This Privacy Policy (the “Policy”) forms part of Dhabi Ltd. Terms and Conditions (“Dhabi” or “we“, or “us“), and applies to you (“you” or “data subject”) if you are:

• an employee, consultant, contractor, legal representative, shareholder, (potential) investor, beneficial owner, board member, signatory, officer, agent or promoter of:
• a client (which may be an individual or a legal person);
• a prospective client;
• a client or counterparty of our clients(s); or
• a counterparty;

To the extent that the client is a company and provides Dhabi with personal data of its data subjects, the client warrants that it has obtained effective written consent(s) from the data subjects in respect of Dhabi’s use of such personal data, and that the client undertakes to provide Dhabi with a copy of any such consent(s) upon its request.

In certain circumstances, we collect information about you even if we do not have a direct relationship with you i.e. we obtain with your permission from publicly accessible sources (like press and internet) or from other third parties (e.g. credit rating agency, banks, brokers, exchanges, trade repositories, processing units and third-party custodians, issuers, authorities, and their representatives). The Policy sets how and why we collect, store, use and share your personal data. It also tells you about privacy rights and how you can contact us if you have any suggestions, questions and concerns about how we handle your personal data when using Dhabi website or application via electronic devices (collectively referred to as the “Applications”). This Policy forms an integral part of our Terms and Conditions.

For the purpose of applicable data protection law, Abu Dhabi Global Market  Data Protection Regulations 2021 (“DPR”), Dhabi is the data controller of your personal information. If you have any questions about this Policy, or our processing of your personal data please contact us at:

Email: support@dhabi.com and

Telephone: (+971) 2 619 4444.

1.1     Personal Data

Personal data is information that we have about you includes information like your name, date of birth and your email address and phone number and nationality), identification data and authentication data (e.g. sample signature), order data (e.g. payment instructions), data from the fulfillment of our contractual obligations (e.g. data in payment transactions), information about your financial situation (e.g. creditworthiness data, scoring/rating data, origin of assets, source of wealth), marketing and sales data, documentation data (e.g. file notes or meeting minutes from a consultation), and other data similar to the categories mentioned.

When you use your account, we get more information about you. Here are some examples.

• When you use your card to pay for things (if applicable), we collect information including the date, where you are and the amount you spend.
• We use ‘cookies’ to understand how people use our Applications. We like to know who uses our Applications, and how we can make them better.
• When you email us, we will ask you some questions so we can make sure it’s you emailing us and not somebody else. You should always be careful about what you write in any emails. Don’t tell us anything more than you need to give us or give us any information that could be used in a bad way by somebody else. If we need you to tell us something, we will ask you for it. You can trust us to look after your personal data. There are laws that make sure we protect it and can’t use it for anything that is bad for you.

1.2     Information Collection and Usage:

In general, any personal data which you provide to Dhabi over the Applications, or which is otherwise gathered via the Applications by Dhabi, in the context of the use of Dhabi products and services will be processed by Dhabi in a lawful, fair, and transparent manner and according to the DPR. Dhabi policies have been adjusted to ensure all applicable personal data will be treated in accordance with the provisions of the DPR. In addition to the above disclosures, the following applies to data subjects protected by the DPR:

• In case of transfers of personal data outside the ADGM, we make sure to transfer your personal data to countries and regions that provide sufficient level of protection for your personal data. Such transfers, to the extent practicable, shall be in accordance with any applicable lists recognized by the ADGM Data Protection Office.
• In some instances, we may be required to transfer your personal data to other countries whose level of protection has not been recognized by the ADGM commissioner. In such cases, we may rely on (i) your written consent. (ii) the exceptions provided by the DPR (e.g. transfers subject to appropriate safeguards, binding corporate rules…etc.); as well on (iii) sufficient guarantees regarding the measures to protect the confidentiality and security of the personal data.
• We shall notify you without undue delay in case of a data breach that would likely result in a high risk to your data rights.
• Every data subject has in relation to their personal data the following rights under the DPR:

1. The right of access
2. The right to rectification
3. The right to erasure
4. The right to restriction of processing
5. The right to data portability
6. The right to object
7. right in case of automated individual decision making including profiling

In some instances, we may be exempted from complying with your request to rectify or erase data, where such rectification or erasure of personal data is not technically feasible, we must provide explicit, clear and prominent information explaining that rectification or erasure of the personal data would not be feasible.

Where the basis for the processing of your personal data is consent, you have the right to withdraw your consent by directly contacting us by either of the methods set out in this Policy. The withdrawal of consent will not without affect the lawfulness or legality of processing personal data prior to withdrawal.

You have a right to file a complaint with us or any ADGM Data Protection Office about an alleged contravention of the protection of your personal information. If you wish to exercise the rights listed above or to raise any queries, you may send an email to the following address: support@dhabi.com.

To this end, and as further described below, Dhabi takes into consideration internationally recognized principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimization, data quality and confidentiality together with DPR.

We process information that we obtain from you in the context of our business relationship (including but not limited to monitoring operations and transactions to manage, prevent and detect fraud, monitor and report risks such as financial legal, compliance, operational risks etc..) and record transactions for accounting reasons. We also process insofar as necessary to provide our services and-constantly improve upon the services. We also process your personal data for anti-money laundering and countering of the financing of terrorism purposes for the compliance with legal and/or regulatory obligations to which we are subject. We may process your personal data for the purpose of our legitimate interests.

We may share the information we collect with third parties as follows or as otherwise described in this Policy:

• with credit and financial institutions or comparable institutions in order to carry out a business relationship with you. With consultants, merchants, and other relevant third parties involved in the utilization of the Applications when necessary to carry out work or provide services on our behalf in relation to the service;
• in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process;
• in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company; and
• between and among Dhabi and any current or future parent, subsidiary and/or affiliated company.

This Policy does not describe information collection practices of other sites, including those linked to, or from, the Applications. Please note that Dhabi is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third-party websites.  You must always carefully review the privacy and confidentiality policy of any third-party website that you may visit in order to understand how the operators of that website may collect, store and use your personal information.

The server on which the Applications is located collects and saves only default information customarily logged by web server software. Information may include the date and time of your visit, the originating IP address, and pages and images viewed.

It may also be possible for you to review and change contact information such as address, phone and e-mail information. To protect your privacy, proof of identity or other authentication is required any time once you contact us.

We may use personal information to provide the products and services you have requested, including services that display customized content and advertising.

We may use personal information for auditing, research and analysis to operate and improve our technologies and services; we may share aggregated non-personal information with third parties outside of the Applications.

When we use third parties to assist us in processing your personal information, we require that they comply with our Policy and any other appropriate confidentiality and security measures. We may also share information with third parties in limited circumstances, including when complying with legal process, preventing fraud or imminent harm, and ensuring the security of our network &services.

The Applications process personal information on servers in the United Arab Emirates.

We will hold and store all consumer and transaction data within the United Arab Emirates. Additionally, we also establish a safe and secure backup of all the consumer data and transactions in a separate location for the required period of retention i.e. 5 years.

We will process and store your personal data for as long as it is necessary in order to fulfill our contractual, regulatory and statutory obligations. It should be noted here that our business relationship is a long-term obligation, which is set up on the basis of periods of year.

1.3     Security of Transactions:

Please be assured that the Applications has security measures in place to protect the information you provide us. We use encryption methods to protect personal data, or any other data that should remain secure to meet Dhabi’s legal requirements.

1.4     Cookies:

Cookies enable websites to remember who you are. Information from cookies may include information relating to your use of our websites, information about your computer (such as IP address and browser type), and demographic data. We collect process and analyze traffic data regarding the use of our webpages. Traffic data is data connected to visitors on the webpage and data handled in communication fields for sending, distributing or making messages available. The

Applications, and third-party advertisers, may use cookies

You can set or amend your web browser controls to accept or reject cookies. If you choose to reject cookies, you may still use our websites and some Services, however your access to some functionality and areas of our website or Services may be restricted substantially.

1.5     Privacy Policy Changes:

Dhabi reserves the right to change this Policy at any time. The amended version of the Policy will be always published only on the Applications.

1.6  Privacy intrusion:

If you suspect/feel that your privacy is being compromised, follow these steps immediately:

• Close all browsers;
• Change your password immediately;
• Inform us by email on support@dhabi.com or phone on (+971) 2 619 4444.

If you elect not to receive promotional emails or messages regarding Dhabi products and services, you may elect to (‘opt out’) from receiving any further promotional emails or messages by clicking on the “opt out” sign which you will find in the email or message received.