Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Safanad, the investment manager of Safanad Inc. (together with its affiliates, the “Company”, “us” or “we”), on behalf of Safanad Inc. and its affiliates, and sets forth the policies of the Company with respect to the collection, use, sharing and protection of the personal information of the Company’s prospective, current, and former clients and investors, including non-public personal information (“NPPI”) collected in connection with our delivery of financial products and services. 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.
What personal information we collect, and how we do so
We collect personal information, such as your name, address, telephone number, 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 Company’s representatives; or (iii) make transactions with the Company, 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.
Why we process your personal information, and the applicable legal basis
We process the personal information that we collect for the following purposes:
- For our everyday business purposes— such as to process your transactions, maintain your account(s), or report to credit bureaus. In these instances, we base our processing of personal information on our fulfilment of our contract with you (Article 6(1)(b) of the GDPR).
If you do not provide us with access to this information, we may be unable to offer you our services and execute your orders.
- For other legitimate business purposes of us and our affiliates – to evaluate your creditworthiness, learn about your experience, and for other customer relations purposes which are based on your and our legitimate interests in monitoring and improving the services that we offer (Article 6(1)(f) of the GDPR).
- For our individual or joint marketing purposes— to offer our products and services to you. In these cases, we will rely on your and our legitimate interests in offering and receiving our services (Article 13 of the e-Privacy Directive), or on consent (Article 6(1)(a) of the GDPR), in the event that you are not a current client or investor.
When our processing of personal information is based on your consent, you may withdraw your consent at any time, without affecting the lawfulness of the processing based on your consent before your withdrawal.
- To respond to court orders and legal investigations – processing for these purposes may be based on the need to comply with legal obligations (when the obligation derives from EU law; Article 6(1)(c) of the GDPR) or on the legitimate interest of the Company to comply with foreign laws.
We may also process your personal information (e.g., IP addresses, device information, cookies) when you browse and navigate through our website, www.Safanad.com. We process this information in order to enable you to use our website, and to log visits and improve the site and the services offered through it (Article 6(1)(f) of the GDPR). You can learn more about how we process and use this information in our Cookies Policy.
How we protect and retain your personal information
To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law. These measures include computer safeguards and secured files and buildings, among other technical and organizational measures. Any information held by Safanad (Dubai) Limited is held in accordance with the Data Protection Law, DIFC Law No. 5 of 2020.
In accordance with our document retention policy, your personal information will be stored for as long as our contractual relationship is ongoing, and for at least a sufficient number of years thereafter in order to ensure the Company’s compliance with legal obligations in each of the jurisdictions in which it is active.
How we may share your personal information
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, including brokers, fund administrators, accounting support firms and compliance/operational support providers) for our everyday business purposes, such as to process your transactions, provide advisory services, 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 Company’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 Company may retain.
You cannot limit this type of sharing under U.S. federal law, but if such a disclosure is made, the Company will require such third parties to treat your private information with confidentiality. When personal information subject to the GDPR is processed and shared, the Company will rely on adequacy decisions, standard contractual clauses and/or other mechanisms to safeguard the personal information transferred.
We may also share information with our affiliates to market to you. You may prevent this type of sharing by emailing us at firstname.lastname@example.org. 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.
Disclosure pursuant to U.S. federal law regarding sharing of NPPI
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.
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.
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.
Who is providing this notice?
|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 bureaus||Yes||No|
|For our marketing purposes— to offer our products and services to you||Yes||No|
|For joint marketing with other financial companies||Yes||No|
|For our affiliates’ everyday business purposes— information about your transactions and experiences||Yes||No|
|For our affiliates’ everyday business purposes— information about your creditworthiness||No||We don’t share this information|
|For non-affiliates to market to you||No||We don’t share this information|
Companies related by common ownership or control. They can be financial and non financial companies. Our affiliates include companies with a Safanad name.
Companies not related by common ownership or control. They can be financial and non financial companies. Non-affiliates we share with can include your broker or agent, or service providers or financial companies who maintain or service customer accounts for the Company.
A formal agreement between non affiliated 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 non-affiliates to market to you
State laws and individual companies may give you additional rights to limit sharing.
If you are a resident of the European Economic Area (“EEA”) or the United Kingdom (“UK”), or if your personal information is processed by one of our affiliates in the EEA or the UK, you have the following rights regarding the Company’s processing of your personal information:
- You have the right to request access to, rectification of, and erasure, of your personal information.
- You have the right to object to or to request the restriction of our processing of your personal information.
- You have the right to request the portability of your personal information.
- You have rights with respect to automated decision making or profiling.
Any requests to exercise these rights may only be made effective insofar as the relevant personal information and the purposes of data processing are compatible with the exercise of such rights.
If you are dissatisfied with the manner in which we have processed your personal information and wish to lodge a complaint, you may contact us, and you also may make a complaint to the supervisory authority of the country where our affiliate has provided you with services or where you reside.
If you have any questions about this Privacy Notice, or wish to exercise any of the above rights, email email@example.com or contact us:
Safanad Inc. 505 Fifth Ave, 24th Floor New York, NY 10017 +1 212 468 5600
Safanad (Dubai) Limited 4th Floor The Gate (East Wing) DIFC, Dubai, UAE +971 4 312 9700
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With respect to the Google Analytics cookies, please note that Safanad has entered into a data processing agreement with Google that provides that the last octet of your IP address is masked when Safanad provides information to Google, that it does not use any other Google services in combination with Google Analytics cookies and that it does not share any data with Google for advertisement purposes. To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.
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