Introduction

This Online Privacy Notice and Cookie Policy ("Policy" or "Privacy Policy") is an external statement for all third-party data subjects describing how Further Ventures Limited ("FVL", "we", "us", "our”) collect, use, retain, protect and disclose personal data of users of our websites ("Site"). It also describes the rights that the You as the user of the Site ("you", "You" "Your") has over Your Personal Data and how they may exercise those rights.

Who we are/ Who is the Controller?

FVL is an incorporated in Abu Dhabi as a venture fund manager regulated by the FSRA of the Abu Dhabi Global Market. FVL is the Controller. 

What information do we collect?

When You visit the Site we collect Your Personal Information such as: 

• Profile or Contact Data such as First and last name, Email, Phone number, Company name, Title etc 
• Device/IP Data such as IP address, Device ID, Domain server, Type of device/operating system/browser used to access the Site
• Web Analytics such as IP address, Device ID, Domain server, Type of device/operating system/browser used to access the Site
• Other Identifying Information that You voluntarily choose to provide

How do we use personal information?

We use the Personal Information for:

• personalisation of content, business information or user experience
• account set up and administration
• delivering marketing and events communication
• carrying out polls and surveys
• internal research and development purposes
• providing goods and services
• legal obligations (eg prevention of fraud)
• meeting internal audit requirements

What legal basis do we have for processing Your personal data?

FVL processes data because it is necessary:

• for the performance of contracts; or
• for compliance with any legal obligation to which it is subject; or
• for the purposes of the legitimate interests pursued by FVL or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of the data subject; or
• for the purpose of performance of a task carried out by a public authority in the interest of ADGM, or in the exercise of its functions by ADGM, FSRA, ADGM Court, Registration Authority or official authority vested with FVL under applicable law.

When do we share personal data?

We generally do not share information collected about You through the Site.

We may, however, share Your information (i) with third parties who provide services to us (such as hosting, technology and communication providers and analytics providers), (ii) as required by law and when we believe in good faith that disclosure is necessary to protect our rights or those of third parties, protect Your safety or the safety of others, investigate fraud, or comply with a court order or other legal process, (iii) among our affiliates for our business purposes in accordance with this Privacy Policy, or (iv) in connection with a corporate change or dissolution, including a merger, acquisition, sale of assets, reorganization, consolidation, bankruptcy, liquidation or wind down of business.

In addition, We may share non-personally identifiable Site usage information (including aggregated and de-identified data) with others, for their own use, in a form that does not include Your name or contact information. The third parties that support our website analytics tools may be able to access and use Your Site usage information.

Where do we store and process personal data?

You agree that we have the right to transfer the Personal Data described in this privacy policy to and from, and process and store it in, the United Arab Emirates and other countries, some of which may have less protective data protection laws than the region in which You reside. Where this is the case, we will take appropriate measures to protect your Personal Data in accordance with this privacy policy. By submitting Your Personal Data, You agree to such transfer, storing or processing. We will take all steps reasonably necessary to ensure Your Personal Data is treated securely and in accordance with this privacy policy.

Cookies

Our Website uses cookies to distinguish You from other users of our Website. This helps us to provide You with a good experience when You browse our Website and also allows us to improve our Website and the Services we provide. By accessing and browsing our website, You are agreeing to our use of cookies.

Reporting a data breach

In the event of a data breach there may be an obligation on FVL to report such a breach to the ADGM Commissioner of Data Protection and/or any individuals affected by the breach. Please refer to the Data Protection Officer for further details.

Direct marketing

We generally will not use Your Personal Data for direct marketing. In rare circumstances We use personal information for direct marketing purposes, We will make sure that those who receive our marketing information have given prior consent which will be clearly communicated and require a clear affirmative ‘opt-in’ and have the opportunity to ‘opt-out’ of marketing. We will support the following conditions:

• individuals can opt-out at any time.
• opting out is as easy as opting in; and
• there is no charge for opting out.

Your Rights under ADGM Rules and EU GDPR 

Under ADGM rules, and where applicable under EU GDPR rules, You have the following rights such as 

• Right to be informed purpose of collecting Your personal information
• Right to access Your Personal Information 
• Right to object to processing Your Information 
• Right to be forgotten
• Right to rectification
• Right to data portability
• Right to file a complaint

Further information is also available from the ADGM website: https://www.adgm.com/operating-in-adgm/office-of-data-protection/for-individuals. 

To exercise these rights, You can also contact us at compliance@further.ae to exercise these rights and we will respond within 45 days. 

Privacy Rights of California Residents.

If You are a resident of California, You have the rights set forth in this section. If there are any conflicts between this section and any other provision of this Privacy Policy, the portion that is more protective of Personal Information shall control to the extent of such conflict. If You have any questions about this section or whether any of the following rights apply to You, please contact us at compliance@further.ae.

Access

You have the right to request certain information about our collection and use of Your Personal Information over the past 12 months, including the:

• Categories of Personal Information that we have collected about You.
• Specific pieces of Personal Information that we have collected about You.
• Categories of sources from which that Personal Information was collected.
• Business or commercial purpose for collecting Your Personal Information.
• Categories of third parties with whom we have shared Your Personal Information.

Categories of Personal Information shared with third parties for a business purpose over the past 12 months, if applicable.

Deletion

You have the right to request that we delete the Personal Information that we have collected about You, subject to certain exceptions under the CCPA: for example, we may need to retain your Personal Information to provide you with the Site or complete a transaction or other action You have requested. If your deletion request is subject to one of these exceptions, we may deny Your deletion request.

Exercising Your CCPA Rights

To exercise the rights described above, You must send us a request that (1) provides sufficient information to allow us to verify that You are either the person about whom we have collected Personal Information or are an agent authorized by that person, and (2) describes Your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify Your identity and complete Your request. You may submit a Valid Request pursuant to the following methods:

Email us at: 

Submit a form at this address: compliance@further.ae

c/o DD-16-121-020, 16, Al Khatem Tower, 

Adgm Square, Al Maryah Island, 

Abu Dhabi, United Arab Emirates

Attention: Compliance Team 

We will work to respond to Your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Contact information

FVL promotes transparency in its processing of personal data. If you have any questions about this policy, please email compliance@further.ae.

Defined terms

Controller: the entity which alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this policy, the Controller is FVL.

Personal data: any information relating to an identified or identifiable natural person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal data breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.

Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Special category data: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Third Party: a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Capitalized words not defined above will have the same definition under applicable law.