Privacy Policy
How we collect, use and protect your personal data under the ADGM Data Protection Regulations
Effective date: 1 July 2026
Introduction
AG (Australian Gulf) Capital Limited ("we", "us", "our" or the "Firm") is committed to protecting the privacy
and security of the personal data we hold. This Privacy Policy explains how we collect, use, disclose, transfer
and store personal data, and the rights available to individuals whose personal data we process.
The Firm is a company established in the Abu Dhabi Global Market ("ADGM") under registration number
000007479, with its registered office at Al Khatem Tower, Abu Dhabi Global Market Square, Al Maryah Island,
Abu Dhabi, UAE. The Firm is authorised and regulated by the Financial Services Regulatory Authority ("FSRA")
of the ADGM (Financial Services Permission number 220056).
For the purposes of the ADGM Data Protection Regulations 2021 (the "Regulations"), the Firm is the data
controller in respect of the personal data described in this Policy.
2. Scope of this Policy
This Policy applies to personal data we process about visitors to our website, prospective and existing clients
and investors, their authorised representatives and beneficial owners, counterparties, service providers, job
applicants, and other individuals with whom we interact in the course of our business. It applies alongside any
additional privacy notice we may provide for a specific product, service or interaction.
3.Personal data we collect
Depending on our relationship with you, we may collect and process the following categories of personal data:
• Identity and background data — name, date and place of birth, nationality, gender, photograph,
passport, Emirates ID and other government identifiers, and information required to verify your identity.
• Contact data — postal address, email address and telephone number.
• Professional and relationship data — job title, employer, professional qualifications, and your role in
relation to a client or counterparty (for example, authorised signatory, director or beneficial owner).
• Financial and investor data — bank and payment details, source of funds and source of wealth, tax
residence and tax identification numbers, investment experience, risk appetite and client classification.
• Due diligence and compliance data — information obtained through know your customer ("KYC"), anti-
money-laundering ("AML"), counter-terrorist-financing, sanctions and politically exposed person
screening.
• Technical and usage data — IP address, device and browser information, and information about how you
use our website, collected through cookies and similar technologies.
• Communications data — the content and metadata of correspondence and, where applicable and
notified to you, recordings of telephone calls and electronic communications.
• Marketing preferences — your preferences in receiving marketing from us.
4. How we collect personal data
• Directly from you — when you contact us, complete forms, subscribe to updates, apply to invest, or
otherwise interact with us.
• Automatically — through cookies and similar technologies when you use our website (see section 11).
• From third parties — including your advisers and representatives, our group companies, fund
administrators, custodians, credit-reference and identity-verification agencies, sanctions and screening
databases, public registers and publicly available sources.
Purposes and lawful bases for processing
Under the Regulations we may only process personal data where we have a lawful basis to do so. The table
below sets out the main purposes for which we process personal data and the corresponding lawful bases.
| Purpose | Data used | Lawful basis |
|---|---|---|
| Responding to enquiries and providing information about our services | Identity, contact, professional | Legitimate interests; steps prior to entering a contract |
| Onboarding clients and investors and providing our services | Identity, contact, financial, investor | Performance of a contract; steps prior to entering a contract |
| KYC, AML, sanctions and financial-crime checks | Identity, due diligence, financial | Compliance with a legal obligation |
| Meeting regulatory, reporting, audit and record-keeping obligations | Most categories | Compliance with a legal obligation |
| Managing our relationship, administration and internal operations | Identity, contact, relationship | Legitimate interests |
| Marketing and sending updates about our services | Contact, marketing preferences | Consent and/or legitimate interests |
| Operating, securing and improving our website | Technical, usage | Legitimate interests; consent for non-essential cookies |
| Establishing, exercising or defending legal claims | As relevant | Legitimate interests; compliance with a legal obligation |
Where we rely on legitimate interests, we have assessed that our interests are not overridden by your
interests, rights and freedoms. You may ask us for further information about that assessment.
6. Marketing
Where required, we will obtain your consent before sending you marketing communications. You can ask us to
stop sending marketing at any time by using the unsubscribe link in our communications or by contacting us
using the details in section 13. Withdrawing consent does not affect the lawfulness of processing carried out
before withdrawal.
7. Disclosure of personal data
We may share personal data with:
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• members of our group and their personnel, where relevant to the purposes above;
• service providers and professional advisers who act on our behalf, including fund administrators,
custodians, banks, auditors, lawyers, IT and cloud-hosting providers, and screening and verification
providers;
• regulators, courts, law-enforcement and government authorities, including the FSRA, the ADGM
Registration Authority and the ADGM Office of Data Protection, where we are required or permitted to do
so;
• a prospective buyer or successor in the event of a reorganisation, merger, sale or transfer of our business
or assets.
We require those who process personal data on our behalf to do so only on our instructions and to keep it
secure.
8. International transfers
We may transfer personal data to recipients located outside the ADGM, including elsewhere in the United Arab
Emirates and in other countries. Where a recipient is in a jurisdiction that is not recognised by the ADGM as
providing an adequate level of protection, we put in place an appropriate safeguard permitted by the
Regulations — for example, standard contractual clauses adopted by the ADGM — or rely on another lawful
transfer mechanism. Where special categories of personal data are transferred, we do so under an appropriate
policy document. You may request further information about the safeguards used by contacting us.
9. Data retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including
to satisfy legal, regulatory, tax, accounting and reporting requirements, and to establish, exercise or defend
legal claims. In many cases we are required by FSRA rules and other applicable laws to retain records for a
minimum period (typically at least six years) after the end of our relationship with you. When personal data is
no longer required, we securely delete or anonymise it.
10. Data security
We maintain appropriate technical and organisational measures designed to protect personal data against
unauthorised or unlawful processing and against accidental loss, destruction or damage. These measures
include access controls, encryption where appropriate, staff training and confidentiality obligations. Where we
are required to do so under the Regulations, we will notify the Office of Data Protection and, where applicable,
affected individuals of a personal-data breach.
11. Cookies
Our website uses cookies and similar technologies to enable core functionality, to remember your preferences
and to understand how the website is used. Non-essential cookies are set only where you have consented. For
more detail, please see our Cookie Policy, or manage your preferences through the cookie banner on our
website.
12. Your rights
Subject to the conditions and exemptions in the Regulations, you have the right to:
• be informed about how we process your personal data;
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• access the personal data we hold about you and obtain a copy;
• have inaccurate or incomplete personal data corrected;
• have your personal data erased in certain circumstances;
• restrict or object to our processing in certain circumstances, including objecting to direct marketing;
• receive certain personal data in a portable format and, where technically feasible, have it transmitted to
another controller;
• withdraw consent where we rely on it; and
• not be subject to a decision based solely on automated processing that produces legal or similarly
significant effects.
We will respond to a valid request without undue delay and in any event within the period required by the
Regulations (generally two months, which may be extended for complex requests). Exercising these rights is
generally free of charge.
13. Contact and complaints
If you have any questions about this Policy, wish to exercise your rights, or would like to reach our Data
Protection Officer, please contact us at:
Data Protection Officer / Privacy Team — info@ausgulf.com
AG (Australian Gulf) Capital Limited, Al Khatem Tower, Abu Dhabi Global Market Square, Al Maryah Island, Abu
Dhabi, UAE
If you are not satisfied with how we have handled your personal data, you have the right to lodge a complaint
with the ADGM Office of Data Protection / Commissioner of Data Protection. We would, however, appreciate
the opportunity to address your concerns before you do so.
14. Changes to this Policy
We may update this Policy from time to time. The current version will always be available on our website, and
the effective date is shown at the top of this document. Material changes will be notified as required.
