This Privacy Notice applies to you if we are processing your personal data in or through our Abu Dhabi Global Market entity, FundRock Investment Management Services (ME) Limited (hereafter “the Company, “We”, “us” or “FRME”). FRME provides this Privacy Notice as a supplement to our global Apex Group Privacy Policy.
This Privacy Notice applies only to our processing that is within the scope of our obligations under the Abu Dhabi Global Market (“ADGM”) Data Protection Regulations 2021 (“DPR“).
We are a data controller with respect to the data collected by our Services, by our customer service team, when you engage with us on social media, when you participate in one of our contests, sweepstakes, promotions, or surveys, when you attend one of our events, or when you otherwise interact with us. As a data controller, we will decide the ways in which and purposes for which we process data about you. We may process data about you ourselves or through others acting as data processors on our behalf.
If you have any questions about this Privacy Notice, you can contact our ADGM Data Protection Officer using the details set out in the Contact Us section below.
Legal Basis for Processing
We collect and process data about you in accordance with the information provided in this Privacy Policy. As required by the ADGM DPR, our legal grounds, or “lawful basis,” for processing data include the following:
It is necessary for the performance of a contract or to enable us to enter into a contract (e.g., providing the Services you requested).
When we have a legitimate interest in processing data about you to operate our business or protect our interests (e.g., to provide, maintain, and improve our Services, conduct data analytics, and communicate with you).
To comply with our legal obligations (e.g., collecting due diligence information and documents to comply with the Financial Services Regulatory Authority (“FSRA”) Anti Money Laundering Rules).
When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing data about you, you may withdraw such consent at any time by contacting us using the details in the Contact Us section below (however, please note that the lawfulness of any processing based on your consent that was provided prior to any withdrawal will not be affected by the subsequent withdrawal of your consent).
No Requirement to Provide Us Data about You
Our Services may collect, sometimes automatically, certain data. We may be unable to provide parts of our Services, if you prevent us from collecting this data.
Transfer of Data Outside of the ADGM
As our Group is headquartered in Bermuda and have operations and service providers in multiple countries, the information you provide to us may be transferred and processed outside the ADGM including to countries which are considered by the ADGM as non-adequate jurisdictions.
We may also transfer data about you to countries that the ADGM has determined offer an adequate level of protection in respect of personal data.
Where required by the ADGM DPR, we will put in place, or require a processor to put in place, appropriate safeguards to protect transferred personal data, such as the standard contractual clauses approved by the ADGM Office of Data Protection or rely on derogations under the ADGM DPR. If you require further information about this, you can request it using the details set out in the Contact Us section below.
Data Retention
Generally, we will keep information relevant to our dealings with you for at least six (6) years following the termination of our contract/relationship. We will retain data about you for as long as necessary to fulfil the purposes for which we collected it, in accordance with our legal obligations, or for the establishment, exercise or defence of legal claims. In doing this, we will consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, data about you may be anonymized, so that it can no longer be associated with you, in which case it is no longer personal data. Once we no longer require data about you for the purposes for which we collected it, we will securely destroy, anonymize, pseudonymize or securely encrypt the data in accordance with applicable laws and regulations.
Data Subject Requests
Under the ADGM DPR you may, under certain circumstances, make data subject requests in relation to the data we hold about you. These data subject requests include the ability to:
- request access to data about you (commonly known as a “data subject access request”) and request certain information in relation to its processing;
- request rectification of data about you;
- request the erasure of data about you;
- request the restriction of processing of data about you;
- object to the processing of data about you; and
- request the transfer of data about you to another party
Please note that the right not to be subject to a decision based solely on automated Processing, would not apply, since automated processing is not conducted.
If you want to make one of the above requests, please email your request to us via the details in the Contact Us section below.
Fees
We typically do not charge you a fee to respond to one of the above requests. However, we may charge a reasonable fee if your request is unreasonable or excessive, or we may refuse to comply with the request in such circumstances.
Cookies
We use cookies to determine your preferences. Please refer to the “Cookies” and “Manage cookies” links of our website.
What we may need from you
Before responding to your request, we may ask you to provide specific information to us to help us verify your identity and ensure your ability to make the request.
Changes to This Privacy Notice
Our practices with respect to data about you may vary from time to time, and we may update this Privacy Notice at any time. If we make changes, we will notify you by revising the date at the top of this notice. The latest version of this Privacy Notice will be made available to you on our website, and we encourage you to review this Privacy Notice regularly to stay informed about our data practices with respect to data about you and the choices available to you.
Contact Us
If you require any further information, contact us using the following contact details: Data Protection Officer, Office 801, Floor 8, Al Maqam Tower, Abu Dhabi Global Market Square, Al Maryah Island, Abu Dhabi, United Arab Emirates or fundrock@apexfs.com.
Complaints
If you are dissatisfied with the way that we have handled your query, you have the right to make a complaint at any time. The ADGM Office of Data Protection is the relevant authority that safeguards your interests in the ADGM. Contact Details: ADGM Authorities Building, ADGM Square, Al Maryah Island, PO Box 111999, Abu Dhabi, UAE (+971 23338888) (data.protection@adgm.com)
