Privacy Policy

This Privacy Policy explains how Azimut (DIFC) Limited and/or Azimut (ME) Limited (“Azimut”, “we”, “us”, “our”), collects, uses, shares and otherwise processes your Personal Data in connection with your relationship with us as an Azimut client, acting for a client or being generally interested in our services and our publications in accordance with the DIFC Data Protection Law No. 5 of 2020 and the Data Protection Regulations and ADGM Data Protection Regulations 2021 (together, the “Law”).

Should you have any questions about this Privacy Policy, you can contact us at compliance-dubai@azimut.ae or compliance-abudhabi@azimut.ae.

We may provide supplemental privacy notices 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 Personal Data. Those supplemental notices should be read together with this Privacy Policy.

The term “Personal Data” as used in this Privacy Policy means any information relating to you such as your name, contact details, bank account details etc. Personal Data does not include data from which you can no longer be identified such as anonymised aggregate data.

The kinds of Personal Data we may collect include your contact details (such as your address, email address and telephone number) and information such as your job title. We may request this data from you and/or we collect the Personal Data you choose to provide to us, e.g. if you contact us by letter, telephone, email or any other means of electronic or personal communication (e.g. signing up for a newsletter, filling in a form, etc.).

We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data only:

1. if you have consented to us doing so;
2. if we need it to perform the contract, we have entered into with you;
3. if we need it to comply with a legal obligation; or
4. if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests will be the providing of services by us, administrative or operational processes within Azimut and direct marketing.

We will use your Personal Data to deliver services to you and/or the institution you work or act for. We may also use your Personal Data to inform you about our services, new developments in the jurisdictions we operate and our marketing events.

Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

We may need to request specific information from you to help us confirm your identity and ensure your right to access Personal Data (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes during your relationship with us.

It is in your sole discretion to provide Personal Data to us. If you do not provide us with all or some of the Personal Data we request, we may not be able to accept an engagement from you, to provide all or some of our services, to enter into a contract with you or to send you the requested (marketing) information.

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 which is compatible with the original purpose. 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.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

When using your Personal Data for the purposes and on the legal basis described above, we may share your Personal Data with our other Azimut offices around the world as well as other services providers we work with. We may also have to share your Personal Data with regulators, public institutions, courts or other third parties.

>For the purposes described above we may have to transfer your Personal Data from the Dubai International Financial Centre or the Abu Dhabi Global Market to an Azimut office or a third party outside of the DIFC or ADGM and to a jurisdiction which is not deemed to have in place an adequate level of protection for Personal Data. We will always ensure that there is a legal basis and a relevant safeguard method for such data transfer so that your Personal Data is treated in a manner that is consistent with and respects the applicable laws and regulations on data protection. If you require further information on this, you can request it from compliance-dubai@azimut.ae or compliance-abudhabi@azimut.ae

You have rights which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:

• request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
• request rectification of your Personal Data;
• request the erasure of your Personal Data;
• request the restriction of processing of your Personal Data;
• transfer your Personal Data to a third party (data portability);
• object to the processing of your Personal Data.

You also have the right to receive your Personal Data in a structured, commonly used and machine-readable format and to have us transmit those Personal Data to another controller, if you have provided these Personal Data to us, if the processing is based on consent or on a contract and the processing is carried out by us by automated means, subject, however, to legal restrictions which may apply.

If you wish to exercise any of these rights, please contact us at compliance-dubai@azimut.ae.

You also have the right to make a complaint at any time to the relevant Commissioner of Data Protection in DIFC and/or ADGM.

In case you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. To withdraw your consent, please contact compliance-dubai@azimut.ae or compliance-abudhabi@azimut.ae. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. In case we processed your Personal Data for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Data for such marketing purposes.

We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period for your Personal Data, we will 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.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

Upon expiry of the applicable retention period, we will securely destroy your Personal Data in accordance with applicable laws and regulations.

You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Policy. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We do not apply automated decision-making techniques.

We reserve the right to update this Privacy Policy at any time, and we will make an updated copy of such Privacy Policy available on our website.

If you have any concerns or require any further information, please do not hesitate to contact compliance-dubai@azimut.ae or compliance-abudhabi@azimut.ae

This Privacy Policy was last updated in September 2024.