Data Protection Notice

Alpen Asset Advisors Limited (“AAA”) is responsible for ensuring that it uses your Personal Data in compliance with the DIFC Data Protection Law No. 5 of 2020 (“DIFC DP Law”). The purpose of this notice (the “Data Protection Notice”) is to explain what Personal Data AAA collects, how AAA uses it and how AAA processes Personal Data, which is subject to the applicable contractual terms and conditions.

In this Data Protection Notice when we refer to “AAA” or “we”/“us”/“our” refers to Alpen Asset Advisors Limited which acts as a data controller (alone or jointly determining the purpose and means of processing).

Please read the following information carefully to understand our views and practices regarding how we handle Personal Data. You can find contact details of the data controllers within AAA, by contacting us in accordance with the “Contact” section below.

Personal data that AAA collects

"Personal Data" includes any information relating to an identified or identifiable natural person (e.g., name, ID card and passport numbers, nationality, contact details) or that of an Affected Person.

Such information also includes any information that you or someone acting on your behalf provides to AAA. This includes information about you that you give AAA by filling in forms, or by communicating with AAA, whether face-to-face, by phone, e-mail or otherwise. If you are a client or are connected with one of our client's matters, this may include Personal Data about you or others that is provided to AAA in connection with the provision of services to you or to the client.

An "Affected Person" means an individual or entity whose information you or a third party(s) provide to us and/or which otherwise comes to our knowledge in connection with our business/client or employment relationship. An Affected Person may include, but is not limited to, (i) clients, prospective clients, counterparties, prospective counterparties and any other person(s) involved in the business relationship, as the case may be (ii) any director, officer, employee, authorized signatory or shareholder of a company, (iii) a trustee, settlor, beneficiary or protector of a trust, (iv) any nominee or beneficial owner, (v) persons(s) holding power of attorney (vi) a substantial interest owner in a business/client relationship , (vii) a controlling person, (viiii) a payee of a designated payment, (ix) any representative(s) or agent(s) or (x) AAA’s employees, directors and shareholders.

We collect and use your Personal Data to the extent necessary in the context of our activities, in particular to achieve a high standard of services. We collect various types of Personal Data about you depending on the nature of the particular service we provide, including:

  • identification information (e.g., full name, ID card and passport numbers, nationality, place and date of birth, gender, photograph);
  • contact information (e.g., address and email address, phone number);
  • family situation (e.g., marital status, number of children);
  • tax status (e.g., tax ID, tax status);
  • education and employment information (e.g., level of education, remuneration);
  • banking, financial and transactional data (e.g., bank account details, transfer of assets, source of wealth);
  • data related to designation as a politically exposed person (PEP);
  • data relating to criminal convictions and offences;
  • data which relates to your use of our services;
  • data from your interactions with us (e.g., our meetings, calls, emails, phone conversations); and
  • background checks;

We never ask for sensitive data or special categories of personal data (i.e., data related to your racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, genetic data, data concerning your sexual orientation or data relating to criminal convictions and offences) unless it is required by law. If we need to process sensitive data for other purposes, we will inform you and obtain your explicit prior consent.

Use of Personal Data

We collect and process Personal Data for the purposes (hereinafter the "Purposes") and based on the legal bases set forth herein:

A. Performance of a contract - we may need to collect and use Personal Data to enter into a contract with you or to perform our obligations under a contract, including but not limited to:

  • provide and perform our obligations with respect to the services we provide or otherwise in connection with fulfilling your instructions;
  • enforce applicable terms of contracts;
  • send administrative information, such as change of our terms, conditions and policies;
  • provide you with information, including reports, regarding our services;
  • assist you and answer your requests as a necessary part of the provision of our services to you, and to manage our relationships;

B. Legitimate interest - we may use Personal Data in order to deploy and develop our services, to improve our risk management, to defend our legal rights and to protect our privacy, safety or property and/or that of our affiliates, yours or others, including but not limited to:

  • to prove transactions;
  • to prevent, detect, investigate about fraud;
  • to manage our IT infrastructure and security of our IT systems;
  • to manage risk;
  • to personalize our offering of services to you;
  • to provide customer management and administration;
  • to analyse, evaluate and improve our business/marketing;
  • to develop our business relationship with you and to improve the quality of our services;
  • to provide you with marketing information on services that match with your circumstances and characteristics or those of the legal entity that you represent; and
  • to establish, exercise and/or defend actual or potential legal claims, investigations or similar proceedings.

C. Compliance with law or regulation - we may use Personal Data as necessary to comply with applicable law/regulation, including but not limited to:

  • comply with regulations dealing with prevention of money-laundering, financial crime, financing of terrorism and market abuse;
  • comply with regulations relating to sanctions and embargos;
  • comply with regulations relating to financial markets in particular with regard to investor protection;
  • set up security measures in order to prevent abuse and fraud;
  • detect transactions which deviate from normal patterns;
  • record, when necessary, our interactions (such as phone calls, email);
  • identify and manage risks;
  • reply to an official request from an administrative or judicial authority which may include authorities outside your country;
  • fight against tax fraud and fulfilment of tax control and notification obligations(such as, without limitation, AEOI and FATCA obligations); and
  • comply with any applicable transaction reporting obligations.

If we need to carry out further processing for purposes other than those mentioned above, we will inform you and, where necessary, obtain your consent.

Disclosure / Transfers of Personal Data to third parties

We will transfer Personal Data about you in the course of our providing services to you in the normal course of business, or if legal, regulatory or market practice requirements necessitates such sharing to external recipients as indicated below:

AAA may disclose Personal Data outside of AAA, as follows:

  • to third party agents, service providers or contractors, bound by obligations of confidentiality, who will only use Personal Data on AAA's behalf for the Purposes described in this Data Protection Notice;
  • to third parties relevant to the services outlined in the contract with you or the contract of a client/ supplier with whom you are connected. This may include for example counterparties to transactions, professional advisers, auditors, lawyers, financial institutions, investors, stock exchanges, banks, brokers, custodians, third party administrators, regulators;
  • to the extent required by law, regulation or court order for example if AAA is under a duty to disclose Personal Data in order to comply with any legal or regulatory obligation including the Dubai Financial Services Authority (DFSA), the Dubai International Financial Centre (DIFC), applicable regulators, relevant registrar of companies, other supervisory authorities and law enforcement authorities; and
  • to any other persons, public authority, agency or body as agreed with you

We reserve the right to make Personal Data accessible to other recipients, as disclosed to you from time to time or if required by applicable laws or requested by a competent authority.

The provision of Personal Data may be mandatory, e.g., in relation to our compliance with legal and regulatory obligations to which we are subject. Please be aware that not providing such information may preclude us from pursuing a business relationship with, and/or from rendering our services to you.

Transfers of Personal Data to a third country

In certain circumstances, we may transfer the Personal Data to another country than the country of establishment of each AAA entity acting as data controller for the relevant Personal Data processing.

In case of international transfers to a country for which the DIFC has recognized that it provides an adequate level of data protection, your Personal Data may be transferred on this basis.

For transfers to a country where the level of Personal Data protection has not been recognized as "adequate" by the DIFC, we will rely on a derogation applicable to the specific situation (e.g., if the transfer is necessary to perform our contract with you) or implement appropriate safeguards to ensure the protection of your Personal Data (such as standard contractual clauses or corporate binding rules approved by competent authorities).

Retention of Personal Data

We will retain Personal Data for the longer of:

  • the period required by applicable law or contractual obligations; or
  • such other period necessary for us to meet our operational obligations, such as proper account maintenance, facilitating client relationship management and responding to legal claims or regulatory requests.

Most Personal Data collected in relation to a specified client is kept for the duration of the contractual relationship with such client plus a specified number of years after the end of the contractual relationship or as otherwise required by applicable law.

Rights in relation to Personal Data

You have a number of legal rights in relation to the Personal Data that AAA holds about you. These rights include:

  • the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which AAA holds about you;
  • the right to request that AAA rectify your Personal Data if it is inaccurate or incomplete;
  • the right to request that AAA erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask AAA to erase your Personal Data but AAA is legally entitled to retain it;
  • the right to object to, and the right to request that AAA restrict, its processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask AAA to restrict, its processing of your Personal Data but AAA is legally entitled to continue processing your Personal Data and / or to refuse that request;
  • in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that AAA transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided to AAA;
  • the right to withdraw your consent, although in certain circumstance it may be lawful for AAA to continue processing your data where AAA has another legitimate reason (other than consent) for doing so. AAA is not relying on your consent in order to process your Personal Data for the purposes and in the manner set out in this Data Protection Notice; and
  • the right to lodge a complaint with the DIFC-Data Commissioner if you think that any of your rights have been infringed by AAA.

You can exercise your rights by contacting AAA using the details set out in the “Contact” section below.


If you would like further information about AAA's processing of Personal Data or the exercise of any of the rights referred to above, please address questions, comments and requests via:


Tel: +971 4 363 4300

Notification of changes

We reserve the right to amend this Data Protection Notice at any time. Our processing of your Personal Data will be governed by the practices set out in that new version of the Data Protection notice from its effective date onwards. Any changes we may make to this Data Protection Notice in future will be posted on this page.

Updated on: September 2020