Privacy Policy

PRIVACY NOTICE

Effective Date: 01-02-2021

1. Introduction

BearBull Global Investments Group Capital Ltd (hereinafter “BearBull”, “us”, “we”, and “our”) respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website [www.bearbullgroup.com], as well as your rights in relation to the personal data we hold. This policy is in accordance with the DIFC Data Protection Law (DIFC Law No. 5 of 2020) and DIFC Data Protection Regulations (hereafter referred to as the “Data Protection Law”).

2. Data Controller

BearBull is the Data Controller of your personal data and is subject to the DIFC Data Protection Law. This Privacy Policy supersedes any previous privacy notice or equivalent which you may have been provided with.

3. Your Rights

Under the DIFC Data Protection Law, you have the following rights:

To withdraw your consent at any time;
To obtain access to, and copies of, the personal data that we hold about you;
To require that we cease processing your personal data if the processing is causing you damage or distress;
To require us not to send you marketing communications;
To require us to erase your personal data;
To require us to restrict our data processing activities;
To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
To require us to correct the personal data we hold about you if it is incorrect.
Please note that the above rights are not absolute, and BearBull may be entitled to refuse requests where exceptions apply.

4. How We Collect Your Data

We collect your personal data in a number of ways, including:

From the information you provide to us when you meet us;
From information about you provided to us by your company or an 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) client 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.

5. Categories of Personal Data Collected

We collect the following categories of personal data about you:

Your name and contact information such as your home or business address, email address, and telephone number;
Biographical information which may confirm your identity including your date of birth, tax identification number, and your passport number or national identity card details, country of domicile, and/or your nationality;
Information relating to your financial position such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details;
Information about your knowledge and experience in the investment field;
An understanding of your goals and objectives in procuring our services;
Information about your employment, education, family or personal circumstances, and interests, where relevant; and
Information to assess whether you may represent a politically exposed person or financial crime risk.

6. Basis for Processing Your Personal Data

• Performance of a Contract: We process your personal data because it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. This includes preparing proposals, providing services, addressing complaints, and any other purpose for which you provide us with your personal data.
• Legitimate Interests: We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person. This includes marketing, training, business administration, and seeking advice on our rights and obligations.
• Legal Obligations: We process your personal data to comply with legal obligations such as anti-money laundering, conduct of business, market and tax transparency requirements, and other regulatory requirements.

7. Sharing Your Data

We may share your personal data with the following parties:

Your agents, advisers, intermediaries, and custodians of your assets;
Third parties we engage to assist in delivering services to you;
Our professional advisers, such as lawyers, consultants, accountants, IT, or public relations advisers;
Third parties such as intermediaries we introduce to you;
Our data storage providers;
Regulators or law enforcement agencies where required by law.

8. Marketing

We will send you marketing about similar services we provide, as well as other information in the form of alerts, newsletters, and invitations to events or functions which we believe might be of interest to you. We will communicate this to you in a number of ways including by post, telephone, email, SMS, social media, or other digital channels.

9. Data Transfer Outside DIFC

When sharing your personal data with third parties as set out in this privacy notice, it may be transferred outside the DIFC. In these circumstances, your personal data will only be transferred on one of the following bases:

The country that we send the personal data to is approved by the DIFC Data Protection Commissioner as providing an adequate level of protection for personal data;
The recipient has provided appropriate safeguards and on condition that your enforceable rights and effective legal remedies for you are available – appropriate safeguards may include standard data protection clauses as adopted by the Data Protection Commissioner;
You have explicitly consented to a proposed transfer after being informed of possible risks of such transfer; or
The transfer is necessary for the performance of a contract.

10. Data Retention

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, 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 retain your personal data for a period of six 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.

11. Security of Your Data

We take appropriate security measures to protect your data from unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security.

12. Changes to This Privacy Policy

We may update our privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on this page. You are advised to review this privacy policy periodically for any changes.

13. Contact Us

If you have any questions about this privacy policy or wish to exercise your rights, please contact us:

By Email: contact@bearbull.ae
By Mail: Al Fattan Currency House Tower 1, Unit 702, DIFC, Dubai, United Arab Emirates