ALMHA CAPITAL PRIVACY POLICY

Almha Capital Limited appreciates your visit to this website and your interest in our philosophy and services. Your privacy is of utmost importance to us. This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from  from www.almhacapital.com (the “Site”).

The responsible and lawful handling of your Personal Information is an important concern for us. To this end, we take appropriate precautions (e.g. implementation of technical and organizational security measures such as password encryption and authentication technologies, access management, sensitization and training of employees, appointment of a data protection officer).

This Privacy Policy contains information about how we process your Personal Information when you use our products and services, visit the Site, or register for a service and provide information about yourself.

Before you register for or use our services, or before you provide any Personal Information, please read our Privacy Policy carefully. Any additional terms and conditions that apply to our services will be communicated when you register for those services.

If you have any questions regarding the processing of your Personal Information or would like to exercise your data subject rights, you are welcome to contact our data protection officer via the contact form on the Site.

PERSONAL INFORMATION

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.” When we talk about “Personal Information” in this Privacy Policy, we are talking both about “Device Information”.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and communications). We process the different categories of Personal Information (e.g. customer data, prospective customers, website users, suppliers, etc.). limiting their processing to a necessary minimum and in accordance with applicable laws and regulations.

We have no intention to collect sensitive data such as ethnic origin, political opinions, religious or similar beliefs, etc. (also called special category data), unless specifically required by applicable law.

We may process Personal Information as described above for the provision of our services or for our own lawful purposes and to the extent permitted by law. This includes in particular:

  • processing, improvement, management and execution of our products and services (for example, accounts, payments, cards, financing, invoices, investments, financial planning, e-banking), as well as for updating the data of persons with whom we have business relationships.
  • product and service development, business decisions, statistics (e.g. evaluation and development of existing products, services and processes, determination of key figures for services and utilization figures).
  • management and monitoring of business-related decisions and risks (e.g., investment profiles, market. credit and fraud risks).
  • compliance with legal and/or regulatory disclosure and reporting obligations to authorities and courts (e.g. automatic exchange of information with foreign tax authorities, orders of courts and public prosecutors, bankruptcy and debt collection offices).
  • market research, marketing, comprehensive customer support, information about services and products offered (e.g. customer events, determination of customer satisfaction, online and print advertisements, sponsoring).
  • protection of our interests and rights in case of claims against us or our employees and customers.

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here. 

In certain circumstances, we may or must outsource business areas and services in whole or in part to third party service providers (e.g. payment transactions, subscription and redemption of fund units, printing and mailing of bank receipts, IT systems and other support functions). In such cases, we generally use third party service providers in jurisdictions where the relevant laws and regulations provide adequate protection of Personal Information. If Personal Information must be passed on to third party service providers, the corresponding service providers are also bound by client confidentiality and other applicable regulations, in particular data protection regulations. For this purpose, we take the appropriate measures (e.g. by means of a contract which obligates the third party service provider to process the relevant personal data exclusively on our behalf and in accordance with our instructions).

Except for the reasons/purposes described in this privacy policy, no Personal Information will be disclosed to third parties without the consent of the data subject.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

DATA STORAGE AND RETENTION PERIODS

If you have provided Personal Information to us, that information will be stored securely for the purposes stated in this Privacy Policy and for the purposes for which the information was provided.

We as well as our third party service providers use appropriate technical and organizational measures to protect your personal data from loss and unauthorized access.

We will retain your Personal Information for as long as is necessary for the purposes for which it was collected, we are required to do so by law, or we have a legitimate interest in retaining it (e.g., for evidentiary purposes, IT security, etc.).

RIGHTS

Under the ADGM Data Protection Regulations 2021, you have certain rights in respect of your Personal Information as follows: 

a)    Access: you have the right to be informed of, and request access to, the Personal Information we process about you.

b)    Rectification: you have the right to request that we amend or update your Personal Information where it is inaccurate or incomplete.

c)    Erasure: you the right to have us delete your Personal Information.

d)    Restriction: you have the right to request that we temporarily or permanently stop processing your Personal Information.

e)    Information: you have the right to request clarification as to the reasons why your Personal Information is being collected, and the identity of the recipients to whom your Personal Information has been disclosed.

f)     Objection: you have the right to object to us processing your Personal Information on grounds relating to your particular situation or for direct marketing purposes.

g)    Portability: you have the right to request a copy of your Personal Information in electronic format and the right to transmit that personal data for use in another party’s service.

h)    Automated Decision Making: you have the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

We shall endeavour to apply your rights following any justified request to that effect on your part and to the extent that our legal and other obligations are not thereby infringed or restricted.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons for example, resulting of changes in the law or in the way personal data is processed. In this case, the new version of the Privacy Policy will be published on our Site or made available to you in another appropriate manner.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected] or by mail using the details provided below:
1017 Al Khatem Tower
Al Maryah Island ADGM
Abu Dhabi, UAE