This policy
This policy outlines the personal data we may collect, how we process and safeguard it, the legal basis for processing, and your associated rights. Under the EU General Data Protection Regulation 2016/679 (GDPR), “personal data” refers to any information that identifies or can identify a natural person, either directly or indirectly, when combined with other information.The lawful bases for processing personal data typically include:
(i) Compliance with legal obligations (“Legal Obligation”),
(ii) Fulfillment of a contract with you (“Contract”), or
(iii) Pursuit of our legitimate business interests, such as raising and investing funds, maintaining
and improving our services, and marketing our products, provided these interests do not override
your rights (“Legitimate Interests”).

When processing is based on your consent (“Consent”), we will clearly outline the purposes of the processing and provide all relevant information to ensure transparency and fairness.
As data protection laws and practices evolve, this policy will be updated periodically. Updates will be published on our Website and take effect from the stated date. It is your responsibility to review the Website regularly for any changes.

How Do We Obtain Personal Data?
We collect or receive personal data in the normal course of our business operations.

Examples include:
• Investment Discussions: You may provide your details when discussing potential investments in our fund.
• Website Visits: We may collect information such as your IP address and the pages you visit when you access our Website.
• Inquiries: You may share your details when inquiring about our funds or other services, whether through the Website, email, or other communication channels.
• Marketing: We may obtain legally compliant lists of potential customers for our funds or services for marketing purposes.

If you provide personal data about yourself or another individual, you confirm that you are authorized to share this information and that the data is accurate and up-to-date.

Sensitive Personal Data
Due to the nature of our business, we do not request, require, or process any “sensitive” or “special categories of personal data.” These categories include, but are not limited to, information about your health, political opinions, racial or ethnic origin, religious or philosophical beliefs, trade union membership, genetic or biometric data, sexual orientation, or sexual life. Such data is not relevant to our operations or services, and we take a strict stance on avoiding its collection.

We kindly ask that you refrain from sending or sharing any such sensitive information with us, whether intentionally or inadvertently, as it is outside the scope of our data processing and unnecessary for our purposes. If sensitive information is provided to us unsolicited, we will take steps to delete it promptly to maintain compliance with applicable data protection laws and to protect your privacy

How do we use personal data?
We utilize personal data as part of our standard business operations. Below are the primary ways we use such data, along with the corresponding lawful bases for processing:

Responding to Inquiries
◦ We use personal data to respond to inquiries about the Company and its Services, provide access to the Websites and Services, and deliver advice and support.
◦ Lawful Basis: Legitimate Interests or Contract.

Marketing Activities
◦ Personal data may be used to market the Company and its Services. If we engage in such activities, we will always provide you with a simple, cost-free method to opt out of receiving future communications.
◦ Lawful Basis: Legitimate Interests (or Consent where applicable).

Investment Activities
◦ We process personal data to explore investment opportunities and to make informed investment decisions on behalf of the Company.
◦ Lawful Basis: Legitimate Interests.

Administrative Purposes
◦ Personal data is used to administer the Company and its Services, including issuing certificates, notices, circulars, and other relevant information to shareholders.
◦ Lawful Basis: Legitimate Interests.

Website and Service Improvement
◦ We analyze personal data to enhance the Website and Services, such as for technical troubleshooting, security purposes, and improving the overall customer experience. Where required by law (e.g., for certain cookies), we will obtain your consent after providing the necessary information.
◦ Lawful Basis: Legitimate Interests (or Consent where applicable).

Sharing with Third Parties
◦ In some cases, we may share personal data with a select group of third parties for specific purposes, including:
▪ Regulatory compliances and Authorities: To comply with legal obligations.
▪ Operational and Business Continuity Needs: To ensure smooth and consistent service delivery.
◦ Lawful Basis: Legal Obligation, Legitimate Interests, or Contract (depending on the circumstances).
By maintaining a clear and lawful approach to personal data usage, we aim to ensure compliance with applicable regulations while safeguarding your privacy.

Sharing Data & International Transfers
We do not sell, rent, or share your personal data with third parties for their marketing purposes. Additionally, we do not accept third-party advertising on our Website. However, we may share personal data under the following limited circumstances:

Operational and Analytical Purposes

◦ To administer, operate, secure, and analyze our Services, we may share personal data with our Investment Adviser and other professional advisors.
◦ Lawful Basis: Legitimate Interests or Contract.

Service Provision and Business Continuity

◦ To deliver our Services effectively and ensure disaster recovery and business continuity, we may store or transmit personal data via third-party providers, such as contractors and advisors, who assist in operating, securing, and analyzing our business.
◦ Lawful Basis: Legitimate Interests or Contract.
Compliance with Legal Obligations

◦ We may be required to disclose your personal data to comply with applicable laws, court orders, government directives, or requests from competent legal or regulatory authorities.
◦ Lawful Basis: Legal Obligation.
Business Transactions

◦ If we enter negotiations with a third party regarding the sale or purchase of all or part of our business, personal data may be disclosed to the extent necessary for the transaction. Any such disclosure will be made under strict confidentiality agreements binding the third party to our privacy policy.
◦ Lawful Basis: Legitimate Interests.
Data Sharing Standards and International Transfers
◦ In all cases, we only share the minimum amount of personal data necessary for the stated purpose. We maintain written contracts with recipients that include safeguards to protect personal data and ensure compliance with applicable laws.
◦ Whenever possible, we keep personal data within the UAE jurisdiction. However, to fulfill operational requirements, we may use ASquare branches, service providers, or facilities located outside the UAE. In such instances, we implement robust security measures to protect your personal data, ensuring compliance with applicable laws and the presence of a valid legal basis for the transfer.

By adhering to these principles, we aim to protect your personal data while fulfilling the requirements of our business operations and legal obligations.

Cookies
Our Website utilizes cookies and similar technologies to enhance user experience and functionality. For detailed information, including options to refuse or selectively manage cookies and similar technologies, please refer to our Cookie Policy, which is an integral part of this Privacy Policy.

Retention
As a default position, we will only retain personal data for any statutory retention period, then a reasonable period (if any) necessary for the above purposes. This is subject, for example, to any valid opt-out or withdrawal of consent where processing is based on consent, or other valid exercise of your data subject rights which is affected.

Security
By default, we retain personal data only for the duration of any applicable statutory retention period, followed by a reasonable timeframe necessary to fulfill the purposes outlined in this policy. This retention may be adjusted in response to valid opt-outs, withdrawal of consent (where processing is based on consent), or the exercise of other applicable data subject rights.

Anonymised data
We may generate anonymized data from personal data, and such anonymization will be conducted in compliance with applicable laws and relevant guidelines under UAE regulations. Anonymization may involve processes such as aggregating data to a level where no individual can be identified, like compiling website usage statistics to assess which content is effective and which may need improvement. Once anonymized, the data no longer qualifies as personal data and, as such, is no longer subject to data protection laws or this Privacy Policy.

Third Party Services
If you access services provided by another provider through our website or services, such as via a link on our site, your use of those services is solely at your own risk and will be subject to the terms and privacy policy of the third-party provider.

Your rights
You have the right to inquire whether we process any personal data about you, and, subject to certain limitations, request a copy of that personal data. Additionally, you have the right to request the correction or deletion of any inaccurate personal data, object to specific processing activities, and withdraw any consent you may have provided for the processing of your personal data. You also have the right to request restrictions on the processing of certain personal data, request the erasure of your personal data, and request that certain personal data be transferred to you or another provider, provided that we hold such data and certain conditions are met. You have the right to object to the processing of your personal data for direct marketing purposes at any time.

‘Do Not Track’
The Website does not utilize technologies that respond to ‘Do-Not-Track’ signals sent by your internet browser.

Contact Us
If you have any questions, feel free to contact us via email at info@AsquareC.com. You have the right to file a complaint at any time, although we encourage you to reach out to us first, as we would appreciate the opportunity to address and resolve any concerns directly with you