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Privacy Statement

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Atremo Digital FZE, and from time to time, its subsidiaries (together the "Group") (and each being "Atremo Digital FZE", "we", "us" or "member of the Group" for the purposes of this Privacy Policy Statement as appropriate) recognize their responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under VARA regulation requirements. Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by us is accurate. We will use your personal data which we may collect from time to time in accordance with this Privacy Policy Statement.

 

We regularly review this Privacy Policy Statement and may from time to time revise it or add specific instructions, policies, and terms. Where any changes to this Privacy Policy Statement are material, we will notify you using the contact details you have provided us with and, where required by VARA, give you the opportunity to opt out of these changes by means notified to you at that time. Otherwise, in relation to personal data supplied to us through the Atremo Digital FZE website or otherwise, continued use by you of the Atremo Digital FZE website or your continued relationship with us shall be deemed to be your acceptance of and consent to this Privacy Policy Statement, as amended from time to time.

 

We will take all practicable steps to ensure the security of personal data and to avoid unauthorized or accidental access, erasure, or other use. This includes physical, technical, and procedural security methods, where appropriate, to ensure that the personal data may only be accessed by authorized personnel.

 

Please note that if you do not provide us with your personal data (or relevant personal data relating to persons appointed by you to act on your behalf) we may not be able to provide the information, products or services you have asked for or process your requests, applications, subscriptions or registrations, and may not be able to perform or discharge the Regulatory Functions (defined below).

 

Purpose

From time to time, we may collect your personal data including but not limited to your name, mailing address, telephone number, email address, date of birth and login name for the following purposes:

 

  1. To process your applications, subscriptions and registration for our products and services.

  2. To perform or discharge the functions of Atremo Digital FZE and any company of which Atremo Digital FZE is the recognized exchange controller.

  3. To provide you with our products and services and administer your account in relation to such products and services.

  4. To conduct research and statistical analysis.

  5. To process your application for employment or engagement within Atremo Digital FZE to assess your suitability as a candidate for such a position and to conduct reference checks with your previous employers.

  6. Other purposes directly relating to any of the above.

 

Direct Marketing

Where you have given your consent and have not subsequently opted out, we may also use your name, mailing address, telephone number and email address to send promotional materials to you and conduct direct marketing activities in relation to Atremo Digital FZE financial services and information services, and financial services and information services offered by other members of the Group.

 

If you do not wish to receive any promotional and direct marketing materials from us or do not wish to receive particular types of promotional and direct marketing materials or do not wish to receive such materials through any particular means of communication, please contact us through one of the communication channels set out in the "Contact Us" section below. To ensure that your request can be processed quickly please provide your full name, email address, log in name and details of the product and/or service you have subscribed.

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Identity Card Number

We may also collect your identity card number and process this as required under applicable law or regulation, as required by any regulator having authority over us, subject to VARA, for the purpose of identifying you where it is reasonable for your identity card number to be used for this purpose.

 

Transfers Of Personal Data For Direct Marketing Purposes​

Except to the extent that you have already opted out we may transfer your name, mailing address, telephone number and email address to other members of the Group for the purpose of enabling those members of the Group to send promotional materials to you and conduct direct marketing activities in relation to their financial services and information services.


Other Transfers Of Your Personal Data

For one or more of the purposes specified above, your personal data may be:

  1. Transferred to other members of the Group and made available to appropriate persons in the Group, in Dubai or elsewhere and in this regard, you consent to the transfer of your data outside of Dubai.

  2. Supplied to any agent, contractor or third party who provides administrative, telecommunications, computer, payment, debt collection, data processing or other services to Atremo Digital FZE and/or any of other member of the Group in Dubai or elsewhere.

  3. Other parties as notified to you at the time of collection.

  4. Use of any information related to clients is only made for the purposes for which the information is provided and in compliance with relevant confidentiality agreements which shall be consistent with applicable laws and regulatory requirements, including with respect to acceptance of such agreements.

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How We Use Cookies​

If you access our information or services through the Atremo Digital FZE website, you should be aware that cookies are used. Cookies are data files stored on your browser. The Atremo Digital FZE website automatically installs and uses cookies on your browser when you access it. Two kinds of cookies are used on the Atremo Digital FZE website:

 

Session Cookies

Temporary cookies that only remain in your browser until the time you leave the Atremo Digital FZE website, which are used to obtain and store configuration information and administer the Atremo Digital FZE website, including carrying information from one page to another as you browse the site, so as to, for example, avoid you having to re-enter information on each page that you visit. Session cookies are also used to compile anonymous statistics about the use of the Atremo Digital FZE website.

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Persistent Cookies​

Cookies that remain in your browser for a longer period of time, for the purpose of compiling anonymous statistics about the use of the Atremo Digital FZE website or to track and record user preferences.

The cookies used in connection with the Atremo Digital FZE website do not contain personal data. You may refuse to accept cookies on your browser by modifying the settings in your browser or internet security software. However, if you do so you may not be able to utilize or activate certain functions available on the Atremo Digital FZE website.

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Compliance With Law And Regulations

Atremo Digital FZE and other members of the Group may be required to retain, process and/or disclose your personal data in order to comply with applicable laws and regulations or in order to comply with a court order, subpoena or other legal process (whether in Dubai or elsewhere), or to comply with a request by a government authority, law enforcement agency or similar body (whether situated in Dubai or elsewhere) or to perform or discharge the Regulatory Functions. Atremo Digital FZE and other members of the Group may need to disclose your personal data in order to enforce any agreement with you, protect our rights, property or safety, or the rights, property or safety of our employees, or to perform or discharge the Regulatory Functions.

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Corporate Reorganization

As we continue to develop our business, we may reorganize our group structure, undergo a change of control or business combination. In these circumstances it may be the case that your personal data is transferred to a third party who will continue to operate our business or a similar service under either this Privacy Policy Statement or a different privacy policy statement which will be notified to you. Such a third party may be located, and use of your personal data may be made, outside of Dubai in connection with such acquisition or reorganization.

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Termination Or Cancellation

Should your account or relationship with us be cancelled or terminated at any time, we shall cease processing your personal data as soon as reasonably practicable following such cancellation or termination, provided that we may keep copies of your data as is reasonably required for archival purposes, for use in relation to any actual or potential dispute, for the purpose of compliance with applicable laws and regulations and for the purpose of enforcing any agreement we have with you, for protecting our rights, property or safety, or the rights, property or safety of our employees, and for performing or discharging our functions, obligations and responsibilities.


Internal Data Handling Policy

Staff members will be periodically reminded of the internal policies as stated in the Privacy Statement and Policy document, to be kept up to date with current company policies regarding the collection and processing of customer data handling.

 

Staff members will be periodically reminded to review the VARA Technology and Information Rulebook, in particular Part III as to be reminded of the regulatory requirements required by VASPs that are registered with VARA.

 

Staff must not share confidential information within Atremo Digital FZE or with any other entities, unless it is necessary for the purposes of conducting virtual asset activities related to such confidential information.

 

Neither Atremo Digital FZE nor its staff shall use or share confidential information for the purpose of the trading of Virtual Assets by any entity.

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