Privacy Policy

1. Data We Collect

We collect the following categories of personal information:

• Identity Data: Full name, date of birth, passport or national ID number, nationality.
• Contact Data: Email address, telephone number, residential and billing address.
• Financial Data: Bank account details, investment history, portfolio data, transaction records.
• KYC / AML Data: Source of funds documentation, employment information, politically exposed person (PEP) status.
• Technical Data: IP address, browser type, device identifiers, cookies, session data, login timestamps.
• Usage Data: Pages visited, features used, time on platform, click-through data.
• Communications: Records of correspondence, support tickets, phone call recordings (where applicable).

2. How We Use Your Data

We process your personal data under the following lawful bases:

• Contract performance: Account creation, investment execution, reporting, and client services.
• Legal obligation: AML/CFT compliance, DFSA regulatory reporting, tax obligations, fraud prevention.
• Legitimate interests: Platform security, analytics, service improvement, risk management.
• Consent: Marketing communications (you may opt out at any time).

3. Data Sharing

We do not sell your personal data. We may share it with:

• Regulatory bodies: DFSA, UAE Central Bank, CBUAE, Financial Intelligence Unit (FIU)
• Service providers: Custodians, payment processors, KYC providers, cloud infrastructure
• Professional advisors: Auditors, legal counsel, tax advisors under strict confidentiality
• Law enforcement: Where legally required or to protect rights and safety

All third-party processors are contractually bound to data protection standards at least as stringent as our own.

4. Security Measures

Sadaindex employs industry-leading security controls including:

• 256-bit AES encryption for data at rest; TLS 1.3 for data in transit
• ISO 27001 certified information security management
• Multi-factor authentication (MFA) on all accounts
• Penetration testing conducted quarterly by independent security firms
• 24/7 Security Operations Centre (SOC) monitoring
• Segregated client fund accounts held with regulated custodians

5. Cookies Policy

We use the following categories of cookies:

• Essential: Required for platform functionality and security. Cannot be disabled.
• Performance: Analytics to understand platform usage (Google Analytics, anonymised).
• Functional: Remember your preferences and personalise your experience.
• Marketing: Only with your explicit consent; used for relevant investment communications.

6. Your Rights

Under DIFC Data Protection Law, you have the right to:

• Access a copy of your personal data we hold
• Rectification of inaccurate or incomplete data
• Erasure ("right to be forgotten") where legally permissible
• Restrict or object to processing in certain circumstances
• Data portability in a machine-readable format
• Withdraw consent at any time without affecting prior processing

To exercise any right, contact our Data Protection Officer at dpo@Sadaindex.com. We will respond within 30 days.

7. Data Retention

We retain personal data for as long as necessary to fulfil the purposes outlined above, and in accordance with applicable law. Investment and KYC records are retained for a minimum of 8 years after the end of the client relationship, as required by DFSA and DIFC regulations. Technical and usage data is retained for up to 24 months.

8. Contact Us

For privacy inquiries, to exercise your rights, or to file a complaint:

You also have the right to lodge a complaint with the DIFC Commissioner of Data Protection at www.difc.ae.