Privacy policy

For the purposes of this Privacy Policy, the term “you” shall be interpreted broadly to include any natural person whose personal data is collected or processed by Elite. The term “personal data” means any information relating to an identified or identifiable natural person. The term “processing” includes any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

We may collect personal data about you in a number of ways. This includes information you provide directly to us, whether in person, over the phone, via email or other means of communication. It may also include information provided to us by your employer, company, agent, intermediary, or adviser in connection with your relationship with us. We may also collect information through documentation you complete or that we complete on your behalf as part of onboarding, application, or service processes. Additionally, we may collect information from publicly accessible sources or third-party service providers, particularly where required for background verification, regulatory compliance, or risk assessment purposes.

Depending on the nature of your relationship with us, the personal data we collect may include your full name and contact details, including business or residential address, email address, and telephone number; biographical and identification information such as date of birth, nationality, domicile, passport or national ID details, and tax identification number; information about your income, assets, liabilities, sources of wealth, bank account details, and financial situation; details about your investment knowledge and experience; your investment objectives and other relevant personal, professional, or familial circumstances; and information relevant to your classification as a politically exposed person or for anti- money laundering or counter-terrorism financing purposes. This list is indicative only and not exhaustive.

While we typically collect personal data directly from you, there may be circumstances where we collect such data from third parties, including for the purpose of verifying the information you have provided or for compliance with our legal or regulatory obligations.

We process personal data on a number of legal bases as set out below.

Where processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract, we may use your personal data for purposes including verifying your identity, preparing service proposals, providing services in accordance with our contractual arrangements with you, managing client relationships, responding to queries or complaints, and undertaking any other steps reasonably necessary in connection with our provision of services.

Where processing is necessary for the purposes of our legitimate interests or those of a third party, and such interests are not overridden by your interests or fundamental rights and freedoms, we may use your personal data for the management and administration of our business, including internal analysis, archiving, data security, IT operations, risk management, business continuity, and obtaining professional advice. We may also use your data to evaluate or engage in business restructurings, mergers, or acquisitions.

Where processing is required to comply with legal and regulatory obligations, we will process your personal data for the purposes of meeting obligations under applicable anti- money laundering, counter-terrorism financing, tax, and financial services laws and regulations. This may include, but is not limited to, laws such as the DIFC Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module, UAE Federal Law No. 4 of 2002, UAE Federal Decree-Law No. 20 of 2018, the DIFC Common Reporting Standard Law, and intergovernmental agreements relating to FATCA and CRS compliance.

We may disclose your personal data, where lawful and necessary, to third parties including your authorised agents or intermediaries, administrators, depositories, custodians, financial institutions, trading counterparties, settlement systems, and regulatory authorities. We may also disclose your personal data to our professional advisers, including legal counsel, auditors, and consultants, to the extent required for the performance of their services to us. In certain cases, we may introduce you to third parties and, where appropriate, will inform you in advance of their identity.

We may also disclose personal data to third parties in connection with corporate transactions, such as a merger or acquisition, or to comply with lawful requests from regulators, courts, or law enforcement agencies.

In certain circumstances, your personal data may be transferred to and stored in jurisdictions outside the DIFC, including to service providers or affiliates located in the United Arab Emirates, Canada, or other countries. Such transfers will only take place where the recipient jurisdiction ensures an adequate level of protection, where appropriate safeguards are in place in accordance with the DPL 2020 (including standard contractual clauses or binding corporate rules), or where another lawful basis for transfer exists. You may request further information in this regard by contacting us using the contact details provided below.

We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of your personal data. This includes maintaining internal policies and procedures designed to protect data integrity, confidentiality, and availability, conducting regular reviews of our security measures, and restricting access to personal data to those who have a legitimate need to access it. All employees are subject to confidentiality obligations and are trained in data protection principles.

We retain personal data only for as long as is necessary for the purposes for which it was collected or as required to comply with applicable legal or regulatory obligations. Where personal data is collected for anti-money laundering purposes, we are required to retain such information for a period of at least six years following the termination of our relationship with you, unless a longer retention period is required by applicable law or regulation or necessary in the context of actual or potential legal proceedings. In other cases, we will generally retain personal data for a period of six years from the date our relationship with you ends.

You have certain rights under the DPL 2020 in respect of your personal data. These rights include the right to request access to the personal data we hold about you, the right to request rectification or erasure of your personal data, the right to object to or restrict processing, the right to data portability, and the right to withdraw your consent where processing is based on consent. Please note that these rights are subject to certain legal limitations and exemptions, and we may be entitled to refuse certain requests where legally permitted to do so.

If you exercise any of your rights, we will take reasonable steps to inform any third party to whom your personal data has been disclosed of your request, to the extent required by law. You also have the right to lodge a complaint with the DIFC Commissioner of Data Protection if you believe we have not complied with our legal obligations in handling your personal data.

Certain personal data is required by law or is necessary to enter into or perform a contract with you. If you do not provide such data when requested, we may be unable to provide services to you or to comply with our legal obligations.

Elite Capital (DIFC) Limited acts as the data controller in respect of your personal data. If you have any questions about this Privacy Policy or wish to exercise your data protection rights, you may contact us using the following details:

• Email:info@elitecapitalinvestments.com
• Telephone:+971 4 499 2400
• Postal Address:Elite Capital Head Office, Central Park Towers, Office 02-40, Dubai International Financial Centre, Dubai, PO Box 507417