In accordance with the provisions of the DIFC Data Protection Law No. 5 of 2020 (“DP Law”), Integra Asset Management Limited (“the Firm,” “we,” “us”), acting as a Data Controller, is committed to fulfilling our obligations under the DP Law by informing individual Data Subjects about their data rights. We are dedicated to safeguarding personal data and adhering to all relevant privacy and data protection laws. In our ongoing commitment to transparently protect your Personal Data, we aim to provide you with details on:

– Why and How We Collect, Process, and Store Your Personal Data We will explain the reasons for collecting, processing, and storing your Personal Data, ensuring complete transparency in our operations.

– The Legal Basis for Processing Your Personal Data We will elucidate the legal foundations upon which your Personal Data is processed.

– Your Rights and Our Responsibilities in Relation to Data Processing

1. Scope of this Privacy Notice This notice pertains to all forms of Personal Data usage (“processing”) by the Firm within or originating from the DIFC.

2. Data Collection Sources We collect your information through various means, including:

• Data you provide directly, as well as data from individuals associated with your business services or acting on your behalf.
• Data obtained from third-party companies, such as referencing agencies and public sources.

3. Types of Information We Collect The specific data we collect varies according to the services we provide. It may encompass personal details, identification, and authentication data, contact details, financial information, and more, including certain special categories of data when permitted by law.

4. Purpose of Processing We process Personal Data for specific purposes, including client onboarding, client relationship management, compliance with legal obligations, and fraud prevention.

5. Legal Basis for Processing We process Personal Data based on legal grounds, including fulfilling contractual obligations, complying with legal requirements, protecting vital interests, pursuing legitimate interests, and obtaining your consent when necessary.

6. Your Obligations You are obligated to provide the necessary Personal Data for establishing and maintaining a business relationship, especially for anti-money laundering compliance.

7. Your Consent If you grant us consent under DIFC regulations for processing your Personal Data, it forms a legal basis for such processing.

8. Data Processing We process Personal Data both manually and electronically to ensure data security and confidentiality, in compliance with current regulations. Our employees and third-party processors access your data, with appropriate safeguards in place.

9. Access and Sharing of Personal Data We may transfer Personal Data to third parties as required by law or to fulfil contractual obligations, and these transfers may include data going outside the DIFC.

10. Data Retention We retain Personal Data as necessary to fulfil the intended purpose and comply with legal, regulatory, and internal policy requirements.

11. Your Rights You have the legal right to request access to, correction of, restriction of use, erasure, and withdrawal of consent for your Personal Data, subject to certain conditions.

12. Automated Decision-Making and Profiling We generally do not use fully automated decision-making, but if we do, we will inform you as required by law.

13. Exercising Your Rights For exercising your rights, please contact us at the provided details.

14. Contact Information If you have concerns regarding data protection and privacy, contact us at [email protected], Office 26-37 Central Park, DIFC, PO Box 507154, Dubai, United Arab Emirates, or email [email protected]

15. Changes to the Privacy Notice This notice explains how the Firm manages your Personal Data and your rights under the DP Law. While it does not create a contractual obligation, you can request a copy from us. We may periodically update this notice and will provide advance notice for any changes significantly impacting data processing or your rights.