Privacy Policy

1. Introduction

Five Stones Capital DMCC ("Five Stones Capital," "we," "us," or "our") is committed to protecting the privacy and personal data of individuals who visit our website or engage with our services. This Privacy Policy explains how we collect, use, store, and protect your personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL") and other applicable data protection regulations.

By accessing this website, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller

The data controller responsible for your personal data is Five Stones Capital DMCC, incorporated in the Dubai Multi Commodities Centre (DMCC), United Arab Emirates. For any data protection inquiries, please contact us at [email protected].

3. Information We Collect

We may collect the following categories of personal data:

4. How We Use Your Data

We process your personal data for the following purposes:

• —To operate and maintain our website and ensure its security
• —To analyse website usage and improve our online presence
• —To respond to your inquiries and communications
• —To comply with legal obligations and regulatory requirements
• —To protect our legitimate interests, including fraud prevention and network security

5. Legal Basis for Processing

We process your personal data on the following legal bases under the PDPL: (a) your consent, where you have provided it; (b) performance of a contract or steps taken at your request prior to entering into a contract; (c) compliance with a legal obligation to which we are subject; and (d) our legitimate interests, provided these are not overridden by your rights and freedoms.

6. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and collect usage data. Cookies are small text files stored on your device that help us understand how visitors interact with our website.

You may manage your cookie preferences at any time through your browser settings or by clearing your browser's stored data.

7. Data Sharing and Transfers

We do not sell, rent, or trade your personal data. We may share your data with:

• —Service providers who assist in operating our website and analytics, subject to appropriate data processing agreements
• —Professional advisers, including legal and compliance consultants, where necessary
• —Regulatory authorities or law enforcement agencies where required by applicable law

Where personal data is transferred outside the UAE, we ensure appropriate safeguards are in place in accordance with the PDPL.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Technical and usage data collected through cookies is retained for a maximum of 24 months. Communication data is retained for the duration of our business relationship and for a reasonable period thereafter as required by law.

9. Your Rights

Under the UAE PDPL, you have the following rights in relation to your personal data:

• —The right to access your personal data and obtain a copy
• —The right to rectify inaccurate or incomplete data
• —The right to request erasure of your personal data
• —The right to restrict or object to processing
• —The right to withdraw consent at any time, where processing is based on consent
• —The right to lodge a complaint with the UAE Data Office

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

10. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.

12. Contact

For any questions or concerns regarding this Privacy Policy or our data protection practices, please contact: