Effective Date: May 5, 2025
Last Updated: May 5, 2025
- Overview
Prospect Asset Management Company Limited (“we”, “us”, or “our”) is committed to safeguarding your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you interact with us or use our website.
We comply with the Abu Dhabi Global Market (ADGM) Data Protection Regulations and any applicable international data protection laws.
- Data We Collect
We may collect and process the following categories of personal data:
- Contact Information: Name, phone number, email address, and company name.
- Usage Information: IP address, browser type, and browsing behavior via cookies and analytics tools.
- Investor Data: Identification documents, proof of eligibility, AML/KYC data, financial suitability assessments (from subscription forms).
- Communication Records: Emails, inquiries, and call logs for service and compliance.
- How We Use Your Data
We process your data to:
- Verify your identity and investor eligibility.
- Comply with anti-money laundering and counter-terrorist financing laws.
- Manage your subscription or redemption requests.
- Provide investor reporting and respond to your inquiries.
- Meet regulatory and compliance obligations.
- Improve our website and service delivery.
We only use your data when we have a lawful basis, including your consent, compliance with legal obligations, or our legitimate business interests.
4. Lawful Basis for Processing
We process personal data in accordance with the lawful bases set out under the Abu Dhabi Global Market (ADGM) Data Protection Regulations 2021. These include the necessity of processing for the performance of a contract, compliance with legal obligations, protection of vital interests, the performance of a task carried out in the public interest or in the exercise of official authority, and for the purposes of our legitimate interests, provided such interests are not overridden by the fundamental rights and freedoms of data subjects. Where none of these bases apply, we obtain the explicit and informed consent of the individual concerned.
- Data Sharing and Disclosure
We may share your personal data with:
- Fund service providers (e.g., administrators, auditors, custodians, legal advisors).
- Regulatory bodies (e.g., FSRA, FATCA, CRS compliance).
- Third-party IT or hosting services, under strict confidentiality agreements.
- Legal authorities, where required to comply with legal obligations.
We do not sell your data to third parties.
6.Data Subject Rights
Under the ADGM Data Protection Regulations, individuals have the right to:
- Access their personal data and obtain a copy;
- Request correction or rectification of inaccurate or incomplete data;
- Request erasure (“right to be forgotten”) where there is no lawful basis for continued processing;
- Restrict processing in certain circumstances;
- Object to processing based on our legitimate interests;
- Withdraw consent at any time where processing is based on consent;
- Receive their personal data in a structured, commonly used, and machine-readable format (data portability), and transmit it to another data controller.
Requests to exercise these rights can be submitted to our Data Protection Officer (DPO) using the contact details provided below. We will respond within the timeframes set out in the applicable regulations.
- International Data Transfers
Where we transfer personal data outside the ADGM jurisdiction, such transfers are made only where the recipient jurisdiction has been deemed to provide an adequate level of protection under ADGM regulations, or where appropriate safeguards are in place. These safeguards may include the use of standard contractual clauses, binding corporate rules, or other lawful mechanisms approved by the ADGM Office of Data Protection. We ensure that all transfers are made in compliance with applicable data protection laws to protect the rights and freedoms of data subjects.
- Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements. The specific retention period depends on the nature of the data and the context of its collection. Once the data is no longer needed, it is securely deleted or anonymized. Further information about our data retention schedule can be provided upon request.
- Data Breach Notification
We have implemented appropriate technical and organizational measures to detect, investigate, and respond to personal data breaches. In the event of a breach that is likely to result in a high risk to the rights and freedoms of individuals, we will notify the ADGM Office of Data Protection without undue delay, and no later than 72 hours after becoming aware of the breach. Where required, we will also notify affected individuals promptly, providing clear information about the breach, its potential impact, and steps taken in response.
10.Appointment of a Data Protection Officer (DPO)
We have appointed a Data Protection Officer (DPO) to oversee our data protection strategy and ensure compliance with ADGM regulations. The DPO serves as the point of contact for data subjects and the ADGM Office of Data Protection. For any questions, concerns, or requests related to the processing of personal data, please contact: Anil Monteiro info@prospectamc.com
- Cookies
We use cookies to enhance website functionality, analyze traffic, and remember your preferences. For more details, see our Cookie Policy.
- Changes to this Policy
We may update this Privacy Policy from time to time. Updates will be posted on this page with the revised effective date. Please review periodically.
- Contact Us
For any privacy-related questions or to exercise your rights, please contact:
Prospect Asset Management Company Limited
Level 16, Office 1609, Tamouh Tower,
Al Reem Island, Abu Dhabi, UAE
📧 info@prospectamc.com