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 our past, present and prospective Customers/Vendors/ Employees/advisors, consultants ; or Anyone involved in any transaction or interaction with us, whether it is in your personal capacity or as a representative of a legal entity (for example, director, a company manager, agent, legal representative, operational staff, other authorized representative, etc.) (“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 your personal information:

From the information you provide to us when you meet or interact with us;
When you communicate with us by telephone, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
When you complete (or we complete on your behalf) client on-boarding or application or other forms;
From your agents, advisers, intermediaries, and custodians of your assets; or
From publicly available sources or from third parties, most commonly where we need to conduct background checks about 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).

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.

SHARING YOUR INFORMATION

To provide you with our services, we share certain data within our group or externally with third parties. Whenever we share your personal data externally with third parties in countries without a deemed adequate level of protection for personal data, we ensure that necessary safeguards are in place to protect them.

To comply with our regulatory obligations, we may disclose personal data to the relevant government, supervisory and judicial authorities after reasonable caution and diligence.

When we use other service providers or third parties to carry out certain activities in the normal course of business, we may have to share personal data required for a particular task. The service providers include:

(i) IT service providers who may provide application or infrastructure (such as cloud) services;

(ii) Legal, auditing or other special services provided by lawyers, notaries, trustees, administrators, company auditors or other professional advisors;

(iii) Identifying, investigating, or preventing fraud or other misconduct by specialized companies.

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.

YOUR RIGHTS

We respect your individual rights to determine how your personal data is being used. You have the below 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 to the applicable supervisory or data protection authority; and
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

Are you obliged to provide us with your personal data

In some cases, we are legally required to collect personal data, or your personal data may be needed before we may perform certain services and provide certain products. We undertake to request only the personal data that is strictly necessary for the relevant purpose. Failure to provide the necessary personal data may cause delays or lead to refusal of certain products and services.

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 take appropriate technical and organizational measures (policies, procedures, IT security, etc.) to ensure the confidentiality and integrity of your personal data and the way it is processed. We apply an internal framework of policies and minimum standards across our business to keep your personal data safe. These policies and standards are periodically updated to keep them up to date with regulations and market developments.

In addition, our employees are subject to confidentiality obligations and may not disclose your personal data unlawfully or unnecessarily. To help us continue to protect your personal data, you should always contact us if you suspect that your personal data may have been compromised.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal information transmitted to us or provided though the website and any transmission is at your own risk.

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).

Where we have collected your personal data as required by anti-money laundering legislation, including for identification, screening and reporting, we will retain that personal data for six years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings; or

Otherwise, we will in most cases retain your personal data for a period of ten years after the termination of our contractual or other relationship with you in case any claims arise out of the provision of our services to you.

When your personal data is no longer necessary for a process or activity for which it was originally collected, we delete it, or bundle data at a certain abstraction level, render it anonymous and dispose it in accordance with the applicable laws and regulations.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Statement to remain compliant with any changes in law or to reflect how our business processes personal data. This version was created and published at the end of March 2021 and enters into force from 1st day of April 2021.

CONTACT DETAILS

If you have any questions about this Policy, or our processing of your personal data, please contact us at: info@soorcapital.com

SOOR CAPITAL MANAGEMENT (DIFC) LIMITED

Dubai International Financial Centre

Gate Village 8, Level 3, Unit 6, DIFC

Dubai, UAE.