HULT Management, a management consultancy and holding company with registration number ICC20210657; and HULT Private Capital SPV LT, a logistics real estate company, with registration number ICC20211042, both registered under the authority of Ras Al Khaimah International Corporate Centre (RAK ICC) in United Arab Emirates (UAE) and both having registered address at Level 27, Cluster X, Jumeirah Bay X3, Office 2702, PO BOX 71301, JLT, Dubai, UAE, operate as HULT Private Capital in United Arab Emirates (collectively referred to hereinafter as “HULT Private Capital UAE” or “HULT UAE”) or any of its associated companies (see Appendix for an overview with registered numbers and addresses) (« HULT UAE » / « we » / « our » / « us ») is committed to protecting and respecting your privacy. This policy (together with our Website Terms of Use, Website Privacy Policy. Cookies Policy and any other documents referred to in them) sets out the basis on which any personal information that we collect from our clients (“you” / “your”) or that you provide to us, will be processed.

This policy applies to personal information we collect when you interact with us including when you engage our services, when you refer work to us, when you make an enquiry, attend an event or request information from us or because of your relationship with our clients or staff.  If you engage us to carry out work for you, we will have client confidentiality obligations to you, as set out in our agreed instructions with you.

Please note that this policy does not apply to employees, consultants or other workers employed or engaged by us, in which respect our employee fair processing notice and/or related notices shall instead apply.

Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.

1. About us

HULT UAE is the data controller in respect of your personal data. This means that we are responsible for deciding how we hold and use personal data about you.

2. What information we collect and how we will use it

2.1 We collect personal information so that we can operate effectively and provide you with the best possible service. The information we collect depends on the context of your interactions with us and how you use our services. It also depends on the choices you make.  You may choose not to provide certain information but if you do, and that information is necessary to provide a particular feature, then you may not be able to use that feature. We will only use your personal information where we have a valid lawful basis to do so.

2.2 We have a duty to process personal data fairly, lawfully and in a manner that you would expect given the nature of our relationship with you. Where we have a legal basis to use your personal information without consent (as set out in the tables below), this policy fulfils that duty by giving you appropriate notice and explanation of the way in which your personal information will be used. Where consent is required for our use of your personal information, we will ask you to positively opt-in. Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.

2.3 If you have any questions or require any further information regarding our use of your personal information please contact us at [email protected], HULT Management, Level 27, Cluster X, Jumeirah Bay X3, Office 2702, PO BOX 71301, JLT, Dubai, United Arab Emirates, tel.: +971 4566 4052.

2.4 The table below summarizes what information we collect about you; explains how we intend to use it and what our legal basis is for using it. In the table below the following types of information include:

• Identity information: name of company, organisation and/or individual, title, position, date of birth, place of birth, nationality, marital status, and information concerning family members.
• Contact information: postal addresses, email addresses and telephone numbers.
• Financial information: tax and audit information, bank account details, payment information, personal financial details, and insurance information.
• Employment information: employment history, National Insurance number, insurance details, salary, and benefits details.
• Special category information: race or ethnic origin, photographs, passport details, health, and medical information.

3. Provision of financial and other services

Why are we processing personal information about you?

• To enable us to provide financial or other services to you or your organisation
• To conduct necessary identity checks before providing financial or other services to you or your organisation

What personal information will we collect about you?

• Identity information
• Contact information
• Financial information
• ID documentation (including but not limited to passports, driving licenses and utility bills)
• Signatures
• Other personal information you provide to us concerning your business and/or personal interests

We may collect additional categories of personal information (including special category personal information) if relevant to the particular type of financial services we are providing. For further information see the relevant section:

• Services for individuals
• Services for businesses
• Services relevant to non-profit organizations and foundations

How will we collect personal information from you?

Collected by us through our provision of financial or other services to you or the organization you represent including:

• Information provided by you when instructing us
• Information provided by you when you:
  • Contact us (including by email, telephone, post, fax, SMS, or other messaging service or in person)
  • Sign up for or attend one of our events or meet us at external events or provide us with your business card and
• Information received from third parties including:
  • When they refer you to us
  • Other parties to matters on which we are instructed and
• Information collected by us through searches via company searching databases or agencies from publicly available information about you or your organisation

Legal basis for processing

• Necessary steps prior to entering a contract with you or your organisation.
• Necessary for the performance of a contract with you or your organisation.
• Necessary to comply with our legal obligations.

3.1 Services to individuals (including advice relating to financial investments)

Why are we processing personal information about you?

To enable us to provide financial or other services to individuals

What personal information will we collect about you?

Personal information that is relevant to your instructions and necessary for management of financial investments including:

• Identity information
• Contact information
• Financial information
• ID documentation (including but not limited to passports, driving licenses and utility bills)
• Signatures
• Employment information
• Immigration and travel information
• Photographs
• Other personal information you provide to us concerning your business and/or personal interests

In addition, we may collect the following special categories of information if relevant to instructions from you including:

• Race or ethnic origin
• Religious or philosophical beliefs
• Biometric data
• Health and medical information

In addition, we may process personal information relating to criminal convictionswhere permitted by law

How will we collect personal information from you?

Collected by us through our provision of financial or other services to you including:

• Information provided by you
• Information received from third parties including:
  • When they refer you to us
  • Other parties to matters on which we are instructed and
• Information collected by us from publicly available information about you or your business interests
• Information collected by us while providing financial services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you.

Legal basis for processing

• Necessary for the performance of a contract with you
• Processing relates to personal data which manifestly made public by the data subject
• Your consent

3.2 Services to businesses (including advice relating to financial investments).

Why are we processing personal information about you?

To enable us to provide financial or other services to your business

What personal information will we collect about you?

Personal information that is relevant to your business, our instructions and necessary for management of financial investments including:

• Identity information
• Contact information
• Financial information
• ID documentation (including but not limited to passports, driving licenses and utility bills)
• Signatures
• Employment information
• Immigration and travel information
• Photographs
• Other personal information you provide to us concerning your business and/or personal interests

In addition, we may collect the following special categories of information if relevant to instructions from you including:

• Race or ethnic origin
• Religious or philosophical beliefs
• Biometric data; and
• Health and medical information

How will we collect personal information from you?

Collected by us through our provision of financial or other services to you or the organization you represent including:

• Information provided by you
• Information received from third parties including:
  • When they refer you to us
  • Other parties to matters on which we are instructed, and
• Information collected by us from publicly available information about you or your organisation
• Information provided by you while instructing us
• Information collected by us while providing financial services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you.

Legal basis for processing

• Necessary for the performance of a contract with your business
• Processing relates to personal data which manifestly made public by the data subject
• Your consent

3.3 Services relevant to non-profit organizations and foundations.

Why are we processing personal information about you?

To enable us to provide services to non-profit organizations and foundations

What personal information will we collect about you?

Personal information that is relevant to instructions and necessary for management of financial affairs including:

• Identity information
• Contact information
• Financial information
• ID documentation (including but not limited to passports, driving licenses and utility bills)
• Signatures
• Employment information
• Immigration and travel information
• Photographs
• Other personal information you provide to us concerning your business and/or personal interests

In addition, we may collect the following special categories of information if relevant to your instructions including:

• Race or ethnic origin
• Religious or philosophical beliefs
• Biometric data; and
• Health and medical information

How will we collect personal information from you?

Collected by us through our provision of financial or other services to you or the organization you represent including:

• Information provided by you
• Information received from third parties including:
  • When they refer you to us
  • Other parties to matters on which we are instructed, and
• Information collected by us from publicly available information about you or your organisation
• Information provided by you while instructing us
• Information collected by us while providing services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you.

Legal basis for processing

• Necessary for the performance of a contract with your business
• Processing relates to personal data which manifestly made public by the data subject
• Your consent

4. 4. Response to enquiries and requests for information

Why are we processing personal information about you?

• To deal with enquiries, correspondence, or complaints.
• To decide if someone else can assist with your enquiry (including experts, advisers, and suppliers)

What personal information will we collect about you?

• Identity information
• Contact information

Any other personal information you provide to us relevant to the inquiry or issue raised.

How will we collect personal information from you?

Collected by us while dealing with enquiries or other requests made by you or the organization you represent including:

• Information provided by you when you:
  • Contact us (including by email, telephone, post, fax, SMS, or other messaging service or in person)
  • Sign up for or attend one of our events or meet us at external events or provide us with your business card.
• Information received from third parties (including other professionals when they refer you to us)
• Information collected by us while providing our services (including information collected by us from publicly available information about you or your organisation)

Legal basis for processing

To enable us to pursue our legitimate interests to provide information or services requested; or to deal with complaints.

5. Organization of meetings, hosted events, and travel

Why are we processing personal information about you?

To enable us to provide events, travel and other services on event or travel related matters

What personal information will we collect about you?

Personal information that is relevant to instructions and necessary for organization of events or travel including:

• Identity information
• Contact information
• ID documentation (including but not limited to passports, driving licenses and utility bills)
• Signatures
• Immigration and travel information documents
• Photographs
• Other personal information you provide to us concerning your involvement in an event or travel
• In addition, we may process the following special categories of information if relevant to an event or travel including where you provide it to us, information about your dietary requirements and allergies
• Images captured by our offices’ CCTV

How will we collect personal information from you?

Provided by you when you:

• Contact us (including by email, telephone, post, fax, SMS, or other messaging service or in person)
• Sign up for or attend one of our events or meet us at external events or provide us with your business card

Collected by us through our provision of travel services to you or the organization you represent.

Information collected by us from publicly available information about you or your organization.

Received from third parties (including other professionals when they refer you to us)

Provided by you

Collected by us while providing services where information has already been disclosed in court or public documents by you, or at the request of or on behalf of you.

Images captured when you visit our offices.

Legal basis for processing

• Necessary for the performance of a contract with you.
• To enable us to pursue our legitimate interest to deliver the services requested.
• Your consent
• Processing relates to personal data which are manifestly made public by the data subject
• To enable us to pursue our legitimate interest to maintain the safety and security of our premises.

6. Operation of our business

Why are we processing personal information about you?

To manage our relationship with you or your organization and exercise our contractual rights and meet our contractual obligations

To enable us to run our business in an efficient and proper manner including to:

• Carry our data analysis
• Manage our financial position and business capability
• Manage risk
• Meet our professional obligations
• To comply with our legal obligations

What personal information will we collect about you?

• Identity information
• Contact information
• Financial information
• Other personal information you provide to us concerning your business and personal interests
• Details of your attendance in meetings and other events we host

How will we collect personal information from you?

• Through our provision of financial or other services to you or the organisation that you represent (for further information see section 3 above)
• Collected by us while dealing with enquiries or other requests raised by you or the organisation that you represent (for further information see section 4 above)
• Collected by us while arranging a meeting or other event or meetings of communications with you (for further information see section 5 above)

Legal basis for proceeding

• To enable us to pursue our legitimate interest to manage our business relationships.
• To enable us to pursue our legitimate interest to run our business in an efficient and proper manner.
• Necessary for the performance of a contract with you
• To comply with our legal obligations

7. Marketing and business development

Why are we processing personal information about you?

• Where you have provided us with your consent to send you marketing communications, newsletters, information about events and updates that may be of interest to you (for further information see section 13 below)
• To send you, unless you have opted out, marketing communications, newsletters, information about events and updates. Where we are using a personal email address (or you are a sole trader or a partner in a partnership that is not a limited company or a limited liability partnership we will only send information relating to similar services to those provided to you in the past.
• To keep records and maintain contact with clients and third-party contacts to grow our business.

What personal information will we collect about you?

• Identity information
• Contact information
• Where provided by you, your areas of interest

How will we collect personal information from you?

• Provided by you when you register your interest in our services with us
• Collected by us while providing or negotiating the provision of services to you (for further information see section 3 above)
• Provided by you when we instruct you to provide a service
• Provided by you when you introduce yourself to use for future work
• Provided by other professionals, agencies, or other bodies when they recommend you to us
• Collected by us while providing our services (including information collected by us from publicly available information about you or your organisation)

Legal basis for processing

• Your consent (for further information see section 13 below)
• To enable us to pursue our legitimate interest to maintain contact with our clients, third party contacts and to grow our business (for further information see section 13 below).

8. Sharing your information

8.1 We will only share personal data with third parties if we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality, and security standards.

8.2 You acknowledge that we may share your personal information with third parties where:

      8.2.1 you have consented to us sharing your personal information in this way;

      8.2.2 we are under a legal, professional, or regulatory obligation to do so (such as to comply with money laundering requirements);

      8.2.3 it is necessary to perform our obligations under our agreed instructions with you or where we have another legitimate interest in doing so that is not overridden by your interests and fundamental rights. For example, to protect our clients or to operate and maintain the security of our computer systems;

      8.2.4 we use third-party high-qualityservice providers to support us in the performance of the activities set out above;

      8.2.5 we also may from time to time provide your contact details to other businesses in connection with our normal business interactions with you, including: restaurants, caterers, event agencies, travel agents, airlines, and car rental providers.

8.3 Further information on how client information may be shared and processed can be found in our agreed instructions with you. We have identified key third-party service providers above; if you require further information regarding the identity of other third parties, we use please e-mail [email protected].

8.4 We may also share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or otherwise to comply with the law.

8.5 We require all our third-party service providers to take appropriate and stringent security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes in accordance with our instructions.

8.6 In the course of providing our services and operating our business it will be necessary for us to share personal information and by signing our agreed instructions with you, you are consenting to this transfer of data. 

8.6 In the course of providing our services and operating our business it will be necessary for us to share personal information and by signing our agreed instructions with you, you are consenting to this transfer of data. 

8.7 In addition, some of the third parties with whom we share personal information may need to transfer your personal information outside the jurisdiction in which you provide it. This may also involve a transfer of your information to locations outside the European Economic Area (EEA).  The level of protection in countries outside the EEA may be less than that offered within the EEA. To ensure that your personal information receives an adequate level of protection, we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with, and which respects the EU laws on data protection. Where our third-party service providers process personal data outside the EEA while providing services to us, our contractual arrangements with these providers will include appropriate measures to meet EU-approved data protection obligations, usually standard contractual clauses.  If you require further information about these protective measures, please email [email protected]

9. Storing your information

9.1 The personal information that we hold about you may be transferred outside of the EEA to be processed and stored. We will take all steps reasonably necessary to ensure that storage of your personal information receives an adequate level of protection and is treated in a way consistent with EU laws on data protection. If you require further information about these protective measures, you can request it [email protected].

9.2 Your personal information will be retained in accordance with our data retention policy which categorizes the information we hold and provides appropriate retention periods for each category, based on the purpose for which the information is processed and considering legal and regulatory requirements, limitation periods for taking legal action, good practice, and business requirements.

9.3 n some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. If you require further information regarding our data retention policy, please e-mail [email protected].

10. Children’s information

10.1 If you become aware that your child or any child under your care has provided us with information without your consent please contact us at [email protected], HULT Management, Level 27, Cluster X, Jumeirah Bay X3, Office 2702, PO BOX 71301, JLT, Dubai, United Arab Emirates, tel.: +971 4566 4052.

11. Keeping your information secure

11.1 All information that you provide to us is stored on secure servers. We have put in place (and ensure that anyone we share your personal information with has put in place) appropriate measures to protect the security of your information.

11.2 The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted via the internet and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access or inadvertent disclosure.

11.3 You are responsible for keeping confidential any passwords that you must access our services. Please do not share your passwords with anyone else. If you lose control of your password, you may lose control over your personal information. If your password has been compromised for any reason, please let us know immediately by contacting us at: [email protected]. 

11.4 We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

11.5 We do not collect or store credit and debit card information. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained from [email protected].

11.6 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

12. Your Rights

12.1 You have the right under data protection laws to access information held about you, subject to certain conditions, and to request its rectification or deletion.

12.2 If you would like to access, update, or amend the information which we hold about you or would like us to stop using your personal information please contact [email protected].

Your rights in connection with your personal information

12.3 By law you have the right to:

      12.3.1 Request access to your personal information (commonly known as a « data subject access request »). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. We will need to prove your identity before we release any personal information to you.  This right is subject to a number of exemptions which allow information to be withheld in certain circumstances. For example, subject access rights are excluded where compliance would involve disclosing information relating: to another individual; data which consists of information which is subject to legal professional privilege; negotiations or confidential references.

      12.3.2 Request correction or erasure of your personal information unless we have the legal right to retain it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

      12.3.3 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

      12.3.4 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

      12.3.5 Request the transfer of your personal information to another party.

      12.3.6 Change your data processing preferences at any time. If you have changed your mind, you can update your account settings by contacting us by email at [email protected]. in respect of marketing messages, you can unsubscribe by using the “unsubscribe” link at the bottom of our marketing messages.

12.4 You should be aware that if you ask us to stop processing your personal information in a certain way or erase your personal information, and this type of processing or data is needed to facilitate our provision of services that you may experience a reduced service. This does not include your right to object to direct marketing, which can be exercised at any time without restriction.

12.5 If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us at [email protected].

No fee usually required
12.6 You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

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

Right to withdraw consent 
12.8 In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact [email protected]. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

13. Marketing

13.1 We would like to send you information by email and/or SMS, updates, details of client events and similar hosted events which may be of interest to you (including, for example promotional materials and newsletters). We will do this if we have a lawful basis for doing so in compliance with relevant privacy law or if you consented to us doing so (for example, when you register with us).

13.2 You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, you can unsubscribe by using the “unsubscribe” link at the bottom of our marketing messages.

14. Changes to this privacy policy

We keep our privacy policy under regular review and will notify you of any updates. This privacy policy was last updated inJanuary 2023.

15. How to contact us and complaints

15.1 HULT UAE incorporated in United Arab Emirates is the data controller in respect of your personal data.

15.2 If you have any questions about this privacy policy or how we handle your personal data please contact us at [email protected].

15.3 If for any reason you are not happy with the way that we have handled your personal data, please contact us at [email protected].