PRIVACY NOTICE
Watar Partners
Version: March 2021
The following entities:
A. Shuraka' Watar al-A'mal for Trading Company , a company incorporated under the laws Kingdom of Saudi Arabia having its registered office at Masharik Tower, 3rd Floor King Fahad Road, Al Moatamarat District P.O. Box 10215 Riyadh 11433 Kingdom of Saudi Arabia.
B. WATAR MANAGEMENT CONSULTANCY, a company incorporated under the laws of United Arab Emirates, having its registered office at 1105, Burj Al Salam, Sheikh Zayed Road, Dubai, United Arab Emirates; and
C. Watar Partners and Co (Private) Limited a company incorporated under the laws of Pakistan having its registered office at Officer #19, First Floor, Pak Land Business center, I-8 Markaz, Islamabad, Pakistan
(collectively referred to herein as “Watar”, “We”, “Us”, and “Our”) created this privacy notice to summarize the manner in which We protect the privacy of each user of Our website and/or Our mobile application (“You” and “Your”). This privacy notice describes Your rights and Our rights and practices in relation to any personal information We collect from You, and/or that You provide to us, and the methods that We follow when We maintain and process such personal information. As used in this privacy notice, “personal information” refers to the information that can be used to identify You, including without limitation Your name, email address, telephone number, residential address, mailing address, and credit card details, as well as other personal data that relates to You. Below are details of how We collect, maintain, and process Your personal information, and the rights that are applicable to You and to Us in this respect.
1. Use and Gathering of Information
Rationale for using Your personal information
You can generally expect to control Your own personal information, and by accessing and utilizing Our website and/or mobile application You acknowledge and agree that there are circumstances when We may need to collect and process personal information from You in order to provide You with Our services. Following are some examples of what information We may request and gather from You, and also a brief description of how We would use such information.
A. Account Opening and Ongoing Relationship Administration: When We establish a new business relationship, We will collect certain information to satisfy Our know your client (“KYC”) background checks. During the period that You are a client of Ours, We will carry out KYC checks periodically to be certain that the data and documents We have in Our records are current and complete. KYC materials would be comprised of certain personal information and documents, such as a Your full name, birth details, passport copy, government-issued identification card, residential address, email, phone number, nationality, marital status, family members, source of funds, and any other personal information.
B. Providing Our Services: Watar gathers personal information so that We are able to provide existing services to Our clients, notify Our clients about new services and features, and to provide You with reports about Your portfolio. The relevant personal information collected for this purpose would be comprised of data such as bank account details and balances, Your portfolio history and preferences, risk appetite, certain special requirements set by You, and portfolio transactions.
C. Customization: Watar may gather personal information to identify You by means of information technology systems that analyze visitors to Our website and users of Our mobile application. This would enable Us to customize Our platforms for You. The relevant personal information that may be collected by Watar for this purpose would include details of Your location, use patterns of Our platforms, and data regarding the devices that are used. In addition, Watar might retain data related to the different investments and asset classes that You prefer.
D. Client Events: Watar may gather personal information about individuals that attend a conference or seminar that We have arranged. For example, We may take photographs at an event sponsored by Watar, and such photographs may include an image of an attendee. Watar has the right to use these pictures on Our website and/or mobile application, for marketing and business purposes, and/or in social media posts and press releases. You have the right to inform Us if You do not wish pictures and/or personal information of You to be used in this way.
E. Internal Purposes: Watar may gather personal information, including KYC materials, from clients and You in order to comply with Our internal compliance requirements and external legal or regulatory compliance requirements.
Our gathering and recording of personal information (including for KYC purposes) may facilitate Our ability to communicate effectively and maintain an ongoing business relationship with You.
If We are gathering, maintaining and/or processing Your personal information in furtherance of Our marketing efforts, then You may notify Us at any time to request that We cease this activity. Watar will respect any such request and will take steps to cease this activity.
Watar can gather, maintain records of and process Your personal information in accordance with applicable laws, and to the extent that:
i. You have given Us consent to gather, maintain, and process Your personal information (for example by logging on to Our website and/or using Our mobile application);
ii. the personal information is required in order for Us to provide You with the services that You have requested from Us (by means of contract or otherwise);
iii. the relevant personal information is required in order for Us to satisfy Our internal compliance requirements and/or external legal or regulatory requirements; or
iv. Your personal interests, rights are not compromised by Our activities related to the personal information, and We have a legitimate business reason for such activities (including, without limitation, the reasons set out above in ii and iii).
Sharing of Your personal information
A. Within Our Group: Your personal information may be disclosed to Our affiliates and subsidiaries in furtherance of the services We provide to You.
B. Third Parties: Your personal information may be disclosed to certain third parties, including Our suppliers and service providers in furtherance of the services We provide to You, and any such disclosure will be subject to the service agreements entered into between Us and You. This would include information technology consultants, legal advisers, audit firms, and other third parties that We do business with on a regular or ad hoc basis. This would also include any entity that becomes an owner or controller of Our business. In addition, it is possible that certain counterparties may require Us to disclose Your KYC information to them in order for Us to carry out Our activities.
C. Photos: As previously stated, Watar may use pictures from Our special events for marketing and promotion, and Your personal image may appear in such pictures, unless You inform Us that You do not wish Your pictures to be used in this way.
D. Other Disclosures: Your personal information may be disclosed to the extent Our cooperation is necessary in connection with legal disputes, inspections, or other governmental or regulatory requirements.
Other than as described above, Your personal information will not be used or disclosed without Your consent.
2. Personal information Storage
By agreeing to do business with us, You acknowledge and agree that Your personal information in Our possession may be transferred to, and/or stored at, the cloud, or a location that is not in the country where You are located or where You provided it. So, the data protection laws that are relevant in Your home jurisdiction would no longer be applicable to such personal information. We will follow Our internal safety procedures in the handling and processing of Your personal information, and We expressly disclaim any and all liability in this respect, except to the extent that We are prohibited from doing so pursuant to applicable law.
A. Time of Retention: Watar can retain Your personal information for any period set by the laws and regulations that are applicable to Us. We may choose (at our own discretion) to destroy copies of Your personal information when Your personal information is no longer necessary for Our business purposes, and the relevant legal and regulatory requirements would allow Us to do so.
B. Other Websites: Watar’s website and/or mobile application may connect You to pages and sites that are owned and/or controlled by other parties. We have no obligation or liability for any collection or usage of Your personal information by such pages and sites, and this privacy notice is not applicable thereto.
C. Email Updates: Watar may send You email updates and reports as part of the services that We provide to Our clients. We will not provide Your email address to a third party for any commercial gain or other purpose, and You may at any time contact Us to opt out of receiving email updates and reports from Us.
3. User’s Obligations and Rights
Any personal information that You provide to Us in furtherance of Our services must be genuine and up to date. You must comply with Our reasonable requests related to Your personal information in a timely and transparent fashion. In order for You to continue using Our service, We require You to update Your personal information that is held with Us in the event any of this personal information changes.
You may contact Us at any time for information about Your personal information that is in Our possession, and We may provide You, or a third party of Your choosing, with copies. You may update or amend Your personal information by providing Us written and/or documentary evidence. In addition, You may contact Us at any time to notify Us of any special circumstances that You would like Us to be aware of in relation to how We store or process Your personal information. As mentioned previously, You may request that We cease processing Your personal information for promotional activities. You also have the right to make a complaint about Our use and maintenance of Your personal information using the contact details below, and Watar will address any such complaint in a straightforward and transparent manner.
4. Protection of Personal information
Watar will follow its internal security procedures to safeguard Your personal information, and to protect it from loss, accidental disclosure or misappropriation. It is not possible to maintain confidentiality and security when using the internet and/or a mobile application. Therefore, We do not guarantee the safety of Your personal information, but We endeavor to implement standard practices to protect Your personal information. Please contact Us if You would like further details about Our systems and safeguards.
5. General Provisions
Please note that Our website and/or Our mobile application are not intended for use by individuals that are not clients of Watar. We may from time to time allow a non-client to access Our website and/or mobile application under limited circumstances, subject to this privacy notice and Our standard terms and conditions. We will only collect, maintain or process personal information about a minor if such data is necessary in furtherance of a Watar service and We have received the approval of a parent or guardian (which would be Our client).
You may decline to receive any services or communications from Watar at any time by providing Us with notice. We will act on any such instruction to the extent allowable by law.
For any questions about this privacy notice or Our processing of personal information, please contact Us as follows:
By email: cs@watarpartners.com
By phone number: +966 11 465 3377
By post or courier: Masharik Tower , 3rd Floor King Fahad Road, Al Moatamarat District P.O. Box 10215 Riyadh 11433 Kingdom of Saudi Arabia
Watar reserves the right to amend or update this privacy notice from time to time, and the posting of any new privacy notice on Our website and/or Our mobile application shall constitute sufficient notice of the same.