1. Introduction

FracAssets (DIFC) Limited (FracAssets) is committed to providing the highest level of privacy and security regarding the collection and use of their customers’ personal information. This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your personal information when you use the service, including when contacting us and tells you about your privacy rights and how the law protects you.

Personal information comprises all the details FracAssets holds or collects directly or indirectly (including via cookies or other similar tools) about you, your transactions, financial information, interactions or dealings with FracAssets, including information received from third parties and information collected through the use of our websites.

In case you have any questions regarding this privacy policy or the security of your personal information, you can reach out to us at contactus@fracassets.com.

For more information about our use of cookies please refer to ourCookie Policy.

Please read this privacy policy carefully. In opening an account with us you consent to our use of your personal information in accordance with our Privacy Policy.

Use of the FracAssets Website is subject to our Terms of Use and any products and services supplied are subject to ourTerms and Conditions. By visiting www.fracassets.com (“our site”) you are accepting and consenting to the practices described in this policy.

2. Collection of your Personal Data

There are a number of laws that set out important standards regarding information that identifies a living individual. This is known as “personal data.” All organizations processing personal data must do so fairly and lawfully.

At FracAssets we treat all of our obligations seriously and take the steps necessary to comply when we store and process your personal data.

It is essential for us to collect, store and process only the minimum required amount of personal data so that we can offer and perform our services. Typical information we might ask for includes your name, your address, other contact details and Know Your Customer (KYC) related information. In addition our servers automatically receive and record information on all visitors to our websites.

We will record your personal data (apart from the automatic information detailed above) once you have fully registered with us.

Your personal data will be collected in a number of ways, including the following:

While you communicate with us (For example while registering for our services);
When you invest in any of our products or services;
When you enter a competition or promotion;
When you make payments or update your account details; and
When you visit our website (for example by cookies, technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other browser-generated information such information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page, any phone number used to call our customer service number or email id used to contact us).
While assessing customer suitability for products and services.
During Know Your Customers (KYC) assessments and setting investor risk profiles.
While conducting market research and surveys with the aim of improving our products and services.
For the prevention, detection, investigation and prosecution of crime (including without limitation, money laundering, terrorism, fraud and other financial crime) in any jurisdiction, identity verification, government sanctions screening and due diligence checks.
While complying with local or foreign law, regulations, voluntary codes, directives, judgments or court orders, agreements between any authority, regulator or enforcement agency policies, reporting requirements under financial transaction legislation and demands or requests of any authority, regulator, enforcement agency or exchange body.
While seeking professional advice, including in connection with any legal proceedings (including any prospective legal proceedings) for obtaining legal advice or establishing, exercising or defending legal rights.

3. Use of your Personal Data

We maintain and use your personal data for the following main purposes:

We reserve the right to access and disclose your personal data if we are required to do so by law, or if it is necessary for the proper operation of our systems, the protection of FracAssets or its users and customers, or for the enforcement of our Terms and Conditions;
Processing applications made by you, running your accounts, providing our services, contacting you and servicing our relationship with you;
Administration and accounting, billing and auditing and other legal purposes;
Security, payment verification, preventing and detecting money laundering, fraud and other crime, recovering debt; and
Generating statistics on our users, such as the popularity of certain of our services, about the “traffic” on our websites.
To provide you, or permit selected third parties to provide you, with information about products or services we feel might interest you.
To notify you about improvements to our service; and
To ensure that content from our site is presented in the most effective manner for you and for your computer system
To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
As part of our efforts to keep our site safe and secure;
To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
To make suggestions and recommendations to you and other users of our site about products or services that may interest you or them.

Except where you have opted out we may also use your personal data to keep you updated about relevant products and services. We may use your personal data including your contact details, your application details and details of the services we provide you with and how you use them, to decide what products and services may be of interest to you. We may contact you by telephone, post, email and other electronic messages such as short text, video and picture messaging with information, news, events, seminars and webinars on our products and services.

In case you wish to opt out of our tracking, you can email us at contactus@fracassets.com.

4. Protection of your personal data

The security of your personal information and protecting the safekeeping and confidentiality of your personal information is important to us. When using external service providers, we require that they follow the same standards as FracAssets. Personal information may be transferred or stored at a location outside of your country of residence. Regardless of where personal information is transferred or stored, we take all steps reasonably necessary to ensure that your personal information is protected.

The Internet is not a secure form of communication and sending and receiving information over the Internet carries with it risks including the risk of access and interference by unauthorized third parties. Information passing over the Internet may be transmitted internationally (even when the sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than your country of residence. We do not accept responsibility or liability for the confidentiality, security or integrity of your personal information in connection with its transmission over the Internet.

However, we take all reasonable care in the collection, storage, processing and disclosure of your personal data and have implemented internal security procedures to reduce the risk that unauthorized parties will be able to access the information. It is because of these security procedures that we may ask for proof of identity before we disclose any personal information about you.

To help protect your personal data and reduce the risk of it being intercepted by unauthorized third parties our secure servers use industry-standard Secure Socket Layer (SSL) and Transport Layer Security (TLS) technology when you submit information to us through our website. This security is documented by the usage of the secure “https” protocol and the padlock on the URL bar.

You can also help to protect your personal data, by following the guidelines below:

Choose a strong password that you will be able to remember and would be hard for someone else to guess. Preferably it should include special characters (such as “!” or “@” for example) and numbers. We recommend that you change it regularly and if you need to write it down, always keep it in a safe place;
Ensure that no-one can see the details you are entering when you log-in;
Remember to close your browser each time you log-off and end your session and, if possible, clear any history of the websites you have visited and that your browser may have saved or “cached”; and never disclose your account details to anyone;
Ensure that the software you use has installed the latest security upgrades and that your software protection is up-to-date.

To get the best from our services, please keep your personal data (including your mobile number and email address) accurate and up to date. You can do this by logging into our secure website.

The transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we receive your information, we use strict procedures and security features to try to prevent unauthorized access.

5. Retention & Monitoring

Information relating to your financial transactions with us will be kept for the period required by relevant tax and revenue legislation.

Your personal profile and data will be retained whilst you continue to be an active member, and for up to 8 years following the discontinuance of membership activity.

In all other cases, we will erase or anonymise your data once it is no longer necessary for the purpose we obtained it for.

To the extent permitted by law, FracAssets may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations.

6. Disclosure of your personal information

We allow third-party service providers to process personal information where this is needed in connection with a service they provide FracAssets. These arrangements may involve your personal information being located in various countries around the world including the United Arab Emirates where FracAssets has its head office.

You should be aware that different privacy laws may apply in these countries from any laws that may apply in the country where you are located. FracAssets will always strive to adopt the highest standards of privacy protection wherever your personal information is located. Our privacy policy does not apply to third-party websites where our online advertisements are displayed or to linked third-party websites that we do not operate or control.

We may share your information with selected third parties including:

Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
Analytics and search engine providers that assist us in the improvement and optimization of our site.

We may disclose your personal information to third parties:

If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements between you; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

7. Withdrawal of consent

You may withdraw consent for data processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal;

You may also instruct us not to process your personal information for marketing purposes. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.

You can reach out to us at contactus@fracassets.com should you wish to exercise these rights.

8. Right of Access

Subject to applicable law, regulations and/or real-estate/financial industry guidelines, you may have the right to request a copy of the personal information processed in relation to you. FracAssets may be allowed, by law, to charge a fee for providing you with a copy of your personal information.

To request a copy of your personal information, please reach out to us at contactus@fracassets.com.

9. Third-Party Websites

The website contains links to other websites. We are not responsible for the privacy policies or practices of third-party websites.

10. Social Media

FracAssets operates channels, pages and accounts on some social media sites to inform, assist and engage with customers. We monitor and record comments and posts made on these channels about FracAssets so that we can improve our products and services.

FracAssets is not responsible for any information posted on those sites other than the information we have posted ourselves. We do not endorse the social media sites themselves or any information posted on them by third parties.

11. International Data Transfers

Information that FracAssets collects may be stored and processed in and transferred between any of the countries in which we operate to enable us to use the information in accordance with this privacy policy.

The Information which you provide may be transferred to countries with weaker privacy and data protection laws than your country of residence.

In addition, personal information that you submit for publication on the website will be published on the internet and may be available, via the internet, around the world. FracAssets cannot prevent the use or misuse of such information by others. You expressly agree to such transfers of personal information.

12. Updates to this Privacy Policy

FracAssets may in its absolute discretion update this privacy policy from time to time. It is therefore recommended that you review it regularly.

13. Contact

In case you have any questions, comments or concerns regarding this privacy policy, please feel free to write to us at contactus@fracassets.com.