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Privacy Policy

1. INTRODUCTION AND SCOPE

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Crescent Capital Investments ("Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy serves as a comprehensive document outlining how we collect, use, process, share, and safeguard your personal information when you visit our website, engage with our investment services, or otherwise interact with us (collectively, the "Services").

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Given our specialized focus on the Middle East and North Africa (MENA) region, alongside our global client base, we adhere to the highest international standards of data protection, including but not limited to local regional data protection laws and, where applicable, the General Data Protection Regulation (GDPR). We recognize that the confidentiality of financial information is the bedrock of trust ("Amanah") in our client relationships.

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Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing or using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

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2. THE DATA WE COLLECT ABOUT YOU

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Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

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  • Identity Data: Includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, passport number, national identification card details, and distinct visual images (where required for KYC purposes).

  • Contact Data: Includes billing address, postal address, email address, and telephone numbers.

  • Financial Data: Includes bank account details, payment card details, statements of net worth, source of funds documentation, tax identification numbers, and history of financial transactions.

  • Transaction Data: Includes details about payments to and from you and other details of products and investment services you have purchased from us.

  • Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

  • Profile Data: Includes your username and password, purchases or orders made by you, your interests, preferences, feedback, risk tolerance assessments, and survey responses.

  • Usage Data: Includes information about how you use our website, products, and services.

  • Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

3. HOW IS YOUR PERSONAL DATA COLLECTED?

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We use different methods to collect data from and about you including through:

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  • Direct Interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

    • Apply for our investment products or services;

    • Create an account on our website or client portal;

    • Subscribe to our service or publications (including market intelligence reports);

    • Request marketing to be sent to you;

    • Enter a competition, promotion, or survey; or

    • Give us feedback.

  • Automated Technologies or Interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.

  • Third Parties or Publicly Available Sources: We may receive personal data about you from various third parties and public sources as set out below:

    • Technical Data from analytics providers (such as Google) based outside the MENA region;

    • Identity and Financial Data from data brokers or aggregators for the purposes of Anti-Money Laundering (AML) and Know Your Customer (KYC) checks;

    • Identity and Contact Data from publicly availably sources such as corporate registries or electoral rolls inside or outside the MENA region.

 

4. HOW WE USE YOUR PERSONAL DATA

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We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

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  • Performance of a Contract: Where we need to perform the contract we are about to enter into or have entered into with you, including the management of your investment portfolio.

  • Legitimate Interest: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This includes utilizing data to improve our market intelligence and strategic advisory services.

  • Legal Obligation: Where we need to comply with a legal or regulatory obligation, particularly those related to financial reporting, taxation, and anti-money laundering regulations in the jurisdictions where we operate.

 

5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

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We have set out below, in a description format, the ways we plan to use your personal data:

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  • Client Onboarding: To register you as a new client, conduct necessary due diligence, verify your identity, and assess your suitability for specific high-risk investment vehicles.

  • Service Delivery: To process and deliver your order including managing payments, fees, and charges, and collecting and recovering money owed to us.

  • Relationship Management: To manage our relationship with you which will include notifying you about changes to our terms or privacy policy, and asking you to leave a review or take a survey.

  • Security: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).

  • Marketing: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

  • Analytics: To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences.

 

6. DISCLOSURE OF YOUR PERSONAL DATA

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We may have to share your personal data with the parties set out below for the purposes set out in Section 5 above:

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  • Internal Third Parties: Other companies in the Crescent Capital Investments group acting as joint controllers or processors who provide IT and system administration services and undertake leadership reporting.

  • External Third Parties: Service providers acting as processors who provide IT and system administration services, professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the Middle East, Europe, and the US who provide consultancy, banking, legal, insurance, and accounting services.

  • Regulators: Revenue and Customs authorities, regulators, and other authorities acting as processors or joint controllers based in the United Kingdom, United Arab Emirates, Saudi Arabia, and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

  • Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

7. INTERNATIONAL TRANSFERS

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We engage in international business. As such, your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country. specifically, data may be transferred between our offices in the MENA region and servers or service providers located in the European Economic Area (EEA).

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Whenever we transfer your personal data out of your resident jurisdiction, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

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  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

  • Where we use certain service providers, we may use specific contracts approved by the European Commission or relevant local authorities which give personal data the same protection it has in Europe.

 

8. DATA SECURITY

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We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

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9. DATA RETENTION

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How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for a minimum of six to ten years after they cease being customers for tax and legal purposes, depending on the specific jurisdiction of the account.

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10. YOUR LEGAL RIGHTS

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights may include:

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  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.

  • Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.

 

If you wish to exercise any of the rights set out above, please contact our Compliance Officer via the contact form.

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11. THIRD-PARTY LINKS

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This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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12. COOKIES POLICY

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Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. We use strict functionality, analytical/performance, and targeting cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.

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13. CHANGES TO THE PRIVACY POLICY

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We keep our Privacy Policy under regular review. This version was last updated on the date listed at the top of this policy. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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14. CONTACT US

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If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Compliance Officer using the contact form.

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