Privacy
Amal Invest is committed to protecting its Clients’ (collectively “Users”, “you”, “your”) privacy and data security. This Privacy Policy outlines how Amal Invest LLC and its affiliates (collectively, “Amal,” “we,” “our,” or “us”) process the information we collect about you through our websites, mobile apps, and other online services (collectively, the “Services”) and when you otherwise interact with us, such as through our customer service channels.
Amal Invest is the registered Data Controller of your Personal Data (please refer to the Abu Dhabi Global Market (“ADGM”) Data Protection Office’s https://www.adgm.com/faqs/data-protection-office#what-are-the-adgm-data-protection-regulations-2021 website for definitions), acting in compliance with the Data Protection Regulation 2021 (“DPR 2021”). We provide this Privacy Policy to inform you of our Privacy Policy and practices, and of the choices you can make about what information is collected, the manner in which that information is collected and how that information is used. This Policy sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us, and how the information can benefit your experience on our website and Amal Invest App (“App”). We wish to help you make informed decisions, so please take a moment to read the sections below.
We will ensure that your Personal Data is private and safe, and never sold to third parties. The information you provide may be confidential, and we will maintain such confidentiality and protect your information in accordance with this Policy, our professional obligations and applicable law. We may share information with our service providers for the purposes set out in this Policy.
We also allow you to manage and review your marketing choices at any time. If you would like to cease receiving marketing materials from us at any time, please let our Data Protection team know directly. You can also change your preferences for receiving our marketing emails and legal updates from us at any time, and you can unsubscribe by following the instructions specified in our marketing emails or via our websites. Please update your details by contacting our Data Protection team by email at [email protected]
With your consent, we may send you push notifications with information through our App. You may grant us access to your location data (through GPS technology) or contact details in order to provide services requested by you. Please read the instructions of your mobile device to understand how to change the settings and enable the sharing of such data or the receipt of push notifications.
This Privacy Policy is effective as of 1st January, 2022 and will remain in effect except with respect to any changes in its provisions in the future. Amal may amend this Privacy Policy from time to time in order to meet changes in the regulatory environment, business needs, or to satisfy the needs of our Users and service providers. Any changes we make to our Privacy Policy will be posted on https://amalinvest.com (“Main Website”) and date stamped so that you are always aware of the latest update. Therefore, the Users are encouraged to frequently visit this Policy in order to be updated about the changes. Modifications will be effective on the day they are posted.
Information You Provide
We collect information you provide when you use our Services or otherwise engage or communicate with us as described below. By providing us with any of the below information, you are consenting to the use of your Personal Data as contemplated in this Policy. If you do not want us to use your Personal Data, please do not provide any.
“Identity Data”, such as your name, date of birth, marital status, social security number, biometric identifiers, and other data on government-issued identification documents;
“Contact Data”, such as your email address, mailing address, and telephone number;
“Financial Data”, such as your bank account and payment card details, and information about your income, account balances, financial transaction history, credit history, tax information, and credit scores;
“Profile Data”, such as your username and password, your knowledge assessment results, your interests, preferences, feedback, and survey responses; and
“Additional Data You Provide”, such as via focus groups, survey responses, contests/sweepstakes, customer support, or other means.
Information We Automatically Collect
As is the case for many other digital platforms, we also collect some information about you automatically when you use our Services, as described below.
“Usage Information”, meaning we collect information about your activity on our Services, which includes device identifiers (like IP address or mobile device identifiers), pages or features you use, time and date of access, and other similar usage information;
“Transactional Information”, meaning when you receive, submit, or complete a transaction that includes, but not limited to an Order (as defined in the Trading Terms and Conditions) via the Services, we collect information about the transaction, such as transaction amount, type and nature of the transaction, and time and date of the transaction;
“Information Collected Through Tracking Technologies” mean that we and our service providers also use technologies, including cookies and web beacons, to automatically collect certain types of usage and device information when you use our Services or interact with our emails. The information collected through these technologies includes your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique device or account ID, usage information (e.g., engagement with the Main Website content such as clicks and subscriptions) and other similar information. For information about how to disable cookies, please see the Your Rights section below.
Third Party Information Collection
We may use third party services that may collect your data, or we may collect your data from third parties as described below.
For safeguarding securities and to act as the executing broker, Amal has contracted Alpaca Securities LLC, a limited liability company duly organized and in good standing under the laws of the state of Delaware, United States. Alpaca maintains a principal place of business at 20 North San Mateo Drive, Suite 10, San Mateo, California, 94401. Alpaca Securities LLC is a member of Financial Industry Regulatory Authority, Inc. (FINRA) ("Custodian"). By utilizing our Services, you acknowledge and agree that the terms of our Custodian's Privacy Policy (currently located at https://files.alpaca.markets/disclosures/library/PrivacyNotice.pdf ) will govern our Custodian's use of such information, and you consent to Custodian's Privacy Policy. Further, you expressly grant Custodian the right, power, and authority to access and transmit your information as reasonably necessary for Custodian to provide its services.
“Connected Services” mean if you link, connect, or log in to your App Account (as described in the Trading Terms and Conditions) with a third-party service (e.g., Google, Apple), the third-party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
“Publicly Available Data” includes contact information, your interactions with our social media platforms, and other information from publicly available sources, such as public websites.
“Advertising Data” means that we collect information in connection with our ad campaigns that surfaced on other platforms, such as the ads you clicked on and other interactions with our ads.
What We Do with Your Information
We maintain and provide the Services, including to process account applications, authenticate your identity, repair our Services, and handle billing and Account management;
Allow our Custodian to comply with the regulations of all jurisdictions in which they must comply in order to provide their services;
Send you transactional or relationship information, including Account Statements (please refer to Trading Terms and Conditions to see what it entails), transaction confirmations, invoices, technical notices, customer support responses, software updates, security alerts, support and administrative messages, and information about your transactions;
Communicate with you about offers and other things we think you will be interested in, such as newsletters, product announcements, surveys, contests or sweepstakes, events or announcements;
Personalize our Services, such as by suggesting content or customizing content or ads we show you;
Monitor and improve our Services, including analyzing usage, research and development;
Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
Help protect the safety and security of our Services, business, and users, such as to investigate and help prevent fraud or other unlawful activity;
Protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements; and
Comply with applicable laws and legal obligations, such as compliance obligations associated with being a regulated broker under the Financial Services Regulatory Authority (“FSRA”).
Third Party Information Disclosure
We are committed to maintaining your trust, and we want you to understand when and with whom we share information about you. We share information about you in the instances described below.
Authorized third-party vendors and service providers. We share information about you with third-party vendors and service providers who perform services for us, such as identification verification, fraud prevention, advertising, mailing services, tax and accounting services, contest fulfillment, web hosting, and analytics services. With your consent, we may record your voice and/or video and send this data to our third-party partner to authenticate you and to help prevent fraud. The information collected from your photo and your voice by our third-party vendors may include biometric data for identity verification purposes. Please refer to our third-party identity verification service provider OnFido’s Privacy Policy https://onfido.com/privacy/#intro for more information.
Social media marketing. When we use social media for marketing purposes, your personal data (only hashed data that includes name and email address) may be shared with the social-media platforms so that they can check if you also hold an account with them. If you do, we may ask the advertising partner or social-media provider to:
use your personal data to send our adverts to you, because we think that you might be interested in a new Amal Invest product or service;
not send you our adverts, because the marketing relates to a service that you already use; or
send our adverts to people who have a similar profile to you (for example, if one of our services is particularly useful to people with similar interests to the ones on your social-media profile, we may ask our advertising partner or social-media partner to send our adverts for that service to those people).
Companies in which you hold securities. Amal may provide your name, address, email address, and securities positions to requesting companies in which you hold securities.
Amal affiliates. Where appropriate, we share information about you with other companies owned or controlled by Amal. These companies will process any information shared in the same manner as described under this Privacy Policy.
Substantial corporate transactions. We may share information about you in connection with a substantial corporate transaction, a merger, consolidation, reorganization, financing, change in control or acquisition of all or a portion of our business by a third party, or in the unlikely event of a bankruptcy or similar proceeding.
Legal purposes. We disclose information about you if we believe that disclosure is in accordance with, or required by, any applicable law or legal process or to protect and defend the rights, interests, safety, and security of Amal, our users, or the public. An example for this might include but is not limited to Financial Data and Transactional Information to fraud-prevention agencies, the UAE or other governmental authorities or law enforcement agencies in line with anti-money laundering and counter-terrorism legislations.
With your consent. We share information about you for any other purposes disclosed to you with your consent.
We share information with others in an aggregated or otherwise de-identified form that does not reasonably identify you.
How and Where We Store Your Data
The data that we collect from you may be transferred to and stored on our databases, located on our secure servers. Unfortunately, the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically, sending such information is entirely at your own risk.
We will retain your Personal Data and other Data and information that are mentioned throughout this Policy for the length of time needed to fulfil the purposes for which it was collected (as outlined in this Policy) unless a longer retention period is required or permitted by law. Your Personal and other Data and information that is processed for marketing purposes will be stored until you exercise the right to withdraw consent, and once such right is exercised, your personal information will be kept only during the applicable statute of limitations period for any disputes or liabilities that may arise because of the processing of that information (which is up to 15 years in the UAE). Once potential actions are time-barred we will proceed to delete the Personal Data. In any other circumstances, we will only retain your personal information for a shorter or longer period as required by any applicable law.
Amal does not wish to receive personal data from minors under the age of 18. We are however unable to determine the age of persons accessing and using our websites. Where a minor provides us with his or her data without parental or guardian consent, we encourage the parent or guardian to contact us immediately, whereupon we will arrange for the prompt removal of the minor’s information and unsubscribe the minor from further Amal communications.
Amal recognizes the importance of information security and as such our Main Website and our App has security measures in place to prevent loss, misuse or alteration of your personal information while under our control. We endeavor to safeguard your information using both procedural and technical safeguards, including firewalls’ and by keeping your information secure on a dedicated server. We are continually reviewing and enhancing our technical, physical, and logical security rules and procedures to offer you the best protection whilst using our Main Website and App.
Your Rights
To exercise your below mentioned rights, please contact us through [email protected] or our App. Your ability to exercise these rights will depend on several factors. Sometimes, we will not be able to agree to your request (e.g., if we have a legitimate reason for not doing so or the right does not apply to the particular information we hold about you).
You have the right to be told about how we use your Personal Data. We provide this privacy policy to explain how we use your Personal Data. If you ask, we will provide a copy of the Personal Data we hold about you. We can’t give you any Personal Data about other people, Personal Data which is linked to an ongoing criminal or fraud investigation, or Personal Data which is linked to settlement negotiations with you. We also won't provide you with any communication we've had with our legal advisers.
You can ask us to correct your Personal Data if you think it's wrong. You can have incomplete or inaccurate Personal Data corrected. Before we update your file, we may need to check the accuracy of the new Personal Data you have provided.
You can object to us processing your Personal Data for marketing purposes.
You can ask us to delete your Personal Data if:
there's no good reason for us to continue using it;
you gave us consent (permission) to use your Personal Data and you have now withdrawn that consent;
you have objected to us using your Personal Data;
we have used your Personal Data unlawfully; or
the law requires us to delete your Personal Data.
However, please note that we may not be able to agree to your request. As a regulated financial services provider, we must keep certain customer Personal Data even where you ask us to delete it. Please see the section How and Where We Store Your Data for more details. If you've closed your Account, we may not be able to delete your entire file because these regulatory responsibilities take priority. We will always let you know if we can't delete your Personal Data.
You can object to us processing other Personal Data (if we are using it for legitimate interests). If our legal basis for using your Personal Data is 'legitimate interests' and you disagree with us using it, you can object. However, if there is an overriding reason why we need to use your Personal Data, we will not accept your request. If you object to us using Personal Data which we need in order to provide our services, we may need to close your Account as we won’t be able to provide the Services.
You can ask us to restrict how we use your Personal Data.
You can ask us to suspend using your Personal Data if:
you want us to investigate whether it is accurate;
our use of your Personal Data is unlawful but you do not want us to delete it;
we no longer need your Personal Data, but you want us to continue holding it for you in connection with a legal claim; or
you have objected to us using your Personal Data (see above), but we need to check whether we have an overriding reason to use it.
You can ask us to transfer Personal Data to you or another company. If we can, and are allowed to do so under regulatory requirements, we will provide your Personal Data in a structured, commonly used, machine-readable format.
You can withdraw your permission. Note, it will have been lawful for us to use the Personal Data up to the point you withdrew your permission.
You can ask us to carry out a human review of an automated decision we make about you. If we make an automated decision about you that significantly affects you, you can ask us to carry out a manual review of this decision.
Contact
We welcome your comments, requests and questions regarding our Privacy Policy at [email protected]