1. Scope of this Privacy Statement

This Privacy Statement applies to the following individuals (“you”):

• Our past, present and prospective customers;
• Anyone involved in any transaction or interaction with us, whether it is in your personal capacity or as a representative of a legal entity (for example, director, a company manager, agent, legal representative, operational staff, other authorized representative, etc.); and
• Our employees, advisors, consultants or secondees.

2. How do we obtain your personal data? We obtain your personal data as follows:

From the information you provide to us when you meet or interact with us;

• From information about you provided to us by your company or an authorized intermediary;
• When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
• When you complete (or we complete on your behalf) customer on-boarding or application or other forms; • From your agents, advisers, intermediaries, and custodians of your assets; or
• From publicly available sources or from third parties, most commonly where we need to conduct background checks about you.

7. Are you obliged to provide us with your personal data?

In some cases, we are legally required to collect personal data, or your personal data may be needed before we may perform certain services and provide certain products. We undertake to request only the personal data that is strictly necessary for the relevant purpose. Failure to provide the necessary personal data may cause delays or lead to refusal of certain products and services.

8. How do we protect your personal data?

We take appropriate technical and organizational measures (policies, procedures, IT security, etc.) to ensure the confidentiality and integrity of your personal data and the way it’s processed. We apply an internal framework of policies and minimum standards across our business to keep your personal data safe. These policies and standards are periodically updated to keep them up to date with regulations and market developments.

In addition, our employees are subject to confidentiality obligations and may not disclose your personal data unlawfully or unnecessarily. To help us continue to protect your personal data, you should always contact us if you suspect that your personal data may have been compromised.

9. How long do we keep your personal data?

We will only retain your personal data for as long as we have a lawful reason to do so. In particular:

• where we have collected your personal data as required by anti-money laundering legislation, including for identification, screening and reporting, we will retain that personal data for six years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings; or
• otherwise, we will in most cases retain your personal data for a period of ten years after the termination of our contractual or other relationship with you in case any claims arise out of the provision of our services to you.

When your personal data is no longer necessary for a process or activity for which it was originally collected, we delete it, or bundle data at a certain abstraction level, render it anonymous and dispose it in accordance with the applicable laws and regulations.

10. Changes to this Privacy Statement

We may amend this Privacy Statement to remain compliant with any changes in law or to reflect how our business processes personal data.

11. Our contact details

You can address your queries regarding this Privacy Statement to:
Frontier Investment Management Partners Ltd
Al Fattan Currency House, Office 9, Level 3, Building 1
Dubai
International Financial Centre
PO Box 482011, Dubai, United Arab Emirates
+971 4 237 9200
admin@fimpartners.com

You can also address your queries or complaints to our legal and compliance department:
Julie Abraham Jadon
Al Fattan Currency House, Office 9, Level 3, Building 1
Dubai
International Financial Centre
PO Box 482011, Dubai, United Arab Emirates
+971 4 237 9200
compliance@fimpartners.com

Created and published: 10 January 2021