Privacy

At Malhotra Capital Partners we value your privacy and strive to protect your personal information in compliance with the laws of Dubai, UAE. Malhotra Capital Partners will only collect and use your personal information in accordance with such laws (including the Personal Data Protection Act), this Privacy Notice and/or the privacy terms in any agreement(s) that you may have or will enter with Malhotra Capital Partners .

1. “Malhotra Capital Partners” or “we” refers to Malhotra Capital Partners , and related corporations (the term “related corporations” is as defined in the UAE Companies Act of Malhotra Capital Partners in UAE or overseas.
2. “Personal information” refers to any information which relates directly or indirectly to you (for individual) and/or relevant individuals in your organisation (for corporation) and/or your transactions with us. This information includes name, photocopy of ID’s passport and their numbers, address, occupation, contact details, financial information, the details of account(s), the type of products and/or services subscribed to and such other necessary information regarding yourself, relevant individuals in your organisation and/or your transaction(s) with us. For the avoidance of doubt, please note that this Privacy Notice is applicable only to the personal information of an individual.

What Kind of Personal Information We Collect and How We Collect It

To enable us to deal with your inquiries, open and operate an account/facility for you and/or to generally provide you with our products and service we may need to and/or may be required to collect, use, disclose and store (i.e. “process”) personal information and/or financial information about you, which is required amongst others:

1. to establish your personal identification and background;
2. to establish your financial standing and credit-worthiness (where required); and/or
3. supply you with any of our products and services that you applied for.

We may obtain this information from yourself and from a variety of sources, including but not limited to:

1. through your relationship with us, for example information provided by you in application forms, when using our products or services, when transacting on your accounts when taking part in customer surveys, competitions and promotions, and during financial reviews;
2. through your verbal and written communications with us and/or our authorised agents
3. from third parties connected with you, such as employers, joint account holders, security providers or guarantors, representatives, other partners in your partnership, or through our corporate customers or corporate security providers where you are a director, shareholder, officer or authorised signatory;
4. from an analysis of the way you use and manage your account(s)/facility(ies) with us, from the transactions you make and from the payments which are made to/from your account(s)/facility(ies);
5. in the public domain;
6. Credit Bureau of different counntires, credit reporting agencies, regulators and government agencies; and/or
7. from such other sources in respect of which you have given your consent to disclose information relating to you and/or where not otherwise restricted.

How We Use Your Personal Information

We may use your personal information for one or more of the following purposes:

1. to assess your application(s) for our products and services;
2. to manage and maintain your account(s) and facility(ies) with us;
3. to manage our business and your relationship with us
4. to better understand your current and future investment needs and your financial situation
5. to provide you with information on and/or to market Malhotra Capital Partners products, services and offers which may be of interest to you
6. to improve our products and services and to develop new products and services
7. to notify you about benefits and changes to the features of products and services
8. to administer offers, competitions and promotions
9. to conduct surveys as to your relationship with us or our current/future products and services;
10. to respond to your enquiries and complaints;
11. to update, consolidate and improve the accuracy of our records
12. to produce data, reports and statistics which have been anonymized or aggregated in a manner that does not identify you as an individual;
13. to conduct research for analytical purposes including but not limited to data mining and analysis of your transactions with us;
14. to meet the disclosure requirements of any law or contract binding on Malhotra Capital Partners
15. for audit, compliance and risk management purposes;
16. to assess financial and insurance risks;
17. to transfer or assign our rights and duties under any agreement(s) with you
18. to protect or enforce our rights to recover any debt owing to us
19. to conduct anti-money laundering checks
20. for crime detection, prevention and prosecution;
21. for any other purpose that is required or permitted by any law, regulations and/or guidelines;
22. for any other purposes relating to or relating to the business or dealings of Malhotra Capital Partners and/or
23. for such other purposes that is incidental or ancillary or in furtherance to the above purposes.

Disclosure of Your Personal Information

In the course of the provision of our products and services to you and the management and/or operation of the same, we may disclose your personal information (to the extent necessary) to the following third parties:

• Malhotra Capital Partners including the directors, officers and sale agents;
• companies and/or organisations that act as our professional advisers;
• companies and/or organisations that assist us in processing and/or otherwise fulfilling transactions that you have requested;
• companies and/or organisations that assist us in providing value added services that you have requested;
• our advisers (including but not limited to accountants, auditors, lawyers, financial advisers, consultants or other professional advisers);
• our merchants and strategic partners;
• any person notified by you as authorised to give instructions or to use the account(s)/facility(ies) or products or services on your behalf;
• any rating / reference agency;
• any financial institutions, merchants, takaful companies, takaful operators, insurers, insurance brokers or direct or indirect providers of credit protection;
• any person connected to the enforcement or preservation of any of our rights under your agreement(s) with us;
• any third-party service provider, agent or contactor who have been appointed by us to provide services to us whether in or outside UAE subject to sufficient security controls over the information;
• regulatory bodies, clearing house and other regulatory bodies which have oversight over us and our activities;
• Credit Bureau established by Governments;
• any other parties to whom such disclosure is required by law or regulatory requirement or pursuant to a Court order, and/or
• subject at all times to any laws (including regulations, guidelines and/or obligations) applicable to Malhotra Capital Partners (whether in or outside UAE).

Your Rights to Access and Correct Your Personal Information

We can assist you to access and correct your personal information provided to us.

Accessing Your Personal Information

1. You may have access to your personal information in Malhotra Capital Partners possession by making a written request to the officer handling your account. We will use reasonable efforts to provide you with a copy of the requested personal information within 21 days of receiving your duly completed written request.
2. Please note that Malhotra Capital Partners may have to withhold access to your personal information in certain situations, for example when we are unable to confirm your identity or where information requested is of a confidential commercial nature or in the event we receive repeated requests for the same information. Nevertheless, we will notify you of the reasons for not being able to accede to your request.

Correcting/Updating Your Personal Information

1. Where the personal information held by us is inaccurate, incomplete, misleading or where relevant, not up-to-date, you may make a request to correct such personal information.
2. You can also assist us to keep your personal information (such as your current mailing address) up to date, as it will enable us to serve you better.
3. Please liaise with the officer in charge of your account with us.
4. We will use reasonable efforts to comply with your request to correct/update your personal information within 21 days of receiving your written request.
5. Please note Malhotra Capital Partners has the discretion whether to allow your correction/updating request or may require further documentary evidence of the new information to avoid fraud and inaccuracy. Where the personal information held by us is inaccurate, incomplete, misleading or where relevant, not up-to-date, you may make a request to correct such personal information.

We regularly review and implement up-to-date technical and organizational security measures when processing your personal information.

Employees of Malhotra Capital Partners are trained to handle the personal information securely and with strict confidentiality, failing which they may be subject to disciplinary action.

We also impose compliance with this Privacy Notice on our agents, third party service providers, consultants and professional advisors. This serves to ensure that your personal information is safeguarded from unauthorized or accidental loss, misuse, modification, disclosure or destruction.

Malhotra Capital Partners will retain your personal information in compliance with this Privacy Notice and/or the terms and conditions of your agreement(s) with Malhotra Capital Partners

1. for the duration of your relationship with us;
2. for such period as may be necessary to protect the interests of Malhotra Capital Partners and/or our customers notwithstanding that your relationship with us has been terminated;
3. where otherwise required by the law; and/or
4. where required by Malhotra Capital Partners relevant policies.

Where indicated, it is obligatory to provide your personal information to us to enable us to process your application for our products or services. Should you decline to provide such obligatory personal information, we may not be able to process your application/request or provide or continue to provide you with our products or services.

Important Notice

Our Privacy Notice may be revised from time to time. Where the Privacy Notice is revised, the revised Privacy Notice will be posted on our website www.malhotracapitalpartners.com and/or communicated to you via any other means of communication deemed suitable by us. If you continue to use our services/products, you shall be deemed to have agreed to accept such changes.