Protecting the confidentiality and security of personal information is integral to the way in which Oxford Bridge Capital Limited conducts its business worldwide. We at Oxford Bridge Capital Limited (OBCL) are committed to safeguarding the privacy of our clients and use it in accordance with our privacy principles set out below while providing our services to them. The following are major points from our updated Privacy Policy statement that will help to explain the data processing practices of our businesses.

Introduction:

In accordance with the General Data Protection Regulation (GDPR), applicable under the DIFC Data Protection Law, OBCL being the data controller for the purposes of this application for its services, must provide you with information on how your personal data will be processed.

Purposes of processing and lawful basis of processing:

The personal data collected from you, provided by you or obtained from other sources on your behalf will be held, disclosed and processed by OBCL or its third party vendor for the purpose of offering our services and maintaining the relationship with you. We process personal data only when we have a lawful purpose. Presently, we use your personal data for the following lawful purposes:

• To consider entering into a relationship at your request, including performing anti-money laundering, anti-terrorism, sanction screening, fraud and other due diligence checks.
• To deliver the services you have requested, including liaising with third parties (i.e. brokers/ custodian banks for the purposes of executing transactions).
• To manage payments, fees and charges and to collect and recover money owed to us.
• To interact with governmental or regulatory bodies or other competent national authorities.
• Recording, maintaining, storing and using recordings of telephone calls that you make to and receive from OBCL, the Administrator, or the Manager and their delegates or duly appointed agents and any of their respective related, associated or affiliated companies for processing and verification of instructions, management and administration of your account(s) and any other matters related to your investment with OBCL, dispute resolution, record keeping, security and/or training purposes.
• To send you marketing (including by paper and electronic channels) communications and service updates.
• For any other purpose as provided for in the Agreement between us.
• Complying with any applicable legal, Tax or regulatory obligations imposed on the Portfolio Manager including legal obligations under the Companies Act, Tax Laws and the AML regulations including but not limited to:

AML:

In line with anti-money laundering requirements under the DFSA AML regulations, all investors are required to be identified. For this purpose, certain documentation will be required at the time of onboarding.

CRS/FATCA:

OBCL is obliged to collect certain information about each investor’s tax arrangements. For CRS/FATCA reporting purposes, please note that in certain circumstances OBCL may legally be obliged to share this information and other financial information with respect to investor’s interest with the relevant tax authorities under relevant jurisdictions.

Screening:

OBCL shall engage in screening for the purpose of AML regulations and counter terrorist facing legislations including PEP screening and with UN, EU and other applicable sanctions regimes.

• Carrying out statistical analysis and market research.
• Recording, maintaining, storing, and using recordings of telephone calls that you make to and receive from OBCL, the Administrator.

Please note that where personal data is processed for purposes of legitimate interests, you have a right to object to such processing and OBCL will no longer process the personal data unless OBCL can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Consent:

From time to time, OBCL may send you information about financial markets etc., by telephone, email or by other reasonable means of communication. You have the right not to receive such information. Your consent is not required to process your personal data for the purposes referenced above. However, in order to process your personal data for the purposes of direct marketing, OBCL seeks your consent. You have a right to withdraw this consent at any time. However, your withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. You can withdraw your consent by contacting OBCL at the below mentioned address.

Disclosures to data processors and / or third parties:

Personal data relating to you which is collected from you or provided by you or on your behalf may be handled by OBCL or their duly appointed agents and any of their respective related, associated or affiliated companies/vendors for the purposes specified above. These data processors will handle your information in accordance with applicable Data Protection Legislation. OBCL may disclose your personal data to other third parties where required by law or for legitimate business interests. This may include disclosure to third parties such as auditors and the regulatory bodies, taxation authorities and technology providers.

Transfers Abroad:

Since we are a company, based in DIFC (UAE), personal data collected from you or provided by you or on your behalf may be transferred outside of transactions originating jurisdiction including to companies situated in countries which may not have the same data protection laws. Such data transfers will only involve companies which are part of the same corporate group or acting as service providers to the OBCL.

Retention period:

OBCL will retain your personal information for as long as is needed to fulfil the purposes outlined in our Privacy Policy, unless a longer retention period is required or permitted by law.

Security Measures to Protect your Data:

We maintain reasonable and appropriate security measures to protect Customer Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Our information security controls ensure that personal and financial data is well protected and accessible only to authorized personnel.

Refusal to provide personal data:

The provision by you of personal data, as outlined in the section titled “Purposes of processing and lawful basis for processing” is required for us to accept your application and manage and administer your portfolio and so that we can comply with the contractual, tax, legal and regulatory requirements referenced above. Where you fail or refuse to provide such personal data, we may not be able to perform the contract we have entered into with you, or we may be prevented from complying with our legal obligations.

Data protection rights:

• You have a right of access to and the right to amend and rectify your personal data.
• You have the right to have any incomplete personal data completed.
• You have a right to be forgotten (right of erasure of personal data)
• You have a right to restrict processing.
• You have a right to data portability.
• You also have the right to object to processing where Oxford Bridge Capital Limited is processing personal data for legitimate interests.
• You have the right to withdraw your consent used for Direct Marketing.

Additionally, you have a right to lodge a complaint with a supervisory authority, in particular, in the State of your habitual residence; place of work or place of the alleged infringement if you consider that the processing of personal data relating to you carried out by OBCL is not as per the regulation in force. You may exercise your rights at any time by using the details set out below: The Data Protection Officer Oxford Bridge Capital Limited Al Fattan Currency House, Office No 706 , Level 7 Dubai International Financial Center (DIFC) P.O Box 506810, Dubai , UAE PH# +971 4 201 3555 Email: [email protected] We may need to request specific information from you to help us confirm your identity and ensure your right to access to the PI requested, or to exercise any of your other rights. This is to ensure that PI is not disclosed to any person who does not have authority to receive it. We aim to respond to all legitimate requests within one calendar month. If we think it may take us longer than one calendar month, (such as where your request is particularly complex or you have made a number of requests), we will notify you and keep you updated.

Other Points

We do not track your online activities across the Internet. We do not use your personal information for automated decision making, including profiling. We do not sell or rent your personal information to third parties.

Changes to this Privacy Notice

We may modify or amend this Privacy Notice from time to time and you are advised to visit our website regularly to check for any amendments. Any material changes will be communicated to you through an appropriate channel, depending on how we normally communicate with you.