PRIVACY STATEMENT AND POLICY

This privacy statement and policy is by Kinanis Tax Consultancy Middle East Limited, with DIFC Commercial Licence No. CL9974 of Innovation One, Dubai International Financial Centre, Dubai, United Arab Emirates (collectively, “Kinanis”, “we”, “us”, “our”). This privacy statement and policy is given in accordance with the applicable data protection laws and regulations including the DIFC Data
Protection Law, as may be amended from time to time.

We collect, use and process your personal data information which have been provided or shall be provided in the future by you or by third parties acting as your agents, associates, employees or representatives (with or without your express consent) or in any other capacity or that have been extracted from the operation of your account or during any other services provided by us, for purposes relevant to our cooperation and the provision of services offered by us, including but not limited to services for which you retain us to provide, enquiring about our services (including conflict checks) etc. The collection and processing of such personal data is necessary for compliance of Kinanis with its legal obligations under any applicable laws as well as guidelines issued by the relevant regulator in relation to the activities of Kinanis. We note that we may process your personal data for more than one
lawful basis depending on the specific purpose for which we are using your data.

Recipients of your data and confidentiality

Any information regarding yourself shall be kept confidential by us in the course of our cooperation and any such information shall not be disclosed or made known to third parties other than the employees and/or the associates and/or the agents of Kinanis which may be situated outside of the UAE and engaged by Kinanis as may be required and/or deemed necessary for the provision of services by us. We may be obliged to disclose your personal data if this is required and we are ordered to do so by a Court of law or any regulatory body or law enforcement agency or to any such person to whom such information may have to be given in any part of the world pursuant to any applicable laws or regulations.

For the purposes of the applicable data protection law, Kinanis is typically the “data controller” of any personal information provided to us. Specifically, your data will be controlled by Kinanis, who you have instructed, or that is providing services to or communicating with you. Very occasionally, we will act as a “processor” (meaning that we process personal data only in accordance with the directions of a data controller, or as otherwise permitted by applicable law).

Storage of Personal Data

Your personal data shall be safely and securely retained for a period of time only as we are engaged to provide services to you. We may retain your data for a longer period if we consider this necessary in order to comply with the applicable laws. We take reasonable measures to protect your personal data from unauthorized access or misuse; however, we cannot guarantee or warrant its security, as the transmission of data through the internet is
never absolutely secure.

What we shall do with your Personal Data

Your personal data shall be collected, recorded, organized and stored electronically and manually in our records, as well as transferred to third countries within or outside the UAE, as may be required and/or deemed necessary within the course of provision of services by us. Such third countries may not be subject to an adequate level of protection from an international perspective. To address this, Kinanis has put in place appropriate procedures and safeguards to ensure the protection of your personal data.

Your Rights:

1. Right of access: you have the right of access and modification of your data;  

2. Right of rectifications and erasure: you have the right to request the rectification of
your data in case these are inaccurate as well as the right to request the erasure of
such personal data (the right to be forgotten);

3. Right to object to or restrict the processing of personal data;

4. Right to data portability: you have the right to receive the personal data collected
from Kinanis in a structured, commonly used and machine-readable format as well as
the right to request the transmission of those data to another controller;

5. The right to object to automated decision-making, including profiling: you have
the right not to be subject to a decision based solely on automated processing,
including profiling, which produces legal effects concerning you or similarly
significantly affects you;

6. The right to lodge a complaint with a supervisory authority: you have the right to
submit a complaint with the relevant data protection authority (e.g., the
Commissioner of Data Protection in the case of the DIFC).

7. The right to withdraw your consent: where the processing is based on your
consent, you shall have the right to withdraw your consent at any time by contacting
us at dataprotection@kinanis.com If you withdraw your consent for your personal
data to be used for the above-mentioned purposes, we will process your request for
such withdraw of consent and will thereafter cease to use and/or disclose your
personal data and proceed with the erasure of your personal data within 30 (thirty)
calendar days, unless this personal data information is necessary for complying with
other legal obligations under the applicable law.

Your rights may be discussed with and/or exercised by contacting our appointed data
protection officer who is the person responsible to address any issues related to personal data at dataprotection@kinanis.com , telephone number: +971 5 6576 1818.

Contact Details:

Kinanis Tax Consultancy Middle East Limited, Innovation One, Dubai International Financial

Centre, Dubai, United Arab Emirates
Email: uae@kinanis.com, dataprotection@kinanis.com
Telephone: +971 5 6576 1818

We reserve the right to amend this privacy statement and policy from time to time.

Kinanis Tax Consultancy Middle East Limited (“the Firm”), is a company registered in the UAE and licensed by the DIFC to provide transfer pricing, related tax compliance and advisory services in the region.

The Firm belongs to the same group of companies with Kinanis LLC, Law Firm of Cyprus, which has been consulting international and local clients and offering consulting services since 1983. The firm, T.P. Alfa Services Limited of Cyprus, is also a company belonging to the group, specializing in Transfer Pricing. The group consists of more than 65 lawyers, accountants, tax consultants and other professionals.

The group has gradually evolved over the years, starting as a traditional Law Firm and
transforming into an innovative, pioneering firm that combines exceptional expertise in corporate and tax, litigation, VAT, accounting, transfer pricing, financial services,
employment, migration, company liquidation, and technology.

The group provides to its clients' businesses full support on a daily basis, as well as tailored solutions, always compatible with the latest global challenges and technological developments.

The group has as its vision and pride to become part of their clients’ story, having as flag, the motto…Being part of your story is our pride