Our Portfolio | Privacy Policy
Introduction and background
The purpose of this Notice is to outline how Novocredit Fund (CEIC) Limited (“Novocredit”) has established measures to protect your privacy and information rights.
This Privacy Notice aims to outline how we maintain these rights. In particular it outlines:
-
How we collect your information
-
Type of information we hold
-
Why we collect data
-
How you can exercise your rights.
-
Who to contact in the event you’re unhappy with our performance.
How we collect Information from You
Novocredit will collect and process your personal data which you provide us through application forms, Know Your Customer (KYC) and Know Your Business Partner (KYB) forms, our website, face-to-face and electronic communication (including telephone conversations) in order to provide our services to you.
The Kind of Information We Hold About You
-
Personal details such as name, date of birth, e-mail ID, nationality and phone numbers
-
Other information such as Visa, Passport, overseas Tax-Identification Number and overseas country-specific unique identifier
-
Current residential address and permanent residential address
-
Shareholding details
-
Financial Information, including billing address, bank account numbers, instruction records, transaction details, counterparty details, and specimen signatures
-
If you are seeking specialised services as permitted under applicable law, then your investment risk appetite and preferences, current investments profile and investment objectives and goals as shared by you
-
Information in the nature of your occupation, education and qualifications, annual income and source of income
-
Address proofs like valid utility bills, driving licence, job card issued by Government agencies, Emirates ID etc.
-
Overseas address proofs such as address on passport, utility bills, bank statements, national ID cards and photographs
-
Information required to meet legal and regulatory requirements relating to the automatic exchange of tax information (e.g. US FATCA and OECD CRS), including details of tax residency, tax classification and tax identification numbers;
Why we collect your data
Specifically, we may use your information for the following purposes:
-
To provide and manage our relationship with you;
-
To give you statements and other information about our relationship;
-
To handle enquiries and complaints;
-
To provide our services to you;
-
validate authorised signatories for processing agreements and transactions;
-
To evaluate, develop and improve our services to you and other customers;
-
To monitor, record and analyse any communications between you and us, including phone calls and video call made through MS Teams or similar applications;
-
To meet our regulatory compliance and reporting obligations and to prevent, detect, investigate and prosecute fraud and alleged fraud, money laundering and other crimes. We may record your image on CCTV when you visit our premises;
-
To assess any application you make, including carrying out fraud, money laundering, identity, sanctions screening and any other regulatory checks;
-
To share your information with Federal Tax Authority, UAE or other relevant tax authorities, Dubai International Financial Centre Authority, Dubai Financial Services Authority (DFSA), Central Bank of UAE and other Government authorities, credit reference agencies, fraud prevention agencies;
-
comply with applicable law including treaties or agreements with or between foreign or domestic governments (including in relation to tax reporting laws), (which may include laws outside the country you are located in), to respond to requests from public and government authorities (which may include authorities outside the country you are located in), to cooperate with law enforcement, governmental, regulatory, securities exchange or other similar agencies.
-
To share your information with our partners and service providers
Your information rights
We recognize that you have rights as a ‘data subject’, and that we have an obligation to uphold these.
Right to be informed
This encompasses the obligation for us to be transparent in how we collect and use your personal data.
Right of access
You have the right to access your personal data and supplementary information.
Right to rectification
If the information we hold on you is inaccurate or incomplete, you can request we correct this.
Right to restrict processing
You have the right to request we cease processing your data, if:
-
You consider it inaccurate or incomplete.
-
Where you object to processing and we are considering whether we still have a legitimate interest to process it.
-
Where we don’t need the data for the original reason we collected it, but may need it to support a legal claim
Right to data portability
Where you have consented to our processing your data, or where the processing is necessary for us to deliver a contract, you can request a copy of that data be provided to a third party in electronic form.
Right to object
You have the right to object to our processing under certain circumstances.
This Privacy Notice should outline how we are transparent in our processing. Please get in touch with us through the ‘contact’ section to find out more or to exercise your information rights.
Transfer of data
We may pass your personal data on to third-party service providers contracted to the Firm in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only for the legitimate reasons they were obtained for originally. When they no longer need your data, they will dispose of the details in line with the Firm’s procedures as set out in the contracts signed with them. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
Retention of data
The Firm retains information in accordance with our data retention requirements. We may keep such information for up to 6 years from the date of close of business relationship or as required to comply with any legal or regulatory obligations to which we are subject.
Securing your information
The Firm places great importance on the security of all personally identifiable information associated with our clients. We have security measures in place to attempt to protect against the loss, misuse and alteration of customer data under our control. While we cannot ensure or guarantee that loss, misuse or alteration of data will not occur, we use our best efforts to prevent this through implementing the following:
-
IT Security Policy and Procedures.
-
Active internal policies to promote expert access control, password complexity/history controls, patching, windows updates and auditing policies.
-
Physical protection of our Data Center and workplace, monitoring, etc.
-
Up to date firewalls with limited and controlled access.
-
Backup data encryption.
Personal Data Breach
With regard to Personal Data Breach caused by the Firm, the Firm shall:
In accordance with the DIFC Data Protection Law No. 5 of 2020,
-
notify you without undue delay in the event of any Personal Data Breach involving Personal Data and
-
provide reasonable assistance to you when you are required to communicate a Personal Data Breach to a Data Subject.
-
Use reasonable efforts to identify the cause of such Personal Data Breach and take those steps as the Firm deems reasonably practicable in order to remediate the cause of such Personal Data Breach.
-
Provide reasonable assistance and cooperation as requested in the furtherance of any correction or remediation of any Personal Data Breach.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by us (or third parties), or how your complaint has been handled, you have the right to lodge a complaint to us at SARComm@gatewayims.com or directly with DIFC Commissioner of Data Protection.
Contact details.
We recognize that you may have questions on how we process and/or store your data or may want to change either the data we hold on or how we communicate with you in the future.
If you have given consent for processing, you are free to withdraw that consent. To do so, please contact the us at contact@gatewayims.com and phone number 043170300
If you have any questions in respect of this Notice, or would like to exercise your rights as a data subject (for example, to correct data or to exercise your right to access) please contact us at contact@gatewayims.com
If you are unhappy that we have responded to your query adequately, of if you have a further complaint, please send you complain on us at SARComm@gatewayims.com.