Introduction
This Privacy Notice explains how Alkhair Capital (Dubai) Ltd (“ALKHAIR”, “we”, “us”, “our”), collects, uses, shares and otherwise processes your Personal Data in connection with your relationship with being generally interested in our services, seeking employment opportunities with us and our marketing materials in accordance with applicable data privacy laws and regulations relevant to your jurisdiction, such as the Data Protection Law, DIFC Law No.5 of 2020 (“DPL”).
This Privacy Notice is meant to inform you about the information we collect about you and how that information will be used. If you have additional questions about ALKHAIR’s data collection practices after reading this notice, please Contact Us or directly contact our DPO at dp@alkhaircapital.ae.
We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. Those supplemental notices should be read together with this Privacy Notice.
This statement may be updated from time to time. We therefore ask you to consult it on a regular basis. The last line of this Privacy Notice indicates when the Statement was last updated. ALKHAIR reserves, in its sole discretion, the right to revise this Privacy Notice at any time by updating this posting.
General principles
We are committed to keeping your information private. By 'Your information' we mean any information about you that you or third parties provide to us. All personal data is treated as highly confidential. Personal data is shared on a ‘need to know’ basis in line with this privacy notice and in keeping with the general principles of the DIFC Data Protection Law No. 5 of 2020 and its associated regulations and other applicable laws. The Client’s personal data is only shared with third parties if we have a lawful basis to do so.
Be aware that on some occasions, where you do not provide information to us we will not be able to enter into a relationship with you as we require that information to contact you or as part of our legal obligations.
Purpose and Scope
ALKHAIR is committed to safeguarding the personal information that we collect about our potential clients, clients,, employees , candidates for employment and internship opportunities, suppliers, business partners, authorized signatories and representatives . Accordingly, we have developed this statement to describe how and what type of data will be collected and the purposes for which ALKHAIR may collect, share or disclose the data. ALKHAIR also outlines reasonable precautions which are taken to keep your data secure.
This Privacy Notice applies to any information obtained by ALKHAIR. It is not applicable to any Internet websites controlled by third-parties not affiliated with ALKHAIR that the website may link to (“third-party-websites”). Please review the privacy statements of third-party websites as ALKHAIR is not responsible for and has no influence on the content or the privacy practices of third-party websites.
The term “Personal Data” as used in this Privacy Notice means any information relating to you such as your name and professional contact details such as your business address, business email address and telephone number and information such as your job title. It may also include bank details and details related to KYC such as your passport as our relationship progresses as the applicable law requires. We will always collect data in line with the ‘data minimization’ principle which means that we will only collect data that we require at the stage we need it. Personal Data does not include data from which you can no longer be identified such as anonymized aggregate data.
Legal basis for collection
We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data as follows:
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Personal data type: |
Purpose:
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Personal information such as gender, name, date of birth and address |
- To meet our anti money laundering (AML) and other regulatory obligations in relation to Know Your Client (KYC) and client due diligence. To verify your identity using our verification processes. - In order to enter into a contract with you at your request or to perform our contract with you. - To meet our obligations under an applicable law. - For our legitimate interest to provide company updates, provide marketing material, notify of changes to service terms and to peruse potential candidates for employment opportunities. |
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Contact information (email address and phone number)
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- To meet our anti money laundering (AML) and other regulatory obligations in relation to Know Your Client (KYC) and client due diligence. - To verify your identity using our verification - Processes. - In order to enter into a contract with you at your request or to perform our contract with you. - To meet our obligations under an applicable law. - For our legitimate interest to provide company updates, provide marketing material, notify of changes to service terms and to peruse potential candidates for employment opportunities. |
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Employment information, financial information, relevant education and trading experience
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- To meet our anti money laundering (AML) and other regulatory obligations in relation to Know Your Client (KYC) and client due diligence. - To verify your identity using our verification processes. - To meet our obligations under an applicable law. - For our legitimate interest to peruse potential candidates for employment opportunities. |
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Citizenship and social security numbers or national identity and passport numbers |
- To meet our anti money laundering (AML) and other regulatory obligations in relation to Know Your Client (KYC) and client due diligence. - To verify your identity using our verification processes. - To meet our obligations under an applicable law. |
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Proof of photo ID, address verification |
- To meet our anti money laundering (AML)and other regulatory obligations in relation to Know Your Client (KYC) and client due diligence. - To verify your identity using our verification processes. - To meet our obligations under an applicable law. |
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Unique device number (IP address) and device information including version of web browser you use |
- In order to enter into a contract with you at your request or to perform our contract with you. - For our legitimate interest to tailor your website experience to our preferences, and for our research and website development. |
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Financial sanctions and credit header information
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- To meet our anti money laundering (AML) and other regulatory obligations in relation to Know Your Client (KYC) and client due diligence. - To verify your identity using our verification processes. - To meet our obligations under an applicable law. |
| Security measures, including capturing images by CCTV |
- For our legitimate interest for information security and physical security purposes. |
We do not intend to rely on consent for processing your data. Where we do need to rely on consent, we will provide a separate Privacy Notice to you.
Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
Rights Under the Law
You have the following rights with respect to your personal data:
· The right to access your personal data,
· The right to request that your personal data regarding is corrected if it is found to be inaccurate,
· The right to request that your personal data is erased where it is no longer necessary,
· The right to withdraw consent to processing at any time, where relevant,
· The right to restrict processing where there is a dispute in relation to the accuracy or processing of the personal data,
· The right to request that we provide you with your personal data and where possible, transmit that data to another data controller. This applies only where the processing is based on consent or is necessary for the performance of a contract with the us and in either case where we process the data by automated means.
· The right to object to the processing of your personal data, which only applies where processing is based on legitimate interest,
· The right not to be subject to a decision which is based solely on automated processing, including profiling which produces legal effects concerning them or which significantly affects them.
We will act on your request promptly unless we have an additional legal basis to continue processing your data which overrides your rights. We may need to verify your identity before we can action a request.
Should you have a request regarding the processing of your personal data please contact us by:
ALKHAIR CAPITAL (DUBAI) LTD
Emirates Financial Towers
North Tower - 9th floor
DIFC, Dubai
United Arab Emirates
Data sharing
Alkhair may disclose your information to our group companies and their associated third-party systems which includes Alkhair Capital Saudi Arabia. While conducting business and managing our relationship we may transfer your data to third parties, service providers or agents. These include, but are not limited to banking and financial institutions, custodians, intermediaries, brokers, issuer of securities and depositories. Under specific circumstances we may also disclose your information to professional advisors such as auditors, lawyers and compliance consultants. These disclosures may be made inside or outside your country of residence to perform our services and for the purposes stated above. This may mean that we transfer Personal Data to a jurisdiction that does not have the same level of data protection as the DIFC does.
If we do need to transfer information to anyone outside of an adequate jurisdiction, we shall do so by relying on a lawful derogation or ensuring safeguards are in place. You can find out more about our data protection safeguards, such as standard data protection clauses by contacting the DPO.
We may also disclose your information to governmental agencies or entities, regulatory authorities, or other persons in line with any applicable law, regulations, court order or official request, or under any and for the purposes of any guidelines issued by regulatory or other authorities, or similar processes as either required or permitted by applicable law.
Online service
Information we collect
You’re not required to provide any personal information on this website. However, you may choose to do so by completing the forms on various pages of the site. We’ll only use the information you provide to us on these pages in order to process the relevant form.
If you’re a ALKHAIR customer or already have a relationship with us, you will have been advised by various methods about how we collect and use your information.
Use of cookies
Cookies are text files that are stored and stored on a computer system via an internet browser.
Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie, which consists of a string through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This enables the visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A particular internet browser can be recognised and identified via the unique cookie ID.
Cookies in use
ALKHAIR website uses PHP cookies. PHP cookies are saved to your computer to optimize your experience while using the website. If you disable the cookies, the website will use the session time to facilitate user’s login. To disable or enable cookies you will need to change some settings on your Internet browser.
Google Chrome
- In the settings menu, select 'show advanced settings' at the bottom of the page
- Select the 'content settings' button in the privacy section
- In the page that appears tells you can manage and/or clear stored cookies.
Firefox
- In the menu, select 'options'
- Select the privacy tab in the options box
- From the dropdown choose, 'use custom settings for history'. This will present the options for cookies, and you can choose to enable or disable cookies.
Internet Explorer 6+
- In the tools menu, select 'Internet options'
- Click the privacy tab
- You will see a privacy settings slider which has six settings that allow you to control the number of cookies that will be placed: Block All Cookies, High, Medium High, Medium (default level), Low, and Accept All Cookies.
Safari
- In the settings menu, select the 'preferences' option
- Open the privacy tab
- Select the option you want from the 'block cookies' section
Any other browser
- For information on how to manage cookies via other desktop browsers please consult your documentation or online help files.
What happens to cookies that have been downloaded in the past?
If you've disabled through your browser, we may still use information collected from the existing cookies, but we'll stop using the disabled cookies to gather any further information.
Security Measures to Protect your Data
ALKHAIR has implemented reasonable technical and organisational security measures to protect your personal data collected against unauthorized access, misuse, loss or destruction. We have in place internal security policies and procedures, and written contracts with our group companies, third parties, service providers, agents, professional advisors and consultants. We also apply best practice recommendations such as document encryption, confidentiality agreements and password protecting files.
Retention Periods
The retention period we rely on will be in accordance with the applicable laws. Where the law does not provide for a retention period, we will hold your data for as long as is necessary to meet our purpose for processing. Once this period has expired, we will safely and security destroy the data.
Data of minors
Alkhair does not seek to collect Personal Data from individuals under the age of 18. Individuals under the age of 18 should receive permission from their parent or legal guardian before providing any personal data to Alkhair.
Automated decision making and profiling
We do not rely on automated decision making for our services, employment or any other business related to ALKHAIR.
Right to lodge a complaint
If you are unhappy with the way we treat your data you have a right to make a complaint to the Commissioner in the DIFC.
The Commissioner can be contacted by:
Dubai International Financial Centre Authority
Level 14, The Gate Building
DIFC, Dubai, UAE
commissioner@dp.difc.ae
The terms of this Privacy Notice are subject to any additional terms of disclaimers or other contractual terms you have entered with ALKHAIR such as specific privacy statements or notices, and any applicable mandatory laws and regulations.
If you have any questions about this Privacy Notice or wish to contact ALKHAIR in connection with any information contained in this Privacy Notice. Please feel free to contact us as detailed above.
Last updated 18 January 2023.