Privacy Policy

As part of our daily business operations we need to collect personal information from our clients and prospective clients in order to provide them with our products and services and ensure that we can meet their needs when providing these products and services as well as when providing them with the respective information.

Your privacy is of utmost importance to us and it is our policy to safeguard and respect the confidentiality of information and the privacy of individuals. Our Privacy Policy also outlines how we manage the personal information we hold about our customers, potential customers, shareholders and other individuals. It applies to Trading Point MENA Limited (“the Firm”, “We”, “Us”, Our, or “TP MENA”), Unit S402, Level 4, Emirates Financial Towers, DIFC, Dubai, PO BOX: 507013, United Arab Emirates. The Firm is also registered with the Dubai Data Protection Commissioner.

This Privacy Policy applies to the processing activities performed by the Firm to the personal data of its clients/potential clients (“You”, “Your”, Yours” or “Yourself”) website visitors and employees. This Privacy Policy does not apply to websites operated by any other organisations and/or other third parties.

This Privacy Policy sets out how Trading Point MENA Limited (the “Firm”) collects, uses and manages your personal information we receive by you or a third party in connection with our provision of services to you or which we collect from your use of our services and/or our website (i.e., www.xm.com/mena) and/or any other related websites and applications including, among others, the Firm’s Members Area. The Privacy Policy also informs you of your rights with respect to the processing of your personal information.

Our Privacy Policy is reviewed regularly to ensure that any new obligations and technologies, changes to our business operations and practices are taken into consideration, as well as that it remains abreast of the changing regulatory environment. Any personal information we hold will be governed by our most recent Privacy Policy as this is posted on our website.

It is the Firm’s policy to respect the confidentiality of information and the privacy of individuals and we are bound by the DFSA rules and regulations.

TP MENA is part of the Trading Point Group. Each entity of the Trading Point Group has its own separate Privacy Policy. Such entities operate their own websites and as such, if you are interested in learning about how such entities process your personal data, please refer to their corresponding privacy statements which may be found on their specific websites.

By you providing us with information about yourself through, via our websites, application forms, telephone or other relevant mediums. You have given consent to the collection, use, disclosure and transfer of that information as set out in this Privacy Policy.

By using our websites, you also consent to our use of cookies as set out in this Privacy Policy. If you apply to open a trading account, your application form (whether in written format or completed electronically, will constitute as you are giving your express consent to the use and (in certain circumstances) disclosure of your personal data.

By using our online services, it would constitute as you are accepting the terms of this Privacy Policy.

The Firm respects the privacy of any users who access its website(s), and it is therefore committed to taking all reasonable steps to safeguard any existing/prospective clients, applicants and website visitors.

The Firm keeps any clients or prospective or potential clients’ personal data in accordance with the applicable data protection laws and regulations. We have the necessary and appropriate technical and organisational measures and procedures in place to ensure that your information remains secure at all times. We regularly train and raise awareness to all of our employees on the importance of maintaining, safeguarding and respecting your personal information and privacy. We regard matters such as breaches of individuals’ privacy as very serious and we may impose appropriate disciplinary measures, including dismissal where necessary. We also have the necessary policies in place to ensure that our Firm manages/processes your personal information in compliance with the applicable data protection laws and regulations and in accordance with this Privacy Policy.

The personal information you provide us with when registering as a user of the Company’s site(s) and/or of its services is classified as registered information, which is protected in several different ways. You can access your registered information after logging in to the Members Area by entering a username and a password that you select. It is your responsibility to make sure that your password is only known to you and not disclosed to anyone else. Registered information is securely stored in a safe location and only authorised personnel have access to it via a username and a password. All personal information is transferred to the Firm over a secure 128-bit SSL connection and thus all necessary measures are taken to prevent unauthorised parties from viewing any such information. Personal information provided to the Firm that does not classify as registered information is also kept in a safe place and accessible by authorised personnel only via a username and a password.

Transmission of information via the internet is not always completely secure but the Firm endeavors to protect your personal data by taking appropriate precautions. Once we have received your information, we will apply procedures and security features to try to prevent unauthorised access.

We strive to meet the needs of our clients from the range of financial services we offer. In order to be able to do this effectively, we need to collect certain personal information. Please also note that because of the nature of the services we provide and our associated regulatory obligations we do not have the option of allowing you to become our client and therefore provide you with our services on an anonymous basis.

We collect this information, through your use of our services, including through account opening application forms, demo sign-up forms, telephone conversations, webinars, subscribing to news updates and from maintaining records of information obtained in the course of ongoing customer service communications. We may also collect this information about you from third parties such as through publicly available sources and/or payment service providers. We also keep records of your trading behavior, including records regarding:

• products you trade with us and their performance;

• historical data about the trades and investments you have made including the amount invested;

• your preference for certain types of products and services.

We may also obtain information about you through our websites, apps or via the use of cookies.

From time to time, we may request information on a voluntarily basis (including through market research, surveys). This information will allow us to improve our service or better cater to the wider needs of our current and future clients.

We may also record communications that we have with you in relation to the services we provide to you and our relationship with you. These recordings may be in electronic format, by telephone, in person or otherwise and will be our sole property, constituting evidence of the communications between us. Such telephone conversations may be recorded without the use of a warning tone or other notice.

If you choose not to provide the information we request, we may not be able to provide you with the product or service you need or open your trading account.

Further, if you visit any of our offices or premises, we may have CCTV, which will record your image.

In order to open an Account with us, you must first complete and submit an application form to us by completing the required information. By completing this application form, you are requested to disclose personal information in order to enable the Firm to assess your application and comply with the relevant rules and regulations. The information you provide may also be used by the Firm to inform you regarding its services.

The information that we may collect from you includes the following:

• full name, residential address and contact details (e.g., email address, telephone number, fax etc.);

• date of birth, place of birth, gender, citizenship;

• Information about your income and wealth, including details about your source of funds, assets and liabilities, bank account information / debit card details, trading statements, financial statements, FATCA and CRS information;

• trading account balances, trading activity, your inquiries and our responses;

• information on whether you hold a prominent public function (PEPs);

• profession and employment details;

• authentication data (e.g., signature);

• Nationality and Residency;

• location data;

• trading performance;

• knowledge and experience;

• traffic data, location data, weblogs and other communication data from your visits to our website;

• verification information, which includes information necessary to verify your identity such as a passport or a driver’s license (examples also include background information we receive about you from public records or from other entities not affiliated with us); furthermore, we may collect other identifiable information such as identification numbers and/or Passport/Tax registration numbers;

• any other similar information;

• activity and movement on the website.

The information you provide us, will be used to assess your application, verify your identity and conduct identity checks and do anything else necessary in order to open your trading account. This can include conducting screening checks in accordance with our obligations under relevant anti money laundering laws and other regulatory laws.

Once this process is complete, the information we hold is used for establishing and managing your account, reviewing your ongoing needs, enhancing our customer service and products and giving you information on any opportunities that we believe may be relevant to you. We may process your personal data on the following bases and for the following purposes:

1. Performance of a contract

We process personal data in order to provide our services and products, as well as information regarding our products and services based on the contractual relationship with our clients (i.e., so as to perform our contractual obligations). In addition, processing of personal data takes place to be able to complete our client on-boarding/acceptance procedures.

In view of the above, we need to verify your identity in order to accept you as our client and we will need to use those details in order to effectively manage your trading account with us to ensure that you are getting the best possible service from us. This may include third parties carrying out credit or identity checks on our behalf. The use of your personal information is necessary for us to know who you are as we have a legal obligation to comply with certain ‘Know Your Customer’ and ‘Customer Due Diligence’ regulatory obligations.

2. Compliance with a legal obligation

There are a number of legal obligations emanating from the relevant laws to which we are subject as well as statutory requirements (e.g., the AML Law, the DFSA Rulebook, Tax laws, etc.). There are also various supervisory authorities whose laws and regulations we are subject to (e.g. the Dubai Financial Services Authority). Such obligations and requirements impose on us necessary personal data processing activities for credit checks, identity verification, compliance with court orders, tax law or other reporting obligations and anti-money laundering controls.

3. For the purposes of safeguarding legitimate interests

We process personal data so as to safeguard the legitimate interests pursued by us or by a third party. A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. Examples of such processing activities include:

• Initiating legal claims and preparing our defense in litigation procedures;

• Means and processes we undertake to provide for the Firm’s IT and system security, preventing Potential crime, asset security, admittance controls and anti-trespassing measures;

• Setting up CCTV systems (e.g., at our premises for security reasons);

• Measures to manage business and for further developing products and services;

• Sharing your personal data within the Group for the purpose of updating/verifying your personal data in accordance with the relevant anti-money laundering compliance framework;

• Risk management.

4. You have provided your consent

Provided that you have given us your specific consent for processing (other than for the reasons set out hereinabove) then the lawfulness of such processing is based on that consent. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.

5. To assess the appropriateness of our services/products for you

6. To provide you with products and services, or information about our products and services, and to review your ongoing needs

Once you successfully open a trading account with us, or subscribe to an update or webinar, we will need to use your personal information to perform our services and comply with our obligations to you. It is also in our legitimate interests to ensure that we are providing the best products and services so we may periodically review your needs to ensure that you are getting the benefit of the best possible products and services from us.

7. To help us improve our products and services, including customer services, and develop and market new products and services

We may, from time to time, use personal information provided by you through your use of the services and/or through client surveys to help us improve our products and services. It is in our legitimate interests to use your personal information in this way to ensure the highest standards when providing you with our products and services and to continue to be a market leader in the financial services industry.

We track visitor activity and behaviour at our website every time you access the site and the resulting data allow us to provide more effective user support if you need any help or advice using our website. We note that this information cannot be used to identify you.

8. To form a profile about you

We may from time to time use personal information about you to create profiles about you so that we can better understand you and your needs. We may also make decisions about you through automated profiling or automated credit checks which may affect your ability to use our services. We may need to do this either to perform our legal obligations or because it is in our legitimate interest to use your personal information in such a way.

9. To investigate or settle enquiries or disputes

We may need to use personal information collected from you to investigate issues and/or settle disputes with you as it is in our legitimate interests to ensure that issues and/or disputes get investigated and resolved in a timely and efficient manner.

10. To comply with applicable laws, court orders, other judicial process, or the requirements of any applicable regulatory authorities

We may need to use your personal information to comply with any applicable laws and regulations, court orders or other judicial process, or the requirements of any applicable regulatory authority. We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so.

11. To send you surveys

From time to time, we may send you surveys as part of our customer feedback process. It is in our legitimate interest to ask for such feedback to try to ensure that we provide our services and products at the highest standards. However, we may, from time to time, also ask you to participate in other surveys and if you agree to participate in other surveys we rely on your consent to use the personal information we collect as part of such survey. All responses to any survey we send out whether for customer feedback or otherwise will be aggregated and depersonalised before survey results are shared with any third parties.

12. Data analysis

Our web pages and e-mails may contain web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence. Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However, where your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to the market.

13. Marketing purposes

We may use your personal information to send you marketing communications by email or phone or other agreed forms (including social media campaigns) to ensure that you are always kept up to date with our latest products and services. Where we send you marketing communications we will either do so based on your consent or if it is in our legitimate interest. If you no longer wish to receive such communications, you can easily unsubscribe by clicking on the relevant “Unsubscribe” link provided in all of our emails sent to you. Alternatively, please send us and email at: support.mena@xm.com. For marketing that you receive as a result of our use of cookies, please see the section dealing with cookies below. In particular please note the information about how to manage your preferences both personally and with any social media websites.

14. Internal business purposes and record keeping

We may need to process your personal information for internal business and research purposes as well as for record keeping purposes. Such processing is in our own legitimate interests and is required in order to comply with our legal obligations. This may include any communications that we have with you in relation to the services and products we provide to you and our relationship with you. We will also keep records to ensure that you comply with your contractual obligations pursuant to the agreement governing our relationship with you.

15. Legal notifications

Often the law requires us to advise you of certain changes to products or services or laws. We may need to inform you of those changes, such as, including but not limited, to the terms or the features of our products or services. In order to be able to send to you these legal notifications we need to process your personal information. You will continue to receive this information from us even if you choose not to receive direct marketing information from us.

16. Corporate restructuring

If we undergo a corporate re-structuring or part, or if all of our business is acquired by a third party, we may need to use your personal information in association with that re-structuring or acquisition. Such use may involve sharing your information as part of a due diligence enquiries or disclosures pursuant to legal agreements. It is our legitimate interest to use your information in this way, provided we comply with any legal/regulatory obligation we have towards you.

17. Security

If you enter any of our premises, we may record your image on our CCTV for security reasons. We may also take your details to keep a record of who has entered our premises on any given day. It is in our legitimate interest to do this to maintain a safe and secure working environment.

The Firm shall not disclose any of its clients’ confidential information to a third party, except: (a) to the extent that it is required to do so by under and/or pursuant to any applicable laws, rules and/or regulations; (b) where there is a duty to the public to disclose; (c) where our legitimate business interests require disclosure; or (d) at your request or with your consent or to persons described below. The Firm will endeavor to make such disclosures on a ‘need-to-know’ basis, unless otherwise instructed by a regulatory authority. Under such circumstances, the Firm shall expressly inform the third party regarding the confidential nature of any such information.

Your personal data may also be used by the Firm for the purpose of future planning of our business, which can include; product development and research. In such instances, where we have legal or regulatory obligations), and depending upon particular restrictions on sensitive personal data, you consent to the disclosure of your personal data where we disclose or transfer that information to:

• The appropriate regulators or government authorities, where required, authorised, permitted or compelled by law;

• Other companies within the Group (including our associated companies elsewhere in the world) who may be involved in administering your account or providing other services for the Group;

• Where applicable, anyone who has been authorised by you (for example, a financial adviser, a lawyer, etc.);

• An introducing broker, referrer, or third-party broker or agent who may have introduced or referred you to us (this is necessary in order to pay fees or commissions for such a referral and can include any click-through links you may have clicked on);

• A third-party service provider, including those who help facilitate or support our business, or develop new software to run our business more efficiently (these could include specialist advisers who have been contracted to provide us with administrative, IT, financial, regulatory, compliance, taxation, insurance, research or other services.

• business parties, credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law;

• credit reporting or reference agencies; and

• anyone authorised by you.

Third party service providers such as credit-referencing agencies may keep a record of any searches performed on our behalf and may use the search details to assist other companies in performing their searches. In the event that the Firm discloses your personal information to business parties, such as card processing companies or banks, in order to perform the services requested by clients, such third parties may store your information in order to comply with their legal and other obligations

We will endeavor to take all reasonable steps to require that organisations both within and outside our Group, who handle or obtain personal information as service providers to us acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with either the DIFC rules or their local privacy regime and this privacy notice.

You should be aware however that our ability to enforce DFSA Data Protection Rules or any other contractual privacy obligation against overseas recipients and to take action in relation to any breach may be very limited and/or far less effective than it would be if such recipients were UAE based. Because the DIFC rules may not apply or be enforceable against some overseas recipients we understand that you may choose not to disclose your personal information to us. However, if you choose not to provide the information we need to fulfil your request for a specific product or service, we may not be able to provide you with the requested product or service.

Clients accept and consent that the Firm may, from time to time, analyse the data collected while visiting our website(s) or by other means, such as questionnaires, for statistical purposes in order to improve the Firm’s business activities.

We may transfer your personal information outside the DIFC or the European Economic Area to other Trading Point group companies as well as processors who are engaged on our behalf. To the extent we transfer your information outside the EEA, we will ensure that the transfer is lawful and that processors in third countries are obligated to comply with the European data protection standards and to provide appropriate safeguards in relation to the transfer of your data in accordance with the applicable data protection laws.

In view of the above, your personal information may be processed by staff operating outside the DIFC who work for us or for one of our processors. Such staff may be, among others, engaged in the fulfilment of your requests, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing and processing. The Firm will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Tracking systems used on the Firm’s website(s) may collect your personal data in order to optimise the services provided to clients/potential clients. The website collects information in the following ways:

• Device information

  By recognizing your device used to access and use the Firm’s website(s), we can provide you with the most appropriate version of our website(s).

• Log information

  Logging certain behaviors on the site enables the Firm to track user action and therefore troubleshoot any issues that may occur.

• Location information

  Using your IP address helps us localise our website content, which we provide to you based on your country, and improve your user experience on our site(s).

• Cookies

  Cookies are text files with a small amount of data sent from our website(s) to your browser and stored on your computer’s hard drive. Cookies help us improve the performance of our website(s) and our website visitors’ experience, track your referrer (if any) and improve our future advertising campaigns.

• Local storage

  You must submit validation documents to us through the Firm’s Members Area in order to activate your trading account. These documents are transmitted over a secure 128-bit SSL connection and stored in a safe location.

Internet cookies are small pieces of data sent from our website(s) to your browser and stored on your computer’s hard drive when using our website(s), and they may include a unique identification number. The purpose of collecting this information is to provide you with a more relevant and effective experience on our website(s), including the presentation of our web pages according to your needs or preferences.

Cookies are frequently used on many websites on the internet, and you can choose if and how a cookie will be accepted by changing your preferences and options in your browser. You may not be able to access some parts of our website(s) if you choose to disable the cookie acceptance in your browser, particularly in the Firm’s Members Area and other secure parts of our website(s). We therefore recommend you enable cookie acceptance in order to benefit from all of our online services.

Furthermore, we use cookies for re-marketing features in order to allow us to reach out to users who have previously visited our website(s) and have shown an interest in our products and services. Periodically, we may use third party vendors, such as Google and AdRoll, to display our advertisements (ads) over the internet to you, based on your previous use of our website(s). You can opt out this particular use of cookies at any time by visiting Google’s Ads Settings page and the DoubleClick opt-out page.

The Firm uses session ID cookies and persistent cookies. A session ID cookie expires after a set amount of time or when the browser window is closed. A persistent cookie remains on your hard drive for an extended time period. You can remove persistent cookies by following directions provided in your web browser's ‘Help’ file.

Additionally, we use cookies to give you access to certain pages of our website(s) or our app(s) without having to log in each time you visit. We may also use independent external service providers to track the traffic on and usage of our website(s). Cookies are small pieces of text stored on your computer to help us determine the type of browser and settings you are using, where you have been on the website(s) or the app(s), when you return, where you came from, and to ensure your information is secure. The purpose of this information is to provide you with a more relevant and effective experience on our website(s) or our app(s), including presenting web pages according to your needs or preferences.

For further details about our cookie policy and how our cookies work, read our Cookies Policy here.

From time to time, our website(s) or app(s) may have links to external third-party websites. Please note, that third party websites are not covered by our Privacy Policy and these sites are not subject to our privacy standards and procedures. Please check with each third party as to their privacy practices and procedures.

Where our use of your personal information requires your consent, such consent will be provided in accordance with the Client Agreement/Terms and Conditions of Business which governs our business relationship and is available on our website(s), or any other contract we may have entered into with you or as set out in our communication with you from time to time.

If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time by contacting us using the contact details set out in this Privacy Policy.

Safeguarding the privacy of your information is of utmost important to us, whether you interact with us personally, by phone, by mail, over the internet or any other electronic medium. We will hold personal information, for as long as we have a business relationship with you, in a combination of secure computer storage facilities and paper-based files and other records and we take the necessary measures to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. These steps are supported by a number of security standards, processes and procedures, and we store information in access-controlled premises or in electronic databases requiring logins and passwords.

When we consider that personal information is no longer necessary for the purpose for which it was collected, we will remove any details that will identify you or we will securely destroy the records. However, we may need to maintain records for a significant period of time. For example, we are subject to certain anti-money laundering laws which require us to retain the following, for a period of 6 years after our business relationship with you has ended:

• a copy of the documents we used in order to comply with our customer due diligence obligations;

• supporting evidence and records in connection with our business relationship, including:

  • business correspondence and other information relating to your account;
  • sufficient records of transactions to enable individual transactions to be reconstructed; and
  • internal findings and analysis relating to a transaction.

Also, the personal information we hold in the form of a recorded communication, by telephone, electronically, in person or otherwise, will be held in line with local regulatory requirements (i.e., 6 years after our business relationship with you has ended). Where you have opted out of receiving marketing communications we will hold your details on our suppression list so that we know you do not want to receive these communications.

As information is more commonly held in electronic form we take our obligations to protect electronically held personal information very seriously. This includes ensuring we meet regulatory requirements regarding the appropriate levels of information and software security, governance and associated procedures. The transmission of information via the Internet is not completely secure., therefore we are unable guarantee the security of your data, which is transmitted to our online services and any transmission is at your own risk.

Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure.

The rights that might be available to you in relation to the personal information we hold about you are set out below. You may exercise these rights by sending us an email at dpo.mena@xm.com.

As per the DFSA rules, you have the right to check any personal information which we hold about you and to advise us of any inaccurate information we hold and where required, inform us of any updates.

If you ask us, we will confirm whether we are processing your personal information and, if so, what information we process and, if requested, provide you with a copy of that personal information (along with certain other details) within thirty (30) days from the date of your request. If you require additional copies, we may need to charge a reasonable administration fee.

If you provide us with personal information that we have not requested, we will endeavour to only retain the information that we are otherwise entitled to hold because of the products and services we provide. However, if this additional information is surplus to our requirements but is provided to us in a manner where it is combined with information that we are either required or entitled to retain then you acknowledge that this unsolicited information may be held by us in the same manner as the balance of your personal information.

Where we receive unsolicited personal information, not required for the purposes of the provision of our services, we will securely destroy the information (provided it is lawful and reasonable for us to do so).

We endeavour to ensure that the personal information we hold is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances.

If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed your personal information to others, we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also inform you who we have shared your personal information with so that you can contact them directly.

You may inform us at any time that your personal details have changed by e-mailing us at support.mena@xm.com. The Company will change your personal information in accordance with your instructions. To proceed with such requests, in some cases we may need supporting documents from you as proof, i.e. personal information that we are required to keep for regulatory or legal purposes.

You can ask us to delete or remove your personal information in certain circumstances such as where we no longer need it or you withdraw your consent (where applicable) provided that we have no legal obligation to retain that data. Such request will be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations and subject to section 'Storage of Your Personal Information and Retention Period'. If we have disclosed your personal information to others, we will let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we will also inform you who we have shared your personal information with so that you can contact them directly.

You can ask us to ‘block’ or ‘suppress’ the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It will not stop us from storing your personal information though. We will inform you before we waive any restriction. If we have disclosed your personal information to others, we will inform about the restriction where possible. At your request, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;

• processing your personal information for direct marketing; or

• processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.

Should you not want us to use your personal information, you must inform the Company by sending an email to dpo.mena@xm.com. If you decide to do so, we may not be able to continue to provide information, services and/or products requested by you and we will have no liability towards you in this respect.

The Firm reserves the right to disclose your personally identifiable information as required by rules and regulations and when the Company believes that disclosure is necessary to protect our rights and/or to comply with any judicial and/or other proceedings, court order, legal process served or pursuant to governmental, intergovernmental and/or other regulatory bodies. The Firm shall not be liable for misuse or loss of personal information and/or otherwise on the Firm’s website(s) that the Firm does not have access to or control over. The Firm will not be liable for unlawful or unauthorised use of your personal information due to misuse or misplacement of your passwords, negligent or malicious intervention and/or otherwise from your end.

Our Privacy Policy is reviewed from time to time to take into account new laws and technologies, changes to our operations and practices, and to ensure that it remains appropriate to the changing environment.

If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

If you have a concern about any aspect of our privacy practices or believe we are in breach of our Privacy Policy, DIFC Data Protection Laws or any other relevant regulations you can submit a complaint, by email, telephone or writing to us. Please see below our contact details. This will be acted upon promptly.

If you are not satisfied with our response to your complaint, you have the right to submit a complaint with our supervisory authority the Commissioner of Data Protection (the “Commissioner”). You may contact the Commissioner at administrator@dp.difc.ae and/or by calling them on +971 4 362 2623.

For any matters relating to your personal data, you can contact us by:

Telephone: +971 4 526 8666

Email Address: dpo.mena@xm.com

Write to Us at the following Address: Unit S402, Level 4, Emirates Financial Towers, DIFC, Dubai, PO BOX: 507013, United Arab Emirates.