Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Safanad, the investment manager of Safanad Inc. (the “Partnership”), on behalf of the Partnership, and sets forth the policies of the Partnership with respect to the collection, sharing and protection of non-public personal information of the Partnership’s investors, prospective investors and former investors. These policies apply to individuals only and may be changed at any time, provided a notice of such change is given to you. Please read this Privacy Notice carefully to understand what we do.

We collect personal information, such as your address, social security number, assets, transaction and/or income information, for example, when you: (i) provide it to us in the Subscription Agreement and related documents; (ii) provide it to us in correspondence and conversations with the Partnership’s representatives; or (iii) make transactions with the Partnership, such as when you purchase securities from us, tell us where to send money or make a wire transfer. We also may collect your personal information from other sources, such as affiliates.

The Firm will not disclose clients’ and investors’ non-public personal information or that of any former clients to third parties other than affiliates and/or other third party firms that assist the Firm in providing advisory services and/or effecting client transactions (such as brokers, fund administrators, accounting support firms and compliance/operational support service providers).

Safanad is committed to employing reasonable steps to procure the safeguarding of the personal information which you may provide to it through this Website and, to the extent that Safanad collects any personal information. Any information held by Safanad (Dubai) Limited is held in accordance with the Data Protection Law, DIFC Law No. 1 of 2007.

We may disclose information about our investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary, under anti-money laundering and similar laws, to disclose information about the Partnership’s investors in order to accept subscriptions from them. We will also release information about you if you direct us to do so. We do not share your information with non-affiliates for them to market to you. We may disclose your information for our own marketing purposes, such as to offer our products and services to you. We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes. You cannot limit these types of sharing.

We may also disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent the Partnership may retain.

You cannot limit this type of sharing under federal law, but if such a disclosure is made, the Partnership will require such third parties to treat your private information with confidentiality.

We may also share information with our affiliates to market to you. You may prevent this type of sharing by emailing us at info@safanad.com. If you are a new investor, we can begin sharing your information 30 days from the date we sent this Privacy Notice. When you are no longer our investor, we may continue to share your information as described in this Privacy Notice. However, you may contact us at any time to limit our sharing. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. State laws may give you additional rights to limit sharing.

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

Safanad Inc. (collectively with its affiliates, the “Company”, “Us” or “We”) is committed to handling information regarding its partners responsibly.

 

Facts

What does the Company do with your personal information?

Why?Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Social Security number and investment experience
  • Wire transfer instructions and account transactions
  • Assets and income.

When you are no longer our customer, we continue to share your information as described in this notice.

How?All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons the Company chooses to share; and whether you can limit this sharing.

 

Reasons we can share your personal information

Does the Company share?

Can you limit this sharing?

For our everyday business purposes— such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureausYesNo
For our marketing purposes— to offer our products and services to youYesNo
For joint marketing with other financial companiesYesNo
For our affiliates’ everyday business purposes— information about your transactions and experiencesYesNo
For our affiliates’ everyday business purposes— information about your creditworthinessNoWe don’t share this information
For nonaffiliates to market to youNoWe don’t share this information

 

Who we are

Who is providing this notice?The Company

 

What we do

How does the Company protect my personal information?To protect your personal information from unauthorized use and access, we maintain security measures that comply with federal law, including computer safeguards and secured files and buildings.
How does the firm collect my personal information?We collect your personal information, for example, when you

  • Open an account
  • Give us your contact information
  • Give us your income information
  • Make a wire transfer
  • Tell us where to send the money

We also collect your personal information from others, such as credit bureaus, affiliates or other companies.

Why can’t I limit all sharing?Federal law gives you the right to limit only:

  • sharing for affiliates’ everyday business purposes—information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

What happens when I limit sharing for an account I hold jointly with someone else?Your choices will apply to everyone on your account – unless you tell us otherwise.

 

Definitions

AffiliatesCompanies related by common ownership or control.  They can be financial and nonfinancial companies.
Our affiliates include companies with a Safanad name.
NonaffiliatesCompanies not related by common ownership or control.  They can be financial and nonfinancial companies.

Nonaffiliates we share with can include your broker or agent, or service providers or financial companies who maintain or service customer accounts for the Company.

Joint marketingA formal agreement between nonaffiliated financial companies that together market financial products or services to you.

Our joint marketing partners include the Company’s placement agents, if any.

Why can’t I limit all sharing?Federal law gives you the right to limit only:

  • sharing for affiliates’ everyday business purposes—information about your creditworthiness
  • affiliates from using your information to market to you
  • sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

 

If you have any questions about this Privacy Notice, email info@safanad.com.