Privacy Statement

​

Atremo Digital FZE ("Atremo", "we", "us" or "our") recognises its responsibilities in relation to the collection, holding, processing, use, disclosure, transfer and protection of personal data under applicable data protection laws and the requirements of the Dubai Virtual Assets Regulatory Authority ("VARA"). 

This Privacy Statement and Policy applies solely to Atremo Digital FZE. References to Atremo, we, us or our do not include any subsidiary, affiliate, related company or other entity. Atremo Digital FZE is the data controller responsible for the personal data described in this policy. 

Atremo Digital FZE is licensed and supervised by VARA to provide Virtual Asset Broker-Dealer Services and is permitted to serve Institutional Investors and Qualified Investors within the scope and conditions of its licence. Nothing in this policy represents that any other person or entity is licensed, authorised, regulated or supervised by VARA. 

Personal data will be collected only for lawful and relevant purposes. Atremo will take reasonable steps to ensure that personal data held by it is accurate, appropriately protected and used only for the purposes for which it was collected or for another purpose permitted by applicable law or regulation. 

Atremo may revise this policy from time to time. Where a change is material, Atremo will provide notice, and obtain consent where required, in accordance with applicable law and regulation. 

Atremo maintains physical, technical and organisational security measures designed to prevent unauthorised or accidental access, erasure, loss, alteration, disclosure or other misuse of personal data. Access to personal data is limited to authorised personnel and approved service providers that require access for legitimate operational, legal, compliance or regulatory purposes. 

If you do not provide personal data that Atremo reasonably requires, Atremo may be unable to process your enquiry or application, onboard or maintain a client relationship, provide its Broker-Dealer Services, or comply with its legal and regulatory obligations. 

​

1. Purpose 

Atremo may collect and process personal data, including name, mailing address, telephone number, email address, date of birth, nationality, identification information, financial information, bank-account information, virtual-asset wallet information and transaction information, for the following purposes: 

• to process enquiries, applications, onboarding, subscriptions and registrations relating to Atremo Digital FZE's Virtual Asset Broker-Dealer Services; 

• to establish, administer and manage client and business relationships and provide Atremo Digital FZE's licensed services; 

• to verify identity and conduct KYC, KYB, AML/CFT, sanctions, source-of-funds, source-of-wealth, fraud-prevention, wallet-ownership, bank-account-ownership, transaction-monitoring and other compliance checks; 

• to obtain and provide quotations and to execute, settle, reconcile, monitor and record transactions; 

• to communicate with clients, prospective clients, representatives, counterparties and service providers, provide support and address complaints or requests; 

• to maintain accounting, audit, operational, risk-management, compliance and regulatory records and reports; 

• to protect Atremo Digital FZE's clients, personnel, systems, website and services and to detect, investigate and prevent fraud, financial crime, misconduct and cybersecurity incidents; 

• to comply with applicable laws, regulations, court orders and requirements of VARA or other competent authorities, and to establish, exercise or defend legal rights and claims; 

• to conduct internal analysis and statistical reporting directly related to Atremo Digital FZE's business and regulatory obligations; and 

• to process applications for employment or engagement with Atremo Digital FZE, assess suitability and conduct appropriate reference and background checks. 

Atremo Digital FZE will process personal data only where a lawful basis is available under applicable law, including where processing is necessary to provide requested services, perform an agreement, comply with a legal or regulatory obligation, establish or defend legal rights, protect legally recognised interests or where valid consent has been provided. 

 

2. Direct Marketing 

Atremo Digital FZE will not use personal data to market financial services or information services offered by any other entity. 

Where permitted by applicable law, regulation and Atremo Digital FZE’s licence conditions, and where any required consent has been obtained, Atremo may use your name and contact details to provide information about Atremo Digital FZE's own Virtual Asset Broker-Dealer Services, relevant service updates or Atremo Digital FZE events. 

You may opt out of direct-marketing communications at any time by using the unsubscribe method included in the communication or by contacting support@atremo.digital. Opting out of marketing will not prevent Atremo from sending operational, transactional, legal, compliance or regulatory communications. 

 

3. Identity Card Number and Identity Verification 

Atremo Digital FZE may collect passport numbers, Emirates ID numbers and other government-issued identification information where reasonably necessary to identify and verify clients, beneficial owners and authorised representatives, prevent fraud and financial crime, satisfy onboarding and regulatory requirements, or respond to lawful requests from competent authorities. 

Atremo Digital FZE may use approved identity-verification service providers to conduct facial-matching, liveness or similar biometric verification checks where required for onboarding, fraud prevention, security or regulatory compliance. Such information will be used only for authorised identity-verification, compliance, security and fraud-prevention purposes. 

 

4. Transfers of Personal Data for Direct Marketing Purposes 

Atremo Digital FZE does not transfer personal data to another entity for that entity's independent marketing activities unless you have expressly consented to the transfer or the disclosure is otherwise clearly permitted or required by applicable law. 

​

5. Other Transfers of Your Personal Data 

For one or more of the purposes specified above, Atremo Digital FZE may disclose personal data where reasonably necessary to: 

• identity-verification, screening, AML/CFT, sanctions, fraud-prevention and compliance service providers; 

• technology, website, hosting, telecommunications, cybersecurity and data-processing service providers; 

• banks, payment or settlement providers, Atremo Digital FZE’s appointed virtual-asset custodian, liquidity providers and trading counterparties involved in providing Atremo Digital FZE’s Broker-Dealer Services; 

• auditors, accountants, lawyers, insurers and other professional advisers; 

• courts, regulators, government authorities and law-enforcement agencies; 

• persons involved in an actual or proposed merger, acquisition, financing, restructuring, sale of business or change of control concerning Atremo Digital FZE; and 

• other recipients where you have authorised the disclosure or where disclosure is permitted or required by applicable law. 

Service providers acting for Atremo Digital FZE are expected to process personal data only for authorised purposes and to apply appropriate confidentiality, privacy and security protections. Atremo Digital FZE does not sell personal data. 

Some service providers or recipients may process personal data outside the United Arab Emirates. Where personal data is transferred internationally, Atremo Digital FZE will use a transfer mechanism permitted by applicable law and apply appropriate contractual, technical and organisational safeguards where required. 

Client information will be used only for the purposes for which it was provided and in accordance with applicable confidentiality obligations, laws and regulatory requirements. 

 

6. How We Use Cookies 

The Atremo Digital FZE website may use cookies and similar technologies to operate and secure the website, maintain website functionality, remember user preferences, understand how visitors use the website, monitor website performance and compile aggregated or anonymous statistics. 

​

6.1 Session Cookies 

Session cookies remain in your browser only for the duration of your browsing session and may be used to administer the website and carry information between pages so that you do not need to re-enter the same information during a single session. 

​

6.2 Persistent Cookies 

Persistent cookies may remain in your browser for a longer period or until deleted and may be used to remember preferences or compile website-usage statistics. 

You may manage or refuse cookies through your browser settings. Disabling certain cookies may affect the availability or operation of website functions. Where consent is legally required, non-essential cookies will be used only after the required consent has been obtained. 

​

7. Compliance with Law and Regulations 

Atremo Digital FZE may retain, process or disclose personal data where reasonably necessary to comply with applicable laws and regulations, meet requirements imposed by VARA or another competent authority, respond to a court order, subpoena, regulatory request or other lawful process, cooperate with government or law-enforcement authorities, prevent or investigate financial crime or cybersecurity incidents, enforce agreements, protect legal rights or safety, or establish, exercise or defend legal claims. 

Any disclosure will be limited to what is reasonably necessary or legally required. 

​

8. Corporate Reorganisation 

If Atremo Digital FZE undergoes a merger, acquisition, financing, restructuring, sale of business, change of control or similar transaction, personal data may be disclosed or transferred to relevant advisers, counterparties or successors where reasonably necessary for that transaction and permitted by applicable law. 

Any recipient will be required to process personal data in accordance with applicable law. Where required, Atremo Digital FZE will notify affected individuals of any material change concerning the data controller or the purposes for which personal data is processed. 

​

9. Termination or Cancellation 

If your account or relationship with Atremo Digital FZE is cancelled or terminated, Atremo will stop processing personal data for purposes that are no longer necessary, subject to its legal and regulatory recordkeeping obligations. 

Atremo Digital FZE may continue to retain and process personal data where reasonably necessary to comply with legal and regulatory requirements, maintain required business and transaction records, respond to regulatory or law-enforcement enquiries, resolve complaints or disputes, enforce agreements, protect legal rights, or establish, exercise or defend legal claims. 

Atremo Digital FZE will retain transaction records, client due-diligence records, business correspondence, information relating to third parties engaged to undertake due diligence, records of ongoing monitoring and other records required under applicable VARA rules for no less than eight years, or for a longer period where required or permitted by applicable law, regulation, legal proceedings or a competent authority. 

​

10. Internal Data Handling Policy 

Atremo Digital FZE personnel will receive periodic reminders and training concerning Atremo Digital FZE’s current policies and applicable legal and regulatory requirements for collecting, processing, protecting and retaining client information. 

Atremo Digital FZE personnel must not access, use or disclose confidential client information within or outside Atremo Digital FZE unless access, use or disclosure is necessary to provide Atremo Digital FZE’s licensed Broker-Dealer Services, carry out legitimate operational, legal, risk-management or compliance functions, or comply with applicable legal and regulatory obligations. 

Neither Atremo Digital FZE nor its personnel may use or disclose confidential client information for unauthorised personal trading or for unauthorised trading of Virtual Assets by another person or entity. 

​

Contact

Questions, requests or complaints concerning this Privacy Statement and Policy or Atremo's processing of personal data may be submitted to:

​

Data controller: Atremo Digital FZE

Address: Premises No. EO60 SRT, Floor no. 23, Sheikh Rashid Tower, Dubai World Trade Center, Dubai, UAE

Privacy and compliance: compliance@atremo.digital

General support: support@atremo.digital

​

Please provide sufficient information for Atremo to identify you and understand your request. Do not send passwords, private keys, access codes or other account credentials by email.