WRise Wealth Management Middle East Limited “WRISE” is committed to protecting the confidentiality and security of personal data collected and conducting in our business.

The purpose of this document Data Protection Privacy Statement “Privacy statement” is to inform you of how WRISE manages Personal Data (as defined below) which is subject to the Dubai International Financial Centre ("DIFC") Data Protection Law (DIFC Law No. 5 of 2020) (the "Law"). The privacy statement will detail the collection, use and disclosure of your personal data.

 

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 WRISE for the purposes of offering you 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:

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1. Personal Data

 

In this Privacy Statement, "Personal Data" refers to any data, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, national identity card, passport or other identification number, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.

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2. Collection of Personal Data

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2.1 Generally, we collect Personal Data in the following ways:

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a) when you submit any form, including but not limited to application forms or other forms relating to any of our services.

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b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;

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c) when you interact with our staff, including relationship managers and their assistants, example via telephone calls (which may be recorded), letters, fax, face-to-face meetings and emails;

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d) when you use some of our services provided through online and other technology platforms, such as websites.

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e) in connection with any investigation, litigation, registration or professional disciplinary matter, criminal prosecution, inquest or inquiry which may relate to you or any Connected Person; and/or

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f) when you submit your Personal Data to us for any other reason.

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2.2 When you browse our website and platforms, you generally do so anonymously but please see the section below on cookies. We do not, at our website and platforms, automatically collect Personal Data, including your email address unless you provide such information or login with your account credentials.

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2.3 If you provide us with any Personal Data relating to a third party (for example, information of your spouse, children, parents, or a Connected Person), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with his/her Personal Data for the respective purposes.

"Connected Person" may include but is not limited to any beneficial owner, authorised signatory, director, shareholder, officer of a company, partner or member of a partnership, settlor, trustee, beneficial owner, protector or grantor of trust, mandate holder, power of attorney holder, surety, third party security provider, provider of funds, founder and/or employee, payee of designated payment, representatives, agents or nominees.

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2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with services you have requested. You acknowledge that you should inform WRISE immediately of any change of facts or circumstances which may render any information or Personal Data previously provided inaccurate, untrue or incorrect and provide any information or documentation as WRISE may reasonably require for the purposes of verifying the accuracy of the updated information or Personal Data.

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3. Performance of Contract

 

• On receiving your application with you providing the required documentation WRISE shall carry out the account opening process.

• Managing and administering your portfolio and any related account on an ongoing basis which involves your personal data.

• Disclosures to third parties such as auditors, regulatory, tax authorities and technology providers;

• Recording, maintaining, storing and using recordings of telephone calls that you make to and receive from WRISE, the Administrator, or the Relationship Manager and their delegates or 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 relationship with WRISE, dispute resolution, record keeping, and security.

 

i. Circulating periodic reports.

ii. Responding to queries or providing you support.

iii. For any other purpose as provided for in the Agreement between us

 

4. Consent

 

By interacting with us, submitting information to us, or signing up for any products or services offered by us, you acknowledge that WRISE may collect, use, disclose and share your Personal Data, and disclose such Personal Data to WRISE DIFC’s authorised service providers and relevant third parties in the manner set forth in this Privacy Statement.

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 WRISE at the address below:

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Contact.ae@wrise.com

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Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, we may not be able to continue to provide our products or services to you, administer any contractual relationship in place or respond to a query.

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5. Compliance with legal obligations

 

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 and other related regulations set by globally recognized AML agencies, all investors are required to be identified. For this purpose, certain documentation will be required at the time of application.

 

• CRS/FATCA: WRISE is obliged to collect certain information about each investor’s tax arrangements. For CRS/FATCA reporting purposes, please note that in certain circumstances WRISE 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 – WRISE 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.

 

6. 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 WRISE or their duly appointed agents and any of their respective related, associated or affiliated companies for the purposes specified above.

These data processors will handle your information in accordance with applicable Data Protection Legislation.

WRISE may disclose your personal data to other third parties where required by law. This may include disclosure to third parties such as auditors and the regulatory bodies, taxation authorities and technology providers.

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6.1 WRISE will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas, including the United Arab Emirates outside the DIFC, or in the DIFC:

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a) the Companies;

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b) the custodian banks in relation to transactions for your account including purchasing and selling of securities and investment products, fund transfers, payments, issuance of standby letters of credit, banker’s guarantees or letters of undertaking and drawing of cheques;

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c) companies providing services relating to insurance and/or reinsurance;

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d) insurers or brokers in relation to the insurance products or services that you have applied for or purchased;

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e) agents, contractors, vendors, installers, or third-party service providers who provide administrative or operational services to WRISE, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to WRISE;

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f) our professional advisers such as our auditors and lawyers;

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g) relevant government regulators, government ministries, exchange, statutory boards or authorities or law enforcement agencies who have jurisdiction over WRISE or any Company or over any transaction entered into by you, such as the Dubai Financial Services Authority and where applicable, competent authorities in the United Arab Emirates outside the DIFC, and other relevant authority;

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h) any person to whom WRISE or any of the Companies is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to WRISE or any of the Companies, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which WRISE or any of the Companies are expected to comply, or any disclosure pursuant to any contractual or other commitment of WRISE or any of the Companies with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or industry bodies or associations of financial services providers, all of which may be within or outside the DIFC and may be existing currently and in the future; and/or

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i) any other party to whom you authorise us to disclose your Personal Data to.

When transferring your Personal Data overseas to countries which do not have data protection laws or to countries where your privacy will not be protected as extensively, including transfers out of the DIFC to other parts of the United Arab Emirates, we will implement appropriate measures to ensure that your Personal Data remains protected and secure while and for as long as it remains under our control, for example, by implementing specific contractual clauses with the entities to whom we share your personal data.

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7. Transfers Abroad

 

Your data will be processed outside of the DIFC. 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 WRISE.

 

8. Retention period

 

WRISE will retain your personal information for as long as is needed to fulfil the purposes outlined in our Privacy Statement or as required or permitted by law.

 

9. Security Measures to Protect your Data

 

We maintain reasonable and appropriate security measures to protect Customer Data 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 authorised personnel.

 

We have put in place procedures to deal with any suspected data security breach and will notify you and the data protection regulator, the DIFC Commissioner of Data Protection (the "Commissioner") of a suspected breach where we are legally required to do so, or we consider it appropriate to do so.

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10. Use Of Cookies

 

10.1 Our websites and platforms use cookies and other technologies. Cookies are stored in your browser’s file directory, and the next time you visit the website or platform, your browser will read the cookie and relay the information back to the website, platform or element that originally set the cookie.

 

10.2 We may employ cookies and other technologies as follows:

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i. tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;

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ii. making our websites and platforms easier to use. For example, cookies may be used to help speed up your future interactions with our websites and platforms;

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iii. collating information on a user’s search and browsing history;

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iv. when you interact with us on our websites and platforms, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the website or platform, the browser used by a visitor, the operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp.

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v. using cookies that are necessary in order to enable our websites and platforms to operate, for example, cookies that enable you to log onto secure parts of our websites and platforms;

 

If you do not agree to our use of cookies and other technologies as set out in this Data Protection Policy, you should delete or disable the cookies associated with our websites and platforms by changing the settings on your browser accordingly. However, you may not be able to enter certain part(s) of our websites or platforms. This may also impact your user experience while on our websites or platforms.

 

11. Your data protection rights

 

Your data protection rights are as under:

• 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 have the right to object to processing where WRISE is processing personal data for legitimate interests.

• You have the right to withdraw your consent – withdraw your consent at any time to the use of your Personal Data for a particular purpose

 

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 WRISE is not as per the regulation in force.

You may request for your rights as outlined below by submitting your written request to us via:

 

Data Privacy Officer:

Samar Kayali
WRise Wealth Management Middle East Limited
Address: Office 501A, level 5, Gate District 2, DIFC

Tel : +971 4 267 5002 
Fax : +971 4 393 5312
Email : dpo.ae@wrise.com

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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.

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.