Privacy Policy

1. About this Privacy Policy

This Privacy Policy explains how Zamana Capital Limited ("Zamana Capital", "Zamana", "we", "us" or "our") collects, uses, stores and otherwise processes personal data when you visit zamana.capital, communicate with us or otherwise interact with us.

Zamana Capital Limited is a private company limited by shares incorporated in Abu Dhabi Global Market ("ADGM").

Registered office:
Office 1501, 15, Addax Port Office Tower
Al Rayfa Street
Abu Dhabi, Al Reem Island
United Arab Emirates

For the purposes of the ADGM Data Protection Regulations 2021, as amended from time to time (the "Data Protection Regulations"), Zamana Capital Limited is the controller of the personal data described in this Privacy Policy unless otherwise stated.

Questions about this Privacy Policy or our use of your personal data may be sent to [email protected].

2. Personal Data We May Collect

We have designed our website to collect as little personal data as reasonably necessary. We do not currently provide website account registration, newsletter subscriptions or online application facilities, and we do not currently use the website for behavioural advertising or marketing tracking.

Information you provide to us

If you contact us by email or otherwise communicate with us, we may process information including:

• your name;
• your email address and other contact details;
• your employer or organisation;
• your job title or professional role;
• the contents of your communication; and
• any other information you choose to provide to us.

Please do not send sensitive or confidential information through our general contact email unless necessary and appropriate.

Technical information

When you visit our website, our hosting, security or other technical service providers may automatically process limited technical information necessary to deliver and protect the website. This may include IP address; browser and device information; date and time of access; pages or resources requested; server and security logs; and information relating to attempted misuse or security incidents.

We do not currently use this information to build marketing profiles about visitors.

3. How and Why We Use Personal Data

We may process personal data where necessary for purposes including:

• responding to enquiries and communications;
• considering potential business relationships;
• communicating with clients, prospective clients, counterparties, advisers and other professional contacts;
• operating, maintaining and securing our website and information systems;
• preventing and investigating fraud, cyber threats and other misuse;
• complying with legal and regulatory requirements;
• establishing, exercising or defending legal rights;
• maintaining appropriate business and regulatory records; and
• pursuing our legitimate business interests where those interests are not overridden by the rights and interests of the individuals concerned.

Depending on the circumstances, our lawful basis for processing may include performance of or steps relating to a contract, compliance with a legal obligation, our legitimate interests, or consent where consent is appropriate or required.

Where we rely on legitimate interests, those interests may include operating and protecting our business, communicating with professional contacts, responding to enquiries and maintaining appropriate business records.

4. Cookies and Analytics

We currently seek to operate zamana.capital without analytics, advertising or behavioural-tracking cookies. Please see our Cookie Policy for further information.

If we introduce analytics, marketing technologies or other non-essential cookies in the future, we will review our consent arrangements and update this Privacy Policy and our Cookie Policy as appropriate.

5. Sharing Personal Data

We do not sell personal data. We may share personal data where reasonably necessary with:

• professional advisers, including legal, regulatory, compliance, tax and accounting advisers;
• technology, cybersecurity, hosting and communications providers;
• other service providers supporting our business;
• regulators, governmental authorities, courts or law-enforcement bodies where required or appropriate;
• counterparties or other persons where necessary in connection with a transaction, business relationship or legal obligation; and
• a purchaser, investor or successor in connection with a genuine corporate reorganisation, financing, merger, acquisition or transfer of all or part of our business, subject to appropriate safeguards.

Where third parties process personal data on our behalf, we seek to ensure that appropriate contractual and organisational protections are in place.

6. International Transfers

Zamana Capital operates in an international financial environment. Personal data may therefore, where necessary, be transferred to or accessed from jurisdictions outside ADGM.

Where the Data Protection Regulations require safeguards for an international transfer, we will seek to ensure that an appropriate transfer mechanism or other lawful basis is in place.

7. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including satisfying legal, regulatory, accounting, reporting and record-retention requirements.

The appropriate retention period will depend on factors including the nature of the information, the purpose for which it is processed, applicable regulatory or legal requirements and whether retention may be necessary to establish, exercise or defend legal rights. Technical and security logs may be retained for periods appropriate to security, troubleshooting and legal or regulatory requirements.

8. Security

We take appropriate technical and organisational measures designed to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction, alteration or disclosure.

No internet transmission or information system can, however, be guaranteed to be completely secure.

9. Your Rights

Subject to the Data Protection Regulations and any applicable limitations or exemptions, you may have rights in relation to your personal data, including rights to:

• be informed about how your personal data is processed;
• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request erasure of personal data in certain circumstances;
• request restriction of processing in certain circumstances;
• object to certain processing;
• receive certain personal data in a portable format where applicable; and
• exercise rights relating to certain automated decision-making and profiling.

Where processing is based on consent, you may also withdraw that consent, subject to applicable law.

To exercise a data-protection right or ask a question about our processing of your personal data, contact [email protected]. We may need to verify your identity before responding to a request.

You may also have the right to raise a concern with the ADGM Office of Data Protection.

10. Third-Party Websites

Our website may contain links to websites operated by third parties. We are not responsible for the privacy practices of third-party websites. You should review the privacy information provided by the relevant third party before providing personal data to it.

11. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes to our business, website, technology, regulatory obligations or applicable law. The current version will be published on zamana.capital, together with the date on which it was last updated.