial Centre to recipients outside the DIFC, and vice versa.
The level of personal information protection in locations outside DIFC may be less than that offered within the DIFC or the country in which you reside and may not be recognized as providing an adequate level of protection, but we have procedures in place to ensure the protection of personal information. These procedures include putting steps in place to ensure that all such entities keep your personal information confidential and secure and only use it for the purposes that we have specified and communicated to you. When we transfer your information to other countries, we will use, share and safeguard that information as described in this privacy Policy. We only transfer personal information to these countries, with your consent, when it is necessary for the services we provide you, or subject to appropriate safeguards that assure the protection of your personal information, such as standard contractual clauses.
DATA PROTECTION OFFICER
In compliance with DIFC Data Protection Law, SOOR CAPITAL MANAGEMENT (DIFC) LIMITED has appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our Data Protection Officer using the details set out below:
Data Protection Officer
SOOR CAPITAL MANAGEMENT (DIFC) LIMITED
Dubai International Financial Centre
Gate Village 8, Level 3, Unit 6, DIFC
Dubai, UAE
Email: info@soorcapital.com
YOUR RIGHTS
Under certain circumstances, you have the following rights:
• Access and Rectification: The right to ask us to provide you, with copies of the personal information we hold about you at any time and to be informed of the contents and origin, verify its accuracy, or else request that such information be supplemented, updated or rectified in accordance with the applicable law;
• Erasure or Restriction of processing: The right to request erasure or restriction of processing of your personal information that is processed in certain circumstances;
• Objecting: The right to object on legitimate grounds to the processing of your personal information. In certain circumstances we may not be able to stop using your personal information, if that is the case, we'll let you know why;
• Porting: The right to request that some of your personal information is provided to you, or to another data controller, in a commonly used, machine-readable format;
• Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisor or data protection authority. In the DIFC, the supervisory authority is the Commissioner of Data Protection:
Commissioner of Data Protection
Dubai International Financial Centre Authority
Level 14, The Gate Building
P.O. Box 74777
Dubai, UAE
Website: https://www.difc.ae/business/operating/data-protection
Email: commissioner@dp.difc.ae
We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner, so please contact us in the first instance using our contact details provided in this policy.
• Withdraw consent: When personal information is processed on the basis of consent an individual may withdraw consent at any time. In the event that you no longer want to receive any marketing material from us, please use the unsubscribe option (which is in all of our marketing emails to you), or contact us on the details set out below.
If you would like to exercise any of the above rights, please contact us at info@soorcapital.com.
CONFIDENTIALITY
The information you provide may be confidential, and we will maintain such confidentiality and protect your information in accordance with this privacy policy, our professional obligations and applicable law. We do not sell, rent, distribute, or otherwise make, personal information commercially available to any third party. We may share information with our service providers for the purposes set out in this privacy policy.
INFORMATION SECURITY
We have implemented reasonable administrative, technical and physical measures to protect your personal information against loss, misuse and alteration.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION
We will retain your personal information for the length of time needed to fulfil the purposes for which it was collected(as outlined in this Policy) unless a longer retention period is required or permitted by law.
Your personal information that is processed for marketing purposes will be stored until you exercise the right to withdraw consent, and once such right is exercised, your personal information will be kept only during the applicable statute of limitations period for any disputes or liabilities that may arise as a consequence of the processing of that information (which is up to 15 years in the UAE). Once potential actions are time-barred we will proceed to delete the personal data. In any other circumstances, we will only retain your personal information for a shorter or longer period as required by any applicable law.
CHANGES TO THIS PRIVACY POLICY
We may from time to time make changes to this Privacy Policy to reflect changes in our business, website, data protection law, or other factors that affect your privacy. We will notify you about material changes to this Policy by placing a notice on our website at www.soorcapital.com.
We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information. This policy was last updated on March 16, 2025 and supersedes the previous version.
CONTACT DETAILS
If you have any questions about this Privacy Policy, or our processing of your personal data, please contact us at:
SOOR CAPITAL MANAGEMENT (DIFC) LIMITED
Dubai International Financial Centre
Gate Village 8, Level 3, Unit 6, DIFC
Dubai, UAE
Email: info@soorcapital.com
For data protection specific inquiries, please also use the email address above.
