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MENA Privacy Policy

MENA Risk Warning

FUNDEDBYME MENA PRIVACY POLICY

www.fundedbyme.ae is a website owned and operated by FundedByMe MENA Limited (“FBM”, "we", "us", "our"). FBM is a company incorporated in the Dubai International Financial Centre (“DIFC”) in the United Arab Emirates ("UAE") and is authorised and regulated by the Dubai Financial Services Authority (“DFSA”) to operate a crowdfunding platform.

This Privacy Policy applies to the website www.fundedbyme.ae and related mobile applications (the "FBM Platform"). This Privacy Policy describes how FBM (acting as data controller) collects and uses your Personal Data.

By using the FBM Platform, you agree to be bound by this Privacy Policy. If you do not agree to be bound by any of the terms included in this Privacy Policy, please do not continue to access and use the FBM Platform. This Privacy Policy supplements, and should be read in conjunction with, the FundedByMe MENA General Terms of Use (the "Terms"). The definitions used in the Terms shall apply to this Privacy Policy, unless otherwise defined herein.

We can, and do, regularly make changes to this Privacy Policy. We will post any amended Privacy Policy to the FBM Platform. If you continue to access and use the FBM Platform, your actions will indicate to us that you agree to be bound by the amended terms found in this Privacy Policy.

The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you provided at the time of requesting services or information from us:

  • Information that you provide to us by registering on the FBM Platform and becoming a Registered User. This includes contact information such as name, date of birth, country of residence, passport details, email address, mailing address, phone number, financial information such as bank account numbers, sources of wealth, unique identifiers such as User name, account number, password and marketing preferences.
  • If you decide to join the FBM Platform as a Fundraiser, and register your company with us, we may ask for information about your business, including but not limited to company name, company size, local or international address, contact details, shareholder structure, business type, financial information about the business and Personal Data such as a professional profile. We will also request your company registration number and the names of the company team members who will be authorised to manage the Campaign on behalf of the company.
  • Information that you provide to us when you communicate with us by telephone, in writing (including by email), by completing marketing surveys and preference information. We may make and keep a record of the information you share with us.
  • Details of transactions you may carry out through the FBM Platform and which may be related to a Campaign – whether or not a Campaign is deemed successful.
  • Information obtained by us from third parties in accordance with our on-boarding procedures and complying with our know-your customer obligations. For example, if you decide to join the FBM Platform as a Fundraiser, we may obtain additional information from credit reference agencies to indicate source of wealth and or supplement the information you provide to us.
  • We will gather certain usage information automatically from all Users when they access and use the FBM Platform. This includes (i) information about the User's interactions with the FBM Platform; (ii) details of any queries the User may make; (iii) content the User may post, upload and/or contribute to the FBM Platform; (iv) technical data, which may include the User's URL, IP address, unique device ID, network and computer performance, browser type, language and identifying information and operating system; and (v) location information. We use this information to analyse trends, to administer our FBM Platform, to track Users’ movements around the FBM Platform and to gather demographic information about our collective User base.

HOW WE USE YOUR INFORMATION

We use information held about you in the following ways:

  • To carry out our obligations arising from (i) legal obligations and/or (ii) any client agreements entered into between you and us to provide information or services that you have requested and to notify you about changes to our services.
  • To provide you with information or services that may be of interest to you, where you have consented to be contacted for such purposes.
  • If you are a Registered User, we may contact you by electronic means (email or SMS) with information about services similar to those which were the subject of a previous interaction we have had with you, including, but not limited to an interaction relating to a Campaign (whether or not deemed successful). We will only contact you in this way if you have consented to be contacted for such purposes.
  • To ensure that content on the FBM Platform is presented in the most effective manner for you and for your computer. This is in our legitimate business interests.

DISCLOSURE OF YOUR INFORMATION

We will share your Personal Data with third parties only in the ways that are described in this Privacy Policy.

We may disclose your Personal Data to any member of our group, which includes any subsidiaries (now and in the future), and any ultimate holding company and its subsidiaries.

In addition, we may disclose your Personal Data to third parties in the following circumstances:

  • In the event that we sell or buy any business or assets. In these circumstances, we may disclose your Personal Data to the prospective seller or buyer of such business or assets.
  • If FBM or its assets are acquired by a third party (whether in full or in part). In these circumstances, any Personal Data held by us may be one of the transferred assets.
  • If FBM is under a duty to disclose or share your Personal Data in order to comply with any legal obligation; or permitted by law in order to enforce our Terms and/or other legal agreement. This may include exchanging information with other companies and organisations for the purposes of credit risk reduction and fraud protection.
  • If you have made an investment or applied to invest in a company via the FBM Platform, your Personal Data may be disclosed to the Fundraiser (or the company's professional representatives) that you have invested or applied to invest in.
  • If you participate on any FBM Platform Q&A forum or FAQ page, whether or not related to a specific Campaign, your details may be shared with those individuals participating on that Q&A forum. This may include sharing your Personal Data with other Users.
  • FBM reserves the right from time to time to partner with and/or outsource certain business activities to third parties. As part of these business activities, we may provide your Personal Data to these companies that provide services to help us with our business activities, including without limitation to processing payments, performing compliance activities or to improve our business operations. These companies are authorised to use your Personal Data only as necessary to provide these services to us.

FBM has partnered with FundedByMe Crowdfunding Sweden AB (publ) to provide ongoing operational and technical support for the FBM Platform.

FBM has partnered with Global Custodial Services to provide third party payment services, including without limitation, the provision of separate client money accounts.

FBM has partnered with Vistra for the provision of compliance support. In particular, Vistra will perform due diligence when onboarding Fundraisers, Investors and Registered Users to the FBM Platform, including but not limited to:

  • reviewing reports of fraudulent activity;
  • applying anti-money laundering controls; and
  • assisting with business continuity and disaster recovery.

FBM may use aggregate information about Users to assist in our marketing campaigns. This includes, but is not limited to advertising on the FBM Platform.

YOUR RIGHTS

Users have the right to access information that by FBM holds about you. Users may ask us:

  • for a copy of your information;
  • to correct or erase your information;
  • to restrict or stop the processing of information;
  • to transfer some of this information to other organisations; and
  • where we have asked for your consent to process your data, to withdraw this consent.

These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.

Where we require information to comply with our legal or contractual obligations, then provision of such data is mandatory, and if such information is not provided (for example, adequate know-your-customer information), then we will not be able to meet obligations placed on us or manage your transactions on the FBM Platform. In all other cases, provision of requested information is optional.

How to exercise your rights

Users can correct, change or delete information in their Registered User account at any time. This can be accessed once the User has logged in via the "my account" page. You can stop receiving marketing emails by following the unsubscribe instructions included in these emails or accessing the email preferences in your account settings page.

HOW LONG WE RETAIN YOUR INFORMATION

We will retain your information for as long as a Registered User account is active or as is needed to provide the Services to you. In most cases we will retain your Personal Data for no longer than 6 years. However, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, wand policies.

FundedByMe Crowdfunding Sweden AB (Publ) will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used by FBM are beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

HOW WE STORE, PROCESS AND SECURE YOUR INFORMATION

The data that we collect from you may be transferred to, and stored at, a destination inside the DIFC. It may also be processed by staff operating inside the DIFC who work for us or for one of our suppliers. Such staff maybe engaged in, amongst other things, the provision of support services. Access to your information is limited to those who have a need to manage it.

Your information may also be transferred from the DIFC to certain countries within Europe. These countries have been recognised by the DIFC as having an adequate level of protection for your Personal Data, as can be expected in the DIFC.

In addition, there may be instances where your information is transferred to the United Arab Emirates. This will only take place when:

  • you have given us your written consent to the proposed transfer; or
  • the transfer is necessary for the performance of a contract between you and/or the implementation of pre-contractual measures taken in response to a request from you.

Should FBM decide to transfer information to a country not referred to above, or a country not listed by the DIFC as having adequate protections (i.e. not on the DIFC's list of jurisdictions with an adequate level of protection for the purposes of Article 11(2) of the DIFC Data Protection Law), then we will seek to ensure that it is adequately protected by (i) ensuring that standard contractual clauses are in place and such transfer only takes place when (ii) the transfer complies with the following conditions:

  1. the DIFC Commissioner of Data Protection has granted a permit or written authorisation for the transfer or the set of transfers;
  2. you have given us your written consent to the proposed transfer;/li>
  3. the transfer is necessary for the performance of a contract between you and/or the implementation of pre-contractual measures taken in response to a request from you;
  4. the transfer is necessary for the conclusion or performance of a contract concluded in your interest between FBM and a Third Party;
  5. the transfer is necessary or legally required on grounds important in the interests of the DIFC, or for the establishment, exercise or defence of legal claims;
  6. the transfer is necessary in order to protect the vital interests of your information;
  7. the transfer is made from a register which according to laws or regulations is intended to provide information to the public and which is open to consultation either by the public in general or by any person who can demonstrate legitimate interest, to the extent that the conditions laid down in law for consultation are fulfilled in the particular case;
  8. the transfer is necessary for compliance with any legal obligation to which FBM is subject or the transfer is made at the request of a regulator, police or other government agency;
  9. the transfer is necessary to uphold the legitimate interests of FBM recognised in the international financial markets, except where such interests are overridden by your legitimate interests; or
  10. the transfer is necessary to comply with any regulatory requirements, auditing, accounting, anti-money laundering or counter terrorist financing obligations or the prevention or detection of any crime that apply to FBM.

Security

All information you provide to us via email or via the FBM Platform is stored on our secure servers.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the FBM Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone, and to inform us if you reasonably believe your password has been compromised.

ADDITIONAL PRIVACY INFORMATION

Blog / Discussions / Q&A Forum

Our FBM Platform offers a publicly accessible blog and community discussions. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. In some cases, we may not be able to remove your Personal Data, in which case we will let you know if we are unable to do so and why.