Introduction
This Privacy Policy gives you information about how we (which includes EightClouds Holdings Limited and our subsidiaries) collect, use, and disclose your personal data and our commitment to using the personal data we collect in a transparent manner. When referenced in this Privacy Policy, the term “personal data” includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, including any information that is subject to applicable data protection laws.
1. What are the sources of your information?
We may obtain information about you from a variety of sources, including:
from you – you may give us your information when you use our platforms (which include our website or other portal which may be made available to you), by filling out online forms or by corresponding with us by phone, email, or otherwise);
from suppliers; or
from screening tools and information available in the public domain.
2. The types of information we collect about you
We may collect, use, store and transfer different kinds of information about you, which includes:
Identity Data (which may include first name, last name, username or similar identifier, date of birth, nationality, passport number/national ID);
Contact Data (which may include residential address, email address, and mobile number);
Financial Data (which may include bank account details and payment card details);
Technical Data (which may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our platforms);
Profile Data (which may include your username and password, your interests, preferences, feedback and survey responses);
Usage Data (which may include information about how you interact with and use our platforms);
Communications Data (which may include your preferences in receiving information from us and our third parties and your communication preferences); and
Data from other sources (which may include social media networks, EightClouds partners, and public sources).
3. How we use your information
We may use or process your personal data for the following purposes:
to provide you with information that we think may be valuable to you;
to verify your identity and conduct due diligence;
to onboard you on our platforms;
to provide an assessment when you submit your pitch deck to us;
to manage our relationship with you;
to resolve complaints and handle requests and enquiries;
to prevent, detect and investigate crime, including fraud and money laundering or terrorist financing, and analysing and managing commercial risks;
to administer and protect our business (including troubleshooting, data analysis, and testing system analysis); and
to comply with legal requirements and exercise or defend legal claims.
4. On what basis do we use your information
We may use your personal data on the following basis:
performance of a contract with you or to take steps at your request to enter into a contract;
for our legitimate interests (to keep our records updated and manage our relationship with you);
because you have given your consent (if we expressly ask for consent to process your personal data); and
to ensure compliance with the relevant legal and regulatory obligations or for purposes of exercising and defending legal claims.
5. Cookies
We may send a small file to your computer when you visit our website (“cookies”). This will enable us to identify your computer, track your behaviour on our platforms and enhance your future visits. Save for the use of cookies, we do not automatically log data or collect data apart from the information you specifically provide to us. You can set your computer browser to reject cookies, which may preclude using certain parts of our platforms.
6. Disclosures of your personal data
To the extent permitted by law, we may share your personal data where necessary with the parties set out below:
government, judicial or regulatory authorities upon request to comply with any court order, law or legal process;
third-party service providers and sub-contractors who provide services to us (for example, we may engage third-party agents, cloud service providers, IT service providers and other third parties to support and facilitate communications and provide legal, accounting, insurance, audit and other professional services);
our professional advisers, such as auditors and lawyers;
our subsidiaries, affiliates, or strategic partners;
third parties to whom we may choose to sell, transfer or merge parts of our business or our assets; and
we may disclose your personal data with your consent to other unaffiliated third parties who are not described elsewhere in this Privacy Policy.
7. Security measures
We are committed to implementing security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered, or disclosed. Nonetheless, there is no such measure that can guarantee 100% security for your personal data. Therefore, we cannot make any representations, warranties, or guarantees that your personal data will be completely secure from theft, loss, or unauthorized access. While we do take measures to safeguard your personal data, we cannot guarantee their appropriateness or effectiveness. In the event of an incident that we are required by law to inform you of, we may notify you electronically, in writing, or by telephone if permitted to do so by law. We encourage you to use caution when using the internet. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us as specified in the “Contact Details” section below.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
This Privacy Policy gives you information about how we (which term includes EightClouds DMCC and our affiliates) collect, use, and disclose your personal data through your use of this website and our commitment to using the personal data we collect in a transparent manner. When referenced in this Privacy Policy, the term “personal data” includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, including any information that is subject to applicable data protection laws.
What are the sources of your personal data?
The sources of your personal data collected (collectively referred to as “Platforms” in this policy) may include, without limitation, the following:
Our Website.
Our Investor and Introducer Portal.
Additionally, we may collect your personal data through your interactions with us. You may give us your personal data by filling out online forms or by corresponding with us by phone, email, or otherwise.
The types of data we collect about you
We may collect, use, store and transfer different kinds of data about you, which we have grouped together as follows:
Identity Data includes first name, last name, any previous names, username or similar identifier, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access Platforms.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you interact with and use Platforms.
Communications Data includes your preferences in receiving information from us and our third parties and your communication preferences.
Advertising You might interact with our partners’ advertisements on our websites and apps, and we might receive and collect this information.
Data from other sources These include social media networks, market research agencies, EightClouds partners, and public sources.
We also may collect, use and share aggregated data, such as statistical or demographic data, which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature to analyse general trends in how users are interacting with our Platforms to help improve the Platforms.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your data, and which of the bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
9. Your rights
If you are subject to laws that provide you with such rights, you may have certain rights in relation to your personal data given, such as:
a request to access your personal data;
a request to correct your personal data;
a request to erase your personal data where it is no longer necessary for the purpose for which your personal data was originally collected; or
to withdraw your consent where we are relying on your consent to process your personal data.
If you wish to access any of these rights, we may ask you for additional information to confirm your identity and for security purposes, before disclosing personal data to you. We will make reasonable efforts to honour your request in accordance with applicable laws within 30 days of receipt of your request, unless we require further information from you. If, due to the complexity of the request, we require additional time, we will promptly inform you.
| Purpose/Use | Type of data | Basis |
|---|---|---|
|
To register you on our Investor and Introducer Portal or when you submit your pitch deck to us |
(a) Identity |
Performance of a contract with you |
|
To onboard you as an investor |
(a) Identity |
(a) Performance of a contract with you |
|
To manage our relationship with you which will include: |
To manage our relationship with you which will include: |
(a) Performance of a contract with you |
|
To administer and protect our business and our Platforms(including troubleshooting,data analysis,testing,system maintenance,support, reporting and hosting of data) |
(a) Identity |
(a) Necessary for our legitimate interests |
|
To deliver relevant Platform content |
(a) Identity |
Necessary for our legitimate interests |
|
To use data analytics to improve our Platforms and experiences |
(a) Technical |
Necessary for our legitimate interests |
|
To comply with legal requirements and exercise or defend legal claims |
(a) Identity |
We may need to process and retain your personal data to comply with relevant legal and regulatory obligations, or for purposes of exercising and defending legal claims |
10. Third-party links
Our platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our platforms, we encourage you to read the privacy policy of every website you visit.
11. Changes to the Privacy Policy
This Privacy Policy may change from time to time. Your continued use of our platforms after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.
11. Contact details
If you have any questions about this privacy policy or want to exercise your privacy rights, please contact us in the following ways:
- Email address: [email protected]
- Postal address: Gold Tower, Office 3401, Cluster I, JLT, Dubai, UAE
- Telephone number: +971(0)45 58 1559
Effective Date: 02/05/2024
COOKIES
We may send a small file to your computer when you visit our website (“cookies”). This will enable us to identify your computer, track your behaviour on our Platforms and enhance your future visits to our Platforms. We may use cookies to collect and store personal data and we link information stored by cookies with personal data you supply to us. Save for the use of cookies, we do not automatically log data or collect data apart from the information you specifically provide to us. You can set your computer browser to reject cookies but this may preclude your use of certain parts of our Platforms.
Disclosures of your personal data
To the extent permitted by law, we may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
⦁ We may share with government, judicial or regulatory authorities upon request to comply with any court order, law or legal process.
⦁ We may use carefully selected third parties to perform services on our behalf or to assist us with the provision of services to you. For example, we may engage third-party agents, distribution partners, cloud service providers, IT service providers and other third parties to support and facilitate advertising and communications, to personalise and optimise our services, analyse and enhance data, and provide legal, accounting, insurance, audit and other professional services. While providing such services, these third parties may have access to your personal data.
⦁ We may disclose personal data to our subsidiaries, affiliates, or strategic partners as needed to provide our services and, generally, as necessary to administer a global organisation.
⦁ Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
⦁ We may disclose your personal data with your consent to other unaffiliated third parties who are not described elsewhere in this Privacy Policy.
⦁ We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
Security measures
We have implemented reasonable security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered, or disclosed. Nonetheless, no such measure is 100% effective. Therefore, we do not guarantee that your personal data will be secure from theft, loss, or unauthorised access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such personal data. In the event of an incident that we are required by law to inform you of, we may notify you electronically, in writing, or by telephone if permitted to do so by law. We encourage you to use caution when using the Internet. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us as specified in the “Contact Details” section below.
Your legal rights
If you are subject to laws that provide you with such rights, you may have certain rights in relation to your personal data given, such as a request to access your personal data, a request to correct your personal data or to withdraw your consent where we are relaying on your consent to process your personal data.
If you wish to access any of these rights, we may ask you for additional information to confirm your identity and for security purposes, before disclosing personal data to you.
If you would like to access the below rights, you may contact us. We shall aim to comply with all requests within a reasonable time in line with applicable laws.
We will make every reasonable effort to honour your request in line with applicable laws. In the event we require additional time due to the complexity of the request, we shall promptly inform you of the same.
Contact details
If you have any questions about this privacy policy or want to exercise your privacy rights, please contact us in the following ways:
⦁ Email address: [email protected]
⦁ Telephone number: +971(0)4 568 6750
Third-party links
Our Platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Changes to the Privacy Policy
This Privacy Policy may change from time to time. Your continued use of our Platforms after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.
Effective Date:
Last Updated Date: