Privacy Notice
Draft for review. Items in square brackets must be confirmed before this notice is published, and the whole notice should be reviewed by SAQR's legal counsel. Remove this box when it is final.
1. Who we are
This notice explains how SAQR Advisors FZC ("SAQR", "we", "us") handles personal information about people who visit this website or contact us through it, including investors, founders and their representatives.
SAQR Advisors FZC is a company registered in the Sharjah Airport International Free Zone (SAIF Zone), United Arab Emirates, under licence numbers 19266 and 19267, with its registered office at SAIF Desk R3-23/C, SAIF Zone Offices, P.O. Box 513604, Sharjah, UAE. We are responsible for your personal information as its controller.
You can contact us about this notice or your information at contact@saqradvisors.com.
We handle personal information in line with the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and, where they apply to you, the EU General Data Protection Regulation and the UK GDPR. [Counsel to confirm that no free-zone-specific data protection regime applies in SAIF Zone.]
Our representative in the EU and the UK
SAQR is based outside the European Union and the United Kingdom but offers its services to people there. We have therefore appointed RegReps as our representative under Article 27 of the EU GDPR and Article 27 of the UK GDPR. You can contact RegReps about anything in this notice, or with any request about your personal information, and they will pass it to us. You can also contact us directly.
- In the EU: RegReps, St Galls House, St Gall Gardens South, Milltown, Dublin D14 Y882, Ireland. Telephone +353 (0)1 669 4774.
- In the UK: RegReps, Kemp House, 152–160 City Road, London EC1V 2NX, United Kingdom. Telephone +44 (0)20 7566 3939.
- Email (EU and UK): saqr@regreps.com
[Counsel to confirm: RegReps' registered legal name and company number for each jurisdiction, and the UK representative arrangement, before publication.]
2. What we collect
Information you give us
When you send an enquiry, we collect what you enter in the form:
- your name, email address, organisation and role;
- whether you are contacting us as an investor, a founder or otherwise;
- for investors, your investor type and sectors of interest, if you choose to give them;
- for founders, your company's stage and a website or deck link, if you choose to give them;
- your message, and whether you would like to meet at an event.
Please do not send us confidential or sensitive information through the form. If a conversation progresses, we may ask for further information, for example to verify identity or eligibility. That information is covered by this notice and by any separate terms we agree with you.
Information collected automatically
Our hosting provider records technical information when you visit the site, such as your IP address, browser type, the pages requested and the time of the request. This is used to operate and secure the site. We do not use advertising or analytics cookies, and we do not track you across other websites.
3. How and why we use it
| Purpose | Legal basis |
|---|---|
| Responding to your enquiry and arranging meetings, including at events | Our legitimate interest in responding to people who contact us; or taking steps at your request before entering into an agreement with you |
| Assessing whether an opportunity or an investor mandate is a fit, and making introductions you have agreed to | Our legitimate interest in running our business; your consent where we introduce you to a third party |
| Keeping a record of our relationship with you | Our legitimate interest in managing our business relationships |
| Operating and securing the website, including preventing abuse of the form | Our legitimate interest in keeping the site secure and available |
| Meeting legal and regulatory obligations, such as identity and anti-money-laundering checks before any investment | Compliance with a legal obligation |
| Establishing, exercising or defending legal claims | Our legitimate interest; compliance with a legal obligation |
We do not sell your personal information, use it for automated decision-making that has legal or similarly significant effects on you, or send you marketing without your agreement.
4. Who we share it with
We share personal information only where needed for the purposes above:
- Service providers who process it on our behalf and under our instructions:
- website hosting: Vercel Inc. (United States); the enquiry form is processed in the European Union;
- email delivery of enquiries: Resend, Inc. (United States);
- our email service: [mailbox provider];
- client relationship management: Sovy Trust Solutions Limited (Ireland), with data stored in the European Union. [Confirm once enquiry management goes live.]
- Investors or companies we introduce you to, only with your agreement and only the information needed for the introduction.
- Professional advisers, such as lawyers, auditors and accountants, under a duty of confidentiality.
- Authorities, where the law requires it.
5. International transfers
Our service providers may process your information outside the country you are in, including in the European Union and the United States. Where the law requires it, we put safeguards in place, such as standard contractual clauses, or rely on adequacy decisions or other lawful transfer mechanisms. You can ask us for more information about these safeguards.
6. How long we keep it
If an enquiry does not lead to an ongoing relationship, we delete it [24 months] after our last contact with you. If it does, we keep the relevant records for the duration of the relationship and afterwards for as long as the law requires, for example [x years] for records relating to investments and identity checks. Hosting logs are kept for a short period under our hosting provider's standard retention. [Confirm retention periods.]
7. Security
We use appropriate technical and organisational measures to protect personal information, including encryption in transit, access restricted to people who need it, and contracts with our service providers that require them to protect it. No system is completely secure. Please contact us at once if you believe your information has been put at risk.
8. Your rights
Depending on the law that applies to you, you may have the right to:
- access the personal information we hold about you;
- have inaccurate information corrected;
- have your information erased;
- restrict or object to how we use it, including where we rely on legitimate interests;
- receive your information in a portable format;
- withdraw consent at any time, where we rely on consent.
To exercise any of these rights, email contact@saqradvisors.com. If you are in the EU or the UK, you can also contact our representative, RegReps, at saqr@regreps.com. We may need to verify your identity, and we will respond within the time the law requires.
You also have the right to complain to a data protection authority. In the UAE, this is the UAE Data Office. [Counsel to confirm.] If you are in the European Union or the United Kingdom, you can complain to the supervisory authority where you live or work. We would appreciate the chance to resolve your concern first.
9. Cookies and analytics
This website does not set cookies and does not use analytics or advertising tools. Fonts and all other files are served from our own site, so visiting it does not send your information to third-party content providers.
10. Changes and contact
We may update this notice from time to time. The date at the top shows when it last changed. If we make significant changes, we will make that clear on this page.
Questions or requests: contact@saqradvisors.com, or write to SAQR Advisors FZC, SAIF Desk R3-23/C, SAIF Zone Offices, P.O. Box 513604, Sharjah, UAE. In the EU or the UK you may also contact our representative, RegReps, at saqr@regreps.com or at the addresses in section 1.