Privacy policy
At Curated Capital we are committed to safeguarding and preserving your privacy.
This Privacy Policy (together with the website Terms and Conditions) explains what happens to any personal data that you provide to us, or that we may learn about you while you visit our websites, attend Curated Capital events, visit our offices, use our services or invest in any products managed by us. This notice also informs you about your privacy rights and how the law may protect you.
We update this Policy from time to time, so please do review it regularly.
This privacy policy is designed to comply with the Abu Dhabi Global Market (ADGM) Data Protection Regulations (DPR) 2021.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
How and from where we may receive personal data
From you
- When you contact or correspond with us (for example, by phone (including during recorded calls), e-mail or otherwise) for any other reason (for example, to request services from us);
- When you use our Website or visit our social media accounts;
- When you report a problem with the Website;
- When you provide us with feedback, opinions and/or comments regarding the Website or our services.
- When you:
- register to receive information from us;
- meet with us;
- attend our events;
- interact with us at third party events;
- hand us your business card;
- subscribe for updates;
- sign up to our website;
- participate in our surveys, competitions, questionnaires etc.; or
Data from other sources
Like many other businesses, we may receive personal data from many sources. This section seeks to list various places from where we may receive personal data about you.
Data we indirectly gather about you:
- When you use the Website, details of your usage (including the date, time, location or duration of the usage);
- If you visit the Website, certain technical information, for example, the type of device (and its unique device identifier) you use to access the Website, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform; and
- Information about your visit to the Website including the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Data we may receive from third parties
- Companies that introduce you to us
- Social networks (e.g. Google, Twitter — see below for further details and our cookies policy below)
- Public information sources such as Companies House or the Financial Conduct Authority’s Register
- Market researchers/Data providers who collect and provide personal data from many sources for the specific and approved purpose of sharing such data with businesses like ours to help with our internal analysis (including assessing market trends, fund distributions statistics etc).
- Marketing partners engaged to help distribute content on us and our services through any medium
- Agents, consultants and advisers. These can be specialist companies who advise us on ways to develop and improve our services and products. These can also be types of firms that help us to prevent, detect and reports unlawful acts and fraudulent behaviours, in particular with regards to financial crime.
- Government and law enforcement agencies.
Purpose and legal basis for processing your data
| Purpose of processing | Type of personal data | Legal basis for processing |
|---|---|---|
| To enable us to check your identity | Name, address, date of birth, passport details, driving license details and any other information you may provide us with | Legal obligation |
| To enable us to complete anti-money laundering checks to prevent financial crime and guard against market abuse activities | Name, address, date of birth, passport details, driving license details and any other information you may provide us with | Legal obligation |
| To deal with any enquiries, correspondence, concerns or complaints you have raised | Name, phone number, email address and details of the enquiry raised | Legitimate interests – to enable us to improve our services and the Website |
| To process any relevant payments | Bank, credit or debit card details | Performance of a contract with you |
| To enable us to process a referral from a third party (for example, a financial adviser) | Name, address, telephone number, email address, details of the referral and details of the third party making the referral | Legitimate interests – to enable us to process the referral |
| To compile internal reports and statistics of usage of the Website and our products and services | Name, details of any products or services purchased and the technical information mentioned above | Legitimate interests – to enable us to develop and manage our brands, products and services |
| To process your registration made via our Website to enable you (whilst acting on behalf of your company) to access the Curated Capital services | Your name, email address and company details (if applicable) | Legitimate interests – to enable us to provide you (where you have registered on behalf of your company) with Curated Capital online services |
| To send you our news items, marketing materials, product information, blog posts, insights and articles via email | Your name and email address | Legitimate interests – to enable us to communicate with business contacts or Consent – where we contact you in your personal capacity, for example where you are a user of our Website |
| To provide you with information, products or services that you request from us or which we feel may interest you | Your name and email address | Legitimate interests – to enable us to communicate with business contacts or Consent – where we contact you in your personal capacity, for example where you are a user of our Website |
| To assess how people use our products and services | Technical information as mentioned above | Legitimate interests – to enable us to improve our products and services |
| For our internal operations, including data analysis, testing, research, statistical purposes and troubleshooting | Technical information as mentioned above | Legitimate interests – to enable us to improve our products and services |
| As part of our efforts to keep the Website safe and secure | Technical information as mentioned above | Legitimate interests – to enable us to improve our products and services |
| To communicate with you if you wish to post on our Website | Your name, contact details, details of the post you wish to make and technical information as mentioned above | Legitimate interests – to review your request |
| To invite you to Curated Capital events | Your name, email address and details of the event | Legitimate interests – to allow us to obtain attendees for Curated Capital events |
| To enable us to host an event | Your name, email address, details of the event and any applicable dietary requirements (including relevant medical information) | Legitimate interests – to allow us to host Curated Capital events for attendees The legal basis for processing any medical information to ensure we adhere to your dietary requirements and allergies will be consent. |
| To enable us to comply with our health and safety obligations when hosting an event (such as fire marshal duties) | Your name and details of the event you are attending | Legal obligation |
| To administer any quizzes and prize competitions we may run | Your name, email address, telephone number and your prize competition entry or quiz entry | Legitimate interests |
| To run polls in which you may choose to participate, for example via Twitter. We may then use the results of our poll (including your views) to inform our market insight or articles we may write | Your Twitter handle (or other relevant social media handle), the IP address associated with you (if relevant) and details of your response to the poll | Legitimate interests – collecting and analysing information for market analysis purposes, which you submit voluntarily |
| To receive feedback on our corporate governance and performance, including any views of investors in the funds that we manage | Your name, email address, telephone number and details of the feedback provided | Legitimate interests – collecting and analysing feedback on our performance and the performance of funds that we manage |
| To personalise the content you may see from us online (either on our Website or the websites of our online partners) if you have agreed to targeted advertising cookies | Your IP address and your consent to the use of targeted advertising cookies | Consent |
| To share your details (where you are an independent financial adviser business contact) with suppliers who carry out market analysis and information relating to IFAs, to enable them to take you into account in their research and analysis | Your name | Legitimate interest of the supplier – to carry out research and analysis on IFA market activity and publish information a directory of such activity – we would contractually require suppliers to whom we provide data to comply with data protection laws in their use of that data |
Privacy policy
Where we have a legal basis for using your personal data without consent (as we have described above), this Privacy Policy fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of how your personal data will be used.
Where consent is required to use your personal data as described above, we will request your permission. Typically, we would collect your consent by you performing an action such as ticking the appropriate consent box or otherwise communicating your consent to us (for example, by email or by you providing us with non-mandatory information); you consent to our use of that personal data as set out in this policy.
You can always change your mind about our processing of your personal data. If you change your mind, you can contact us by email at hello@curatedim.com, or in respect of marketing messages, you can unsubscribe by using the unsubscribe link at the bottom of our marketing messages.
Cookie Policy
Like most other websites, our Website uses cookies. Cookies are small text files stored on your computer or mobile device by your browser. Cookies can be used to store certain preferences on a website or track if you have visited that site before.
No cookies used by Curated store personally identifiable data such as:
- Names
- Phone numbers
- Email addresses
- Mailing addresses
- Financial data
If you would like to limit or block the usage of cookies, you can do so in your browser settings. These settings differ between browsers.
By clicking “I Agree” on the cookie consent banner when you first access the Website, and by using this site without changing your cookie settings, you are consenting to our use of cookies.
If you choose not to allow cookies, the quality of your browsing experience may be reduced, and you may not be able to access all or parts of the Website. You can opt out of some individual cookies as described below.
If you have questions about our use of cookies, please email hello@curatedim.com.
For more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org.
Retaining personal data
We will retain the personal data we receive or collect about you for the period reasonably required for us to use it in accordance with this Privacy and Cookies Policy or in accordance with our legal rights and obligations. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your rights
You have the following rights with regard to your personal data:
- Right to Access: You can request a copy of the personal data we hold about you and check that we are lawfully processing it.
- Right to Rectification: You can ask us to correct any inaccurate or incomplete personal data.
- Right to Erasure: You can request that we delete your personal data where there is no legitimate reason for us to retain it.
- Right to Restriction of Processing: You can ask us to restrict the processing of your personal data in certain situations.
- Right to Data Portability: You can request to receive your personal data in a structured, commonly used format and have it transferred to another controller.
- Right to Object: You can object to us processing your personal data for legitimate interests or direct marketing.
Please note that if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type of processing or data is needed to facilitate your use of any of our products or services, you may not be able to use them as you did before. This does not include your right to object to direct marketing, which can be exercised at any time without restriction. Please allow at least five working days for your request to be actioned.
Please note that the rights mentioned above do not extend to non-personal data. Please also note that it is likely to be necessary to retain your personal data for the purposes of assessing and verifying your submitted data and to manage our products and services, so your rights under applicable law to request erasure may be limited accordingly.
If you would like to exercise any of the rights mentioned above, please contact us at hello@curatedim.com.
Disclosure of your personal data
We may disclose your personal data to other organisations, including:
- Other companies in the Curated Group and their agents;
- Service providers (for example, IT services), business partners, suppliers and sub-contractors for the performance of any contract we enter into with you and for processing of our data on the basis of our legitimate interest (as we have explained in this policy) including providing you with marketing communications or developing and tailoring products. Such service providers may help us to update your records, carry out marketing fulfilment services (such as distributing our materials and reports) and help us analyse data for our internal purposes;
- Analytics, market researchers, data partners and search engine providers that assist us in the improvement and optimisation of the Website, our services, our products and their distribution;
- Government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information);
- If we sell any business or assets or receive investment into our business, in which case we may disclose your personal data to the prospective buyer or investor;
- If we or substantially all of our assets are acquired by a third party, in which case personal data held by us, including your personal data, will be one of the transferred assets; and
- If we are under a duty to disclose or share your personal data to comply with any legal obligation or in order to enforce or apply the Terms and Conditions for our Website or any other contract between you and us;
- Or to protect the rights, property or safety of Curated, our users, and others.
Storing your personal data and transferring data outside of the ADGM
“In operating our Website and services, it may become necessary to transfer data that we collect from you to locations outside of the Abu Dhabi Global Market (ADGM), such as the European Union, UK, US and Australia, for processing and storing. In compliance with the ADGM Data Protection Regulations (DPR) 2021, we will ensure that any international transfers of personal data are protected by Standard Contractual Clauses (SCCs), Binding Corporate Rules (BCRs), or other appropriate safeguards as outlined in Articles 41-44 of the ADGM DPR 2021.
Our Website can also be accessed and used worldwide, which means your data may be processed outside the ADGM. Please note that the country from which you are accessing personal data may not provide an adequate level of protection for your personal data.
Security
All information you provide to us is stored on secure servers. We will use appropriate technical and organisational measures to safeguard your personal data.
Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We maintain (and ensure that anyone we share your personal data with maintains) appropriate technical and organisational measures to ensure an appropriate level of security in respect of all personal data we process. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the Website or any of our services; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access or inadvertent disclosure.
Third-party links
On occasion, we include links to third parties on this Website. Where we provide a link, we are not responsible for the collection or use of your personal data from these third party websites. You should review their privacy policy before sending them any personal data.
Letting us know if your information is incorrect
If any of the information which we hold about you is incorrect, please tell us, and we will amend it. You can email us at hello@curatedim.com.
How to complain
This section tells you how you can contact us to complain about our data privacy processes and how you can contact appropriate government regulators.
Please let us know if you are unhappy with our use of your personal data. You can contact us using hello@curatedim.com.
How to withdraw your consent and the implication of not providing personal data
This section explains what to do if you no longer want us to hold or use your personal data. This section also explains the effects of not choosing to provide personal data.
Withdraw consent
You can withdraw your consent at any time. Please contact us at hello@curatedim.com if you want to do so.
This will only affect how we use information when our reason for doing so is that we have your consent.
If you withdraw your consent or do not provide minimum personal data (like contact details), we may not be able to
- provide information on certain products or services to you;
- keep you informed on our business developments;
- contact you regarding your desire to post on our Website; or
- report back to you on the status of any complaints you have made.
Contacting us
Please contact us if you have any questions relating to this Privacy and Cookies Policy at hello@curatedim.com.
