Privacy Policy

TAWAREF CAPITAL SPC

Tawaref Capital SPC, a segregated portfolio company incorporated in the Cayman Islands, with company number TR-384126 and its registered office at Trident Trust Company (Cayman) Limited, One Capital Place, P.O. Box 847, George Town Grand Cayman KY1-1103, Cayman Islands (“us”, “we”, or “TAWAREF”, which also includes its affiliates) is the author and publisher of this website (“Website”) on the world wide web as well as the software and applications provided by TAWAREF, including but not limited to any and all mobile application (together with the Website, referred to as the “Services”). 
This privacy policy ("Privacy Policy") explains how we collect, use, share, disclose and protect personal information about the Users of the Services, and the visitors of Website (jointly and severally referred to as “you” or “Users” in this Privacy Policy). We created this Privacy Policy to demonstrate our commitment to the protection of your privacy and your personal information. Your use of and access to the Services is subject to this Privacy Policy and our Terms and Conditions.

BY USING THE SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND AGREE TO BE BOUND BY THE PRIVACY POLICY. YOU HEREBY CONSENT TO OUR COLLECTION, USE AND SHARING, DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE ANY OF THE SERVICES OR GIVE US ANY OF YOUR INFORMATION. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

Tawaref CAPITAL SPC (“Tawaref or the “Advisor”) is committed to safeguarding the use of personal information of our clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”).

This Policy is addressed to any current clients and/or prospective clients of Tawaref (“you” or “your”) whose public and non-public personal information Tawaref collects and controls to conduct its business, including on our platform (“Platform”).

Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Tawaref (also referred to as "we", "our" and "us") protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.

Tawaref does not sell your personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.

Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.

To affirm our continued commitment to the proper use of client information and protecting your privacy, we have set forth the following privacy policies.

Changes to Our Policy

We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.

Periodically we may revise this Policy and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent information sharing.

Information collected

When you establish a relationship with us, you are requested to furnish personal and financial information to assist in assessing your financial objectives and goals. The information you share with us is private and confidential, and we are committed to protecting your privacy. In addition to the information collected, during our relationship we may also collect a variety of nonpublic and public personal information from other sources for example but not limited to:

1. 1. Assets and liabilities
2. 2. Tax card number
3. 3. Name, address, and phone number, email address
4. 4. Account information
5. 5. Investment activity
6. 6. Investment experience and goals
7. 7. Assets and liabilities
8. 8. Income and expenses, etc.……

The specific types of personal information we collect, and share depend on the service you have with us. This information can include:

• personally, identifying information such as name, telephone, address, date of birth, social security number, government identification, and marital status.
• digital footprint data such as e-mail, login information, and IP addresses.
• biographical data such as age and gender.
• employment data such as salary information, job position, and tax information.
• financial Information such as bank information, salary information, credit card numbers, and pension.
• Custody, brokerage and advisory agreements.
• Account applications and forms.
• Transactional information with us or others
• Investment questionnaires and suitability documents.

 
Usage of personal information

We will only use your personal information with the purpose to provide you with our investment services. In managing your investment for you, we will use your personal information to:

• monitor, audit, evaluate and otherwise administer our services.
• provide you with access to protected areas of our Platform.
• provide continuous service to you and to conduct business processing functions including by providing personal information to our related bodies corporate, contractors, service providers or other third parties.
• assist with the administrative, marketing (including direct marketing), planning, product or service development, quality control or research purposes of Tawaref and its contractors and service providers.
• communicate with you and respond to your inquiries.
• conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms.
• for other purposes required or authorized by law, including other purposes for which you have provided your consent.
• protect against, identify and prevent fraud, copyright infringement, unauthorized use and distribution of protected content and other unlawful activity, claims and liabilities; and/or.
• perform data analyses (such as market and customer research).

In the event that we use personal information we collect for other purposes not identified above where direct client consent is required under applicable rules, laws and/or regulations we will provide specific notice at the time we collect such personal information.

Processing collected Personal information

Tawaref may have one or more of the following lawful bases to process your personal information:

• Consent: your freely, informed, and voluntary consent to process your personal information in connection to our investment services.
• Contract: processing your personal information is necessary in order to fulfill a contract.
• Legal Obligation: processing is necessary to comply with applicable rules, laws, and regulations.
• Legitimate Interests: processing is necessary to the legitimate interests of our firm and/or a third party.

 
Sharing collected information

Tawaref will share Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information.

All financial companies need to share client’s personal information to run their everyday business. It is the policy of Tawaref to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/non affiliated entities who need to know that information to provide services in furtherance of the client's engagement of Tawaref.

In that regard, Tawaref may disclose the client’s information:

1. 1. to individuals and/or entities not affiliated with Tawaref, including, but not limited to the client’s other professional advisors and/or certain service providers that may be recommended or engaged by Tawaref in furtherance of the client's engagement of Tawaref (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, record keeper, proxy management service provider, etc.).
2. 2. required to do so by judicial or regulatory process; or
3. 3. otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations.

Clients and/or prospective clients will be deemed to have automatically authorized Tawaref to share any information contained in any document completed by a client and/or prospective client to Tawaref for the purpose of facilitating the business relationship with any corresponding nonaffiliated third party service provider in connection to Tawaref providing such services (i.e., broker-dealer, investment adviser, account custodian, record keeper, insurance company, etc.).

We limit access to nonpublic personal information to only those employees who have a business or professional reason for knowing it and who have signed a copy of Tawaref’s Privacy Policy to have access to client information. Employees violating Tawaref’s Privacy Policy will be subject to Tawaref’s disciplinary process. Tawaref limits access to nonaffiliated third parties as permitted by law. Additionally, whenever Tawaref hires other third party organizations to provide services to Tawaref’s clients, Tawaref will require them to sign confidentiality agreements and/or the Privacy Policy.

Know your rights

To the extent permitted by the applicable law of your jurisdiction, in relation to your personal information, you may request:

• to have your personal information corrected, for example, if it is incomplete or incorrect
• to opt out of receiving marketing communications at any time
• to access the personal information held by us about you
• the right to restrict or object to the processing of your personal information, or request that your personal information is erased
• the right to receive a copy of the personal information which you have provided to our platform, in a structured, commonly used and machine-readable format (known as “data portability”)
• have a copy of the personal information we hold about you provided to you or another controller where technically feasible
• where you have provided personal information voluntarily, or otherwise consented to its use, the right to withdraw your consent

To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information.

To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.

Protection measures

To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information.

We require third parties that assist in providing our services to you to protect the personal information they receive from us.

Internet Security

Although we have made efforts to secure data that you submit to us on our Platform, as our Platform is linked to the internet which is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Links to Third-Party Web Platforms

As a convenience to you, Tawaref may provide hyperlinks to web platforms operated by third parties. When you select these hyperlinks you will be leaving our Platform.

Tawaref has no control over third party web platforms, their content, or security. Accordingly, when you access these third party web platforms it is at your own risk. We encourage you to read the associated privacy policies by such third party web platforms to learn more about their data privacy management practices. Tawaref may, in its sole discretion, block links to our Platform and Content without prior notice.

To the extent permitted by applicable law, we retain your personal information for the period necessary to serve the purposes for which we obtained it. We may also retain your personal information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest.

Platform cookies

We may use “cookies” to help us tailor our Platform to better suit your needs (for example, we may use cookies to enable us to save any personal preferences indicated by you) and to provide a more effective route to various components of our Platform.

Cookies are small text files that are stored in your computer's memory and hard drive when you visit certain web pages. They are used to enable Platforms to function or to provide information to the owners of a Platform.

Automated Decision Making. Our Platform contains cookies that function as an automated decision-making mechanism to determine user location.

Third party cookies. Third party cookies are cookies set by a web platform other than the website you are currently visiting. When you visit our Platform, if we have a link to a third-party website, you may receive cookies that are set by that third party. These cookies are used for the purposes described in the bullet points above. We do not control the setting of these third party cookies, so we suggest you might wish to check the third party web platforms for more information about their use of cookies and how to manage them.

Amending internet browser settings to disable cookies. You can configure your browser to send accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies that have already been set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. You are free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Platform. In addition, a number of companies offer utilities designed to help you visit Platforms anonymously.

Governing law

This Agreement (and any dispute, controversy, proceedings or claim of whatever nature arising out of or in any way relating to this Agreement or its formation) shall be governed by and construed in accordance with English law.

Each of the parties to this Agreement irrevocably agrees that the competent courts of England and Wales shall have exclusive jurisdiction to hear and decide any suit, action or proceedings, and/or to settle any disputes, which may arise out of or in connection with this Agreement and, for these purposes, each party irrevocably submits to the jurisdiction of the courts of England and Wales.