Privacy Policy

1. Our Obligation

This policy explains how Al Liwan collects, uses, and protects personal data. It applies to clients, prospective clients, company representatives, and shareholders who interact with us or our services.

Al Liwan is committed to handling personal data responsibly and in accordance with the ADGM Data Protection Regulations 2021.

2. Who We Are

Al Liwan is a financial services firm regulated in the Abu Dhabi Global Market (ADGM) by the Financial Services Regulatory Authority (FSRA). We act as the Data Controller for personal data processed in connection with our services.

For any privacy-related queries, please contact us at:

• Email:info@alliwan.com

• Website: www.alliwan.com

3. Information We Collect

We may collect the following types of personal data:

• Identity information: name, passport or ID number, date of birth

• Contact details: address, email address, telephone number

• Financial information: account details, assets, income, and investment history

• Risk profile and suitability information

• Communications: emails, call recordings, and written correspondence

• Compliance and regulatory documents: KYC, AML, and source of funds documentation

We collect data directly from you, from your authorised representatives, and where necessary from third parties such as banks, regulators, or other financial institutions.

4. Why We Collect Your Data

We collect and use personal data to:

• Open and manage client accounts

• Provide investment banking, wealth management, asset management, and family office services

• Meet legal and regulatory obligations including AML, KYC, and FSRA requirements

• Assess client risk and suitability

• Prevent fraud and financial crime

• Communicate with clients about their accounts and our services

We only collect information that is necessary for these purposes.

5. Legal Basis for Processing

We process personal data under the following legal bases as set out in the ADGM Data Protection Regulations 2021:

• Legal obligation: where processing is required to comply with applicable laws or FSRA regulatory requirements.

• Contractual necessity: where processing is needed to deliver services under an agreement with you.

• Legitimate interests: where processing supports our business operations without overriding your rights, such as fraud prevention and risk management.

• Consent: where you have specifically agreed to the use of your data for a particular purpose. You may withdraw consent at any time.

6. Profiling and Decision Making

We may assess client risk and investment suitability as part of delivering regulated financial services. This involves reviewing your financial profile, objectives, and risk appetite.

These assessments are not made solely by automated systems. Human review forms part of all material decisions affecting clients.

7. Who We Share Data With

We may share personal data with trusted third parties where necessary and lawful, including:

• Regulators and government authorities (e.g. FSRA, ADGM, UAE Central Bank)

• Banks and financial institutions

• IT systems and infrastructure providers

• External auditors and legal advisers

• Compliance consultants and risk advisers

Data is only shared where there is a valid legal basis, including compliance with regulatory obligations, performance of contractual services, legitimate business interests, or fraud prevention. We do not sell personal data to third parties.

8. International Transfers

In certain circumstances, personal data may be transferred outside the ADGM, for example to service providers or counterparties located in other jurisdictions.

Where such transfers occur, we ensure appropriate safeguards are in place, including contractual protections and security controls, consistent with the ADGM Data Protection Regulations.

9. How Long We Keep Your Data

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, and business requirements.

Once data is no longer required, it is securely deleted or disposed of in line with our internal retention policies.

10. How We Protect Your Data

We take the security of personal data seriously. Our measures include:

• Restricted access to systems holding personal data

• Secure data storage within our Microsoft 365 environment

• Confidentiality obligations for all staff

• Regular review of access controls and data handling practices

11. Third-Party Websites

Our website may contain links to external sites. Al Liwan is not responsible for the privacy practices of those sites. We recommend reviewing the privacy policy of any third-party website you visit.

12. Your Rights

Under the ADGM Data Protection Regulations 2021, you have the right to:

• Access the personal data we hold about you

• Request correction of inaccurate or incomplete data

• Request deletion of your data where it is no longer required

• Object to or restrict how your data is processed

To exercise any of these rights, please contact us at info@alliwan.com.

You also have the right to raise a concern with the ADGM Commissioner of Data Protection:

• Phone: +971 2 333 8888

• Email: Data.Protection@adgm.com

• Address: ADGM Building, Abu Dhabi Global Market Square, Al Maryah Island, Abu Dhabi, UAE

13. Policy Updates

We may update this policy from time to time to reflect changes in our business or applicable law. The current version will always be available at www.alliwan.com. The date at the top of this page indicates when it was last revised.