1. Introduction.

These Website Standard Terms and Conditions (these “Terms” or these “Website Standard Terms and Conditions”) contained herein on this webpage, shall govern your use of this website, including all pages within this website (collectively referred to herein below as this “Website”). These Terms apply in full force and affect your use of this Website, and by using this Website, you expressly accept all terms and conditions contained herein in full. You must not use this Website if you have any objection to any of these Website Standard Terms and Conditions.

2. Other Terms that may apply to you

These Terms together with the Privacy Notice constitute the entire agreement between you and Saray Capital (DIFC) Ltd (“Saray Capital”) in relation to your use of this Website and supersede all previous agreements in respect of your use of this Website.

3. Intellectual Property Rights

Other than the content you own, which you may have opted to include on this Website, under these Terms, Saray Capital and/or its licensors own all rights to the intellectual property and material contained in this Website, and all such rights are reserved.

You are granted a limited license only, subject to the restrictions provided in these Terms, for purposes of viewing the material contained on this Website.

4. Restrictions.

You are expressly and emphatically restricted from all of the following:

1. publishing any Website material in any media;
2. selling, sublicensing and/or otherwise commercializing any Website material;
3. publicly performing and/or showing any Website material;
4. using this Website in any way that is, or may be, damaging to this Website;
5. using this Website in any way that impacts user access to this Website;
6. using this Website contrary to applicable laws and regulations, or in a way that causes, or may cause, harm to the Website, or to any person or business entity;
7. engaging in any data mining, data harvesting, data extracting or any other similar activity in relation to this Website, or while using this Website;
8. using this Website to engage in any advertising or marketing;

Saray Capital (DIFC) Limited may restrict access by you to any areas of this Website, at any time, in its sole and absolute discretion.

5. No warranties.

This Website is provided “as is,” with all faults, and Saray Capital makes no express or implied representations or warranties of any kind related to this Website or the materials contained on this Website. Additionally, nothing contained on this Website shall be construed as providing consult or advice to you.

6. Limitation of liability.

In no event shall Saray Capital nor any of its officers, directors, and employees, be liable to you for anything arising out of or in any way connected with your use of this Website, whether such liability is under contract, tort or otherwise, and Saray Capital including its officers, directors and employees shall not be liable for any indirect, consequential or special liability arising out of or in any way related to your use of this Website.

7. Indemnification.

You hereby indemnify to the fullest extent Saray Capital from and against any and all liabilities, costs, demands, causes of action, damages and expenses (including reasonable attorney’s fees) arising out of or in any way related to your breach of any of the provisions of these Terms.

8. Severability.

If any provision of these Terms is found to be unenforceable or invalid under any applicable law, such unenforceability or invalidity shall not render these Terms unenforceable or invalid as a whole, and such provisions shall be deleted without affecting the remaining provisions herein.

9. Variation of Terms.

Saray Capital is permitted to revise these Terms at any time as it sees fit, and by using this Website you are expected to review such Terms on a regular basis to ensure you understand all terms and conditions governing the use of this Website.

10. Assignment.

Saray Capital shall be permitted to assign, transfer, and subcontract its rights and/or obligations under these Terms without any notification or consent required. However, you shall not be permitted to assign, transfer, or subcontract any of your rights and/or obligations under these Terms.

11. Entire Agreement.

These Terms, including any legal notices and disclaimers contained on this Website, constitute the entire agreement between Saray Capital and you in relation to your use of this Website, and supersede all prior agreements and understandings with respect to the same.

12. Governing Law & Jurisdiction.

Saray Capital is regulated by the Dubai Financial Services Authority (DFSA) and is licensed to provide services to Professional Clients. The services/products promoted on this Website may not be suitable for Retail Clients under the DFSA rules and regulations and are not provided to Retail Clients. Professional Clients may not be afforded the Retail Client protection and compensation rights that may generally be available to them from within the DFSA and other jurisdictions.

ONLINE PRIVACY NOTICE

We at Saray Capital respect your concerns about privacy. This Online Privacy Notice applies to the personal information we obtain through this Website. This Online Privacy Notice describes the types of personal information we obtain through the Website, how we may use the information, with whom we may share it, and the choices you may have regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.

We may update our privacy notice from time to time. When we do, we will communicate any changes by publishing the updated Online Privacy Notice on our Website. We would encourage you to visit our Website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.

1. Data protection information

By accessing and continuing to access the Website of Saray Capital you accept this Data Protection Information and confirm that you are 18 years of age or older.

This Data Protection Information applies to all personal data we obtain through the use of this Website. Personal data is any information referring to an identified or identifiable or, in certain cases, a legal entity. Personal data are, for example, information on name, gender, address, e-mail address, telephone number, etc.

Depending on your individual situation, additional provisions (e.g., General Terms of Contract and conditions of use for various services) may apply to certain kinds of data processing.

2. Information we obtain and the mechanisms by which data is collected

When you visit this Website, the web server automatically records certain details of your visit (e.g., your IP address, the website which you are visiting us from, and Saray Capital’s site you are visiting, including the date and duration of your visit). Such “tracking data” is used to optimize the offering on Saray Capital’s website and provide information on how you find out about our products and services and how you use them. However, it does not usually allow you to be identified.

Saray Capital may also receive personal data which are transmitted to us by you via the Website of Saray Capital; if you complete a registration form or comment field for a newsletter, etc.

3. How the data is used

General

As part of our obligation to process your personal data in relation to Saray Capital’s Website in a transparent manner, we want to inform you generically on:

• why and how Saray Capital collects, uses, and stores your personal data on its Website;
• the lawful basis on which personal data is processed;
• to whom your personal data may be disclosed; and
• what your rights and our obligations are in relation to such processing.

How the data is used

Saray Capital collects, uses, and stores personal data through the Website:

• To execute, process, and manage products or services and contracts;
• To design statistics, planning, and product development, business decisions;
• To monitor and manage risks;
• To conduct marketing, market research, demand-oriented support optimization, improvement of the services;
• To improve technical management and development of Saray Capital’s Website (including client and user administration);
• To comply with legal or regulatory obligations and applicable laws (in connection with money laundering and terrorist financing);
• To protect the lawful interests and rights of Saray Capital such as in the case of claims against Saray Capital;
• For purposes otherwise specified.

What is the lawful basis on which your personal data is processed

Personal data collected through Saray Capital’s Website will only be used and processed, respectively, if a legitimate and lawful basis for such use is given. Processing is considered fair and pertinent, if it is carried out, in particular

1. on the basis of consent;
2. to carry out contractual obligations;
3. to comply with statutory and regulatory requirements;
4. to protect the vital interests of an individual; and
5. for the purposes of safeguarding legitimate interests, respectively.

Saray Capital processes your personal data in accordance with the DIFC Data Protection Law and for as long as required.

Retention periods are determined based on the type of record, the nature of the activity, product, or service, and the applicable legal or regulatory requirements.

With whom the data may be shared or disclosed

Within Saray Capital those recipients are given access to personal data that require them in order to perform Saray Capital’s contractual and statutory or official obligations or for the purposes described above.

Personal data may also be transferred to other recipients outside of Saray Capital (“Third Parties”) abroad, but only if those Third Parties implement appropriate technical and organizational measures that ensure the processing meets the requirements of the DIFC Data Protection Law and protects an individual’s rights. These Third Parties are not authorised by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

Saray Capital may also need to disclose your personal data to regulatory authorities and institutions (e.g., the supervisory authorities in the fields of financial market and tax law, financial and tax authorities, criminal prosecution authorities, courts) insofar as a statutory or official obligation exists.

In the event we sell or transfer all or a portion of our business or assets (including in the event of reorganization, dissolution, bankruptcy, or liquidation), we reserve the right to transfer any information we have about you.

What are your rights and our obligations in relation to such processing

Saray Capital will only retain information relating to you for as long as necessary to fulfill the purpose for which it was collected, including for satisfying any legal, accounting, or reporting requirements or to comply with our data retention practices. If applicable, pursuant to the DIFC Data Protection Law and any laws from other jurisdictions like it, you can request Saray Capital whether personal data about you is being processed through a Subject Access Request (“SAR”). You have a right to ask for inaccurate personal information about you to be rectified or completed if it is incomplete. You also have a right to have your personal information erased in specific circumstances. Furthermore, you have the right to request restrictions on the use of your personal data, and you can object on reasonable grounds relating to your particular situation to the processing of your personal data.

If Saray Capital processes your personal data on the basis of your consent, you have the right to withdraw that consent at any time. Please note that such a withdrawal of your consent does not imply that Saray Capital must erase all personal data relating to you where the legitimate and lawful reason to retain emanates. Furthermore, please note that Saray Capital may still be allowed to continue processing your personal data if other legal reasons exist.

Please note that these rights are not absolute (e.g., sometimes, there may be overriding interests or legitimate reasons that require the processing to continue). But Saray Capital will consider your request and respond to you with the outcome.

You may have the right to make a complaint to the responsible data protection authority.

In certain circumstances, Saray Capital may process your personal data through automated decision-making, including profiling. Under certain conditions, you can request to discuss a decision taken by such automated decision-making.

To exercise any of your rights, please send an email to the following address: info@saraycapital.com.

4. Information on the use of cookies

What is a Cookie?

Cookies are small text files that are unique to the web browser on your computer or mobile device, which is used to retain user preferences and enhance the browsing experience. Thus, Saray Capital can gather statistical information about the frequency of visits to certain areas of the website and tailor the sites to be more useful and improve your online experience.

Types of cookies we use

Performance

These cookies are used to analyse trends, administer the website, track visitor movements, and gather broad demographic information for aggregate use. We use the information to compile reports and to help us improve our Website. These cookies are not linked to personally identifiable information.

Targeting and Advertising

We sometimes advertise our products, services, and vacancies on third party websites such as LinkedIn, Facebook, Twitter, Instagram, Google, and Bing. To help us target our advertising, we use cookies from those third parties on our websites to tell us which pages you clicked on and interacted with. Each third party uses its own tracking cookies. If you do not want to be shown targeted advertising, some third-party sites allow you to request not to see messages from specific advertisers. These third-party cookies are not under our control, so you should check the websites and cookie policies of any third parties.

How to manage cookies

Most browsers accept and maintain cookies by default. Check the ‘Help’ or ‘Settings’ menu of your browser to learn how to change your cookie preferences. You can choose to alter cookies settings related to the use of our Website, but this may limit your ability to access certain areas of the site. Note: by using the Website of Saray Capital you agree to the use of cookies for the described purposes.

5. How to contact us

If you have any questions about this Website Standard Terms and Conditions, or if you would like to update information we have about you or your preferences, please contact us by email at info@saraycapital.com or write to us at:

Saray Capital (DIFC) Limited
Office C406, Burj Daman
DIFC
P. O. Box 507197
Dubai, UAE

Phone: +971 4 272 8166
Email: info@saraycapital.com