This Privacy Notice relates to you when you’re on our website.
Our company name is Exinity ME Limited and our trading name is EXINITY (hereinafter "EXINITY"). EXINITY is committed to protecting your personal information and respects its’ clients and users expectations on privacy and confidentiality. This policy statement will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you. We are committed to safeguard any information we collect, use and hold about you.
What data do you collect?
We collect different kinds of personal data about you. We’ve grouped them together as follows; identity data, contact data, professional data, tax data, financial data, transaction data, technical data, profile data, usage data, marketing and communications data.NEXT
Data processing 2
How is my data used?
- provide you with our investment services
- comply with our legal or regulatory obligations
- make our site better and make sure that what’s on our site is presented in the most effective way
- let you take part in our interactive features on our site
- keep our site safe and secure
3 Data sharing
Who do you share my data with?
- Operational software providers
- External Third Parties (for ex. service providers, professional advisers regulators and other authorities, Banks and Payment institutions, affiliated companies directly and indirectly connected with EXINITY)
- Specific third parties; Supervisory and regulatory and public authorities, IT and Trading Platform Administration providers, Translating Agencies, Marketing Providers, Professional Firms, Auditors, Card Payment providers and Cloud Storage Companies etc
- Our website host, because that’s how we show you our services
- analytics and search engine providers that assist us in the improvement of our site
My rights 4
- Request access
- Request correction
- Request erasure
- Object to processing
- Request the restriction
- Request the transfer
- Withdraw consent
Purpose of this policy statement
This policy statement aims to give you information on how EXINITY collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service as per the Client Agreement.
It is important that you read this policy statement together with any other policy statement or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This policy statement supplements the other notices and is not intended to override them.
Who we are
Our company name is Exinity ME Ltd and our trading name is EXINITY.
EXINITY is the controller and is responsible for your personal data.
Our address is: 16-104 Al Khatem Tower, ADGM Square, Al Maryah Island, Abu Dhabi.
Any enquiries about our use of your personal data should be addressed to the email: [email protected]
Changes to the privacy statement and your duty to inform us of changes
We may modify or amend this policy statement from time to time. We will notify you appropriately when we make changes to this privacy statement. We do however encourage you to review this statement periodically so as to always be informed about how we are processing and protecting your personal information.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). When you register with EXINITY, it is necessary that we collect some personal data from you for business purposes. By understanding your needs, we can treat you fairly as a client; we can provide you with the most suitable services, give you the appropriate information, process your requests in a fair and efficient manner.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, maiden name, last name, proof of identity, username or similar identifier, marital status, title, date and place of birth and gender, country of residence and citizenship.
Contact Data includes billing address, delivery address, email address and telephone numbers proof of address.
Professional Data includes level of education, profession, employer name, work experience, information on experience.
Tax Data include country of tax residence and tax identification number.
Financial Data includes annual income, net worth, source of funds, anticipated account turnover, bank account, bank statements, payment card details and copies, E-wallet information.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, deposit methods, purpose of transactions with us.
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 and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, store and use the following more sensitive types of personal information:
Information about criminal convictions and offences.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Non-Personal Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy statement.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in the required registration forms in our Website or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
apply for our products or services;
make a request under the Terms and Conditions,
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or give us feedback;
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from analytics providers such as [Google];
Contact, Financial and Transaction Data from providers of payment services.
Identity and Contact Data from individual and publicly availably sources, such as Registrar of Companies, Worldcheck and Thomson Reuters.
The following list illustrates the reasons why EXINITY may need to use your Personal Data:
Where we need to perform the contract we are about to enter into or have entered into with you (ex. verification of your identity, due diligence, to register you as a Client, to assess your appropriateness and suitability, to manage payments, fees and charges, to manage our relationship with you and notify you about changes in our terms and policies, etc).
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (survey purposes, to administer and protect our business, to deliver relevant website contents to you and advertisements, to use data analytics to improve our website, services etc).
Where we need to comply with a legal or regulatory obligation (where we are obliged by the law and regulations to disclose your data).
Disclosures of personal data
We may have to share your personal data with the parties set out below for the purposes set out below.
External Third Parties (for ex. service providers, professional advisers regulators and other authorities, Banks and Payment institutions, affiliated companies directly and indirectly connected with EXINITY).
Specific third parties (for ex. Supervisory and regulatory and public authorities, IT and Trading Platform Administration providers, Translating Agencies, Marketing Providers, Professional Firms, Auditors, Card Payment providers and Cloud Storage Companies etc).
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets or affiliated entities of EXINITY. 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 policy statement.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services or products from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Some of our external third parties are based outside the Abu Dhabi Global Market (ADGM) so their processing of your personal data will involve a transfer of data outside the ADGM.
Whenever we transfer your personal data out of the ADGM, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Office of Data Protection here.
- In the absence of an adequate level of protection, we may transfer your personal data out of ADGM only if one of the safeguards set out under section 5 of the ADGM Data Protection Regulations 2015 is in place.
- Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide adequate level of protection to personal data.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the ADGM.
EXINITY has put in place appropriate security measures to protect the security of its’ Client’s personal data and prevent any unauthorized or unlawful processing, accidental loss, destruction, alteration, disclosure or damage on Client’s personal data. EXINITY implements appropriate technical and organisational measures such as network traffic encryption, pseudonymisation, data encryption, two-factor authentication, access management procedure, tokenisation, clean desk policy, business continuity and disaster recovery, IT systems risk assessment, physical and logical access segregation, process in case of personal data breach policy etc. EXINITY limits access to the Client’s personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process the Client’s personal data on EXINITY’ instructions and they are subject to a duty of confidentiality.
We record, monitor and process any telephone conversations and/or electronic communications between us such as through fax, email, social media, electronic messages, either initiated from the Company’s side or your side. All such communications are recorded and/or monitored and/or processed by EXINITY, including any telephone conversations and/or electronic communications that result or may result in transactions or client order services even if those conversations or communications do not result in the conclusion of such transactions. The content of relevant in person conversations and/or communications with you may be recorded by minutes or notes. Any such records shall be provided to you upon request at the same language as the one used to provide investment services to you.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to withdraw consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us through email at: [email protected]
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. If you require further information on how we deal with a Data Breach please Contact us.
If you have any questions which have not been covered in this Policy Statement, or any further concerns regarding the use of Personal Data, please reach out to us using the contact details available on the footer of our website or send an email to [email protected].
We would highly appreciate if you could address any complaint as regards to this policy and about use of your information in our complaints department at: [email protected].
If your complaint or concern is not resolved you can contact the Office of the Data Protection via their website.