Privacy Policy

New Genre Holdings Limited (License Number: CL12221), registered in the Dubai International Financial Centre ("DIFC"), is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or engage with our services.

As a DIFC-registered entity, we comply with the DIFC Data Protection Law No. 5 of 2020 and its associated regulations, as well as applicable international data protection standards. This policy should be read in conjunction with our Terms of Service and any other relevant agreements.

By accessing our website or providing us with your personal information, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

We may collect personal information that you voluntarily provide to us when you:

• Submit inquiries through our contact forms
• Request information about our services or investment opportunities
• Subscribe to our communications or newsletters
• Participate in due diligence processes
• Engage with us as an investor, partner, or service provider

This information may include:

• Full name and contact details (email address, phone number, postal address)
• Professional information (company name, job title, business address)
• Financial information and investment history (for qualified investors)
• Identification documents and verification information (as required by regulatory obligations)
• Any other information you choose to provide

When you visit our website, we may automatically collect certain technical information, including:

• Internet Protocol (IP) address and location data
• Browser type and version
• Device information (operating system, device type)
• Pages visited, time spent on pages, and navigation patterns
• Referring website addresses
• Date and time stamps of visits

This information is collected through cookies, log files, and similar tracking technologies. You can control cookie preferences through your browser settings, though disabling cookies may affect website functionality.

We process your personal information for legitimate business purposes, including:

• Service Delivery: To respond to your inquiries, provide requested information, and facilitate investment or business relationships
• Regulatory Compliance: To fulfill our legal and regulatory obligations, including anti-money laundering (AML) and know-your-customer (KYC) requirements under DIFC laws and regulations
• Due Diligence: To conduct background checks and verification processes for potential investors, partners, and service providers
• Communications: To send you relevant updates, investment opportunities, market insights, and other business communications (you may opt out at any time)
• Website Improvement: To analyze website usage, improve user experience, and optimize our digital presence
• Security: To protect against fraud, unauthorized access, and other security threats
• Legal Obligations: To comply with applicable laws, regulations, legal processes, or governmental requests

We will only use your personal information for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose.

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

• Service Providers: With trusted third-party service providers who assist us in operating our business (such as IT services, professional advisors, and administrative support), subject to contractual confidentiality obligations
• Group Companies: Within our corporate group for internal administrative purposes and investment management activities
• Regulatory Authorities: With DIFC authorities, regulatory bodies, law enforcement, or other governmental entities when required by law or to protect our legal rights
• Business Transfers: In connection with any merger, acquisition, reorganization, or sale of assets, provided that the acquiring party agrees to protect your personal information consistent with this Privacy Policy
• Professional Advisors: With lawyers, auditors, accountants, and other professional advisors who assist us in conducting our business
• With Your Consent: With any other third parties where you have provided explicit consent

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest using industry-standard protocols
• Secure socket layer (SSL) technology for data transmission
• Access controls and authentication mechanisms
• Regular security assessments and updates
• Employee training on data protection and confidentiality
• Contractual obligations with third-party processors

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but continuously work to maintain and improve our security practices.

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements. Retention periods vary depending on the nature of the information and applicable legal requirements.

Given the international nature of our business, your personal information may be transferred to and processed in countries outside the UAE and DIFC. These countries may have different data protection laws than those in your jurisdiction.

When we transfer personal information internationally, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by relevant authorities
• Transfers to jurisdictions with adequate data protection frameworks
• Implementation of appropriate technical and organizational measures
• Binding corporate rules within our group of companies

By providing your personal information, you consent to such transfers in accordance with this Privacy Policy.

Under the DIFC Data Protection Law, you have certain rights regarding your personal information:

• Right of Access: You can request confirmation of whether we process your personal information and obtain a copy of such information
• Right to Rectification: You can request correction of inaccurate or incomplete personal information
• Right to Erasure: You can request deletion of your personal information in certain circumstances
• Right to Restrict Processing: You can request that we limit how we use your personal information
• Right to Object: You can object to our processing of your personal information for certain purposes
• Right to Data Portability: You can request transfer of your personal information to another organization in certain circumstances
• Right to Withdraw Consent: Where we rely on your consent, you can withdraw it at any time

To exercise any of these rights, please contact us using the details provided below. We will respond to your request within the timeframes required by applicable law. Please note that certain rights may be subject to limitations and exceptions under applicable law.

Our website may contain links to third-party websites, applications, or services that are not operated or controlled by New Genre Holdings Limited. This Privacy Policy does not apply to such third-party platforms.

We are not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. The inclusion of links does not imply endorsement of such third parties or their services.

If you access third-party services through our website, you do so at your own risk and subject to the terms and privacy policies of those third parties.

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately.

If we become aware that we have collected personal information from a child without appropriate parental consent, we will take steps to delete such information from our systems.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Any updates will be posted on this page with a revised "Last Updated" date.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal information. Material changes to this Privacy Policy will be communicated through prominent notice on our website or direct communication where appropriate.

Your continued use of our website or services following the posting of changes constitutes your acceptance of such changes.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us:

For data protection inquiries specifically, please clearly mark your correspondence as "Privacy Request" to ensure prompt attention.

We are committed to working with you to obtain a fair resolution of any privacy concerns. You also have the right to lodge a complaint with the Office of the Commissioner of Data Protection in the DIFC if you believe we have not handled your personal information appropriately.

This Privacy Policy is governed by and construed in accordance with the laws and regulations of the Dubai International Financial Centre. Any disputes arising from or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the DIFC Courts.