Privacy Policy

Introduction

Arrowsphere Holdings Limited ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or engage with our services.

As a DIFC-incorporated private family office holding company, we adhere to the highest standards of data protection and privacy in accordance with applicable laws and regulations, including the DIFC Data Protection Law No. 5 of 2020 and international best practices.

Please read this Privacy Policy carefully. By accessing or using our website and services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy.

Information We Collect

Personal Information

We may collect personal information that you voluntarily provide to us when you:

• Contact us through our website or email
• Request information about our services
• Subscribe to our newsletters or communications
• Participate in surveys or provide feedback
• Apply for employment or partnership opportunities

This information may include your name, email address, phone number, professional title, company name, and any other information you choose to provide.

Automatically Collected Information

When you visit our website, we may automatically collect certain information about your device and browsing activity, including:

• IP address and geographic location
• Browser type and version
• Operating system
• Pages visited and time spent on pages
• Referring website addresses
• Date and time of visits

Business and Financial Information

For prospective or current business partners, investors, or service providers, we may collect additional information necessary for due diligence, compliance, and business operations, including financial information, investment history, and professional credentials.

How We Use Your Information

We use the information we collect for the following purposes:

• Communication: To respond to your inquiries, requests, and communications
• Service Delivery: To provide, maintain, and improve our services and website functionality
• Business Operations: To conduct due diligence, manage investments, and fulfill contractual obligations
• Legal Compliance: To comply with applicable laws, regulations, and legal processes
• Security: To protect against fraud, unauthorized access, and other security threats
• Analytics: To analyze website usage and improve user experience
• Marketing: To send you relevant information about our services, subject to your consent where required
• Record Keeping: To maintain accurate business records and documentation

Information Sharing and Disclosure

We respect your privacy and do not sell, rent, or trade your personal information to third parties. We may share your information in the following limited circumstances:

Service Providers

We may share information with trusted third-party service providers who assist us in operating our website, conducting our business, or providing services to you, provided they agree to keep this information confidential and use it only for the purposes for which we disclose it to them.

Legal Requirements

We may disclose your information when required to do so by law, in response to valid legal processes, to protect our rights or property, or to protect the safety of our users or the public.

Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction, subject to the same privacy protections.

Professional Advisors

We may share information with our legal counsel, accountants, auditors, and other professional advisors who are bound by confidentiality obligations.

Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and audits
• Access controls and authentication procedures
• Employee training on data protection and privacy
• Secure data storage and backup systems
• Incident response and breach notification procedures

However, please note that no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Your Rights and Choices

Depending on your location and applicable laws, you may have certain rights regarding your personal information:

Access and Portability

You have the right to request access to the personal information we hold about you and, in certain circumstances, to receive a copy of that information in a portable format.

Correction and Update

You have the right to request correction of inaccurate or incomplete personal information we hold about you.

Deletion

You have the right to request deletion of your personal information, subject to certain legal exceptions and retention requirements.

Objection and Restriction

You have the right to object to certain processing of your personal information and to request restriction of processing in certain circumstances.

Withdrawal of Consent

Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section below. We will respond to your request within a reasonable timeframe and in accordance with applicable law.

Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze website traffic, and understand user preferences.

What Are Cookies?

Cookies are small text files that are placed on your device when you visit a website. They help websites remember your preferences and improve functionality.

Types of Cookies We Use

• Essential Cookies: Required for the website to function properly
• Performance Cookies: Help us understand how visitors interact with our website
• Functional Cookies: Remember your preferences and settings
• Analytics Cookies: Provide insights into website usage and performance

Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of our website.

International Data Transfers

As a DIFC-incorporated entity, we operate internationally and may transfer your personal information to countries outside the DIFC for processing and storage. When we do so, we ensure that appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable data protection laws.

These safeguards may include standard contractual clauses, adequacy decisions, or other legally approved transfer mechanisms.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The retention period depends on various factors, including:

• The nature of the information collected
• The purpose for which it was collected
• Legal and regulatory requirements
• Contractual obligations
• Our legitimate business needs

When personal information is no longer needed, we will securely delete or anonymize it in accordance with our data retention policies and applicable laws.

Children's Privacy

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child, we will take steps to delete that information as soon as possible.

If you believe we have collected information from a child, please contact us immediately using the information provided below.

Third-Party Websites and Services

Our website may contain links to third-party websites and services that are not operated or controlled by us. This Privacy Policy does not apply to those third-party websites or services.

We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party websites or services before providing any personal information or using their services.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will update the "Last updated" date at the top of this Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information. If we make material changes to this Privacy Policy, we will provide notice through our website or by other means as appropriate.

Your continued use of our website and services after any changes to this Privacy Policy constitutes your acceptance of those changes.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We will make every effort to resolve your concerns and respond to your requests in a timely manner, in accordance with applicable data protection laws.

Governing Law and Jurisdiction

This Privacy Policy is governed by and construed in accordance with the laws of the Dubai International Financial Centre (DIFC) and applicable international data protection standards.

Any disputes arising from or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the DIFC Courts.