Please read this Privacy Notice carefully, as it sets out how Lunate Holding RSC Limited and its group of affiliates, including without limitation, Lunate Capital Limited and Lunate Capital LLC, may use your personal information. Our website terms of use explain the terms on which you are allowed to use our website (“our website” or “the website”).

1. DEFINITIONS

1.1 “Customer”, “you” or “your” means an individual who: (a) subscribes for, uses or receives, has used or received, or applies to use or receive Lunate's services; (b) corresponds with Lunate; and/or (c) is a user of our website.

1.2 “Lunate”, “we” or “us” means Lunate Holding RSC Limited and its group of affiliates, including Lunate Capital Limited and Lunate Capital LLC. Any references to “Lunate”, “we” or “us” includes our successors or assigns.

1.3 “Personal information” means information that identifies you personally, for example your name, photograph, account number, e-mail address, payment information, user logs or certain numbers associated with your equipment (for example IP address), or other data that can be linked with such information in order to identify you. It does not include truly anonymized information.

2. WHAT TYPE OF PERSONAL INFORMATION DOES LUNATE COLLECT?

2.1 Once you submit or upload information through our website, we will know who you are and your activities on this website and information about you and/or your company may be recorded on our systems. For example, we may ask for the following types of Personal Information when you complete an online form on our website.

  • name;
  • phone number;
  • e-mail address;
  • postal address;
  • company name;
  • country where you are based;
  • client relationship data (e.g. products held and services rendered), securities and payment transaction data and other financial information;
  • information we collect or generate to comply with our obligations under the anti-money laundering regulatory framework (e.g. information on origin of assets or beneficial ownership);
  • information we collect or generate for risk management purposes such as client due diligence data (including periodic review results), client risk profiles, data to assess suitability/appropriateness, client qualifications data, screening alerts, tax data or complaint information;
  • marketing and sales information (e.g. newsletters, documents received, invitations to and participation at events, personal preferences and interests, opt-in and opt-out declarations); and
  • your comments/questions.

2.2 We may also collect Personal Information from you at trade shows/events, from telephone calls and/or other correspondence with you.

2.3 As part of Lunate’s recruitment process, we may also collect the following Personal Information from applicants for the review and evaluation of their applications:

  • contact information (name, email address and phone number(s));
  • nationality;
  • age;
  • academic and professional qualifications;
  • experience certificates or reference letters;
  • resume/CV documents that support a job application;
  • employment history;
  • remuneration and benefits package; and
  • dependents and beneficiary information.
3. COLLECTION AND USE OF ANONYMOUS WEB INFORMATION THROUGH THE USE OF COOKIES

During your interaction with our website, Lunate may use a browser feature called a 'cookie' to collect information anonymously and track your patterns on our website. For more information in relation to the information we collect and how we employ cookies, see our Cookies Policy.

4. HOW DOES LUNATE USE YOUR PERSONAL INFORMATION?

4.1 We use your Personal Information for various reasons. The main reason we use your Personal Information is to provide you with our website and information about us. We also use your Personal Information for:

  • internal record keeping;
  • developing our website;
  • answering your queries or complaints;  
  • market research;
  • establishing and maintaining a responsible commercial and legal relationship with you;
  • providing you with our products and/or services;
  • providing you with information about developments and updates in our products and/or services; and
  • meeting our legal and regulatory requirements.
5. ON WHAT BASIS DOES LUNATE PROCESS YOUR PERSONAL INFORMATION?

5.1 Lunate uses and processes your Personal Information on the following lawful bases:

  • For a legitimate purpose: Where it is relevant and necessary for our legitimate interests, including: (a) ensuring compliance with applicable laws; (b) preventing loss and misuse of our proprietary materials; (c) maintaining the security of our website; or (d) detecting unauthorised, excessive or inappropriate use of our website.
  • Where we have your consent: With your consent for a specific purpose, including responding to queries you have raised, and to send you updates and information that you have requested. You may withdraw your consent at any time, as detailed in Sections 6.2 and 13.1 of this Privacy Notice.
  • To provide a requested service or product, or to carry out a contract with you: Where processing is necessary for the performance of a contract, such as to provide you with our products and/or services.
  • Where we have a legal obligation: In order to comply with our legal and regulatory obligations, including responding to requests from supervisory or regulatory authorities and law enforcement agencies. 

5.2 Lunate will process your Personal Information in accordance with applicable laws and regulations and with the use of appropriate security measures.

6. HOW DOES LUNATE OBTAIN YOUR CONSENT?

6.1 Sometimes Lunate may request your consent before processing your Personal Information. If so, the form of consent sought by Lunate may vary, depending upon the circumstances and the type of Personal Information to be processed by Lunate. In determining the form of consent to be obtained from you, Lunate will consider the sensitivity of the relevant Personal Information and your reasonable expectations, so that you understand the nature, purpose and consequences of the collection, use and/or disclosure of your Personal Information. Lunate will always seek express consent when the Personal Information is likely to be considered ‘sensitive’ or ‘special’ in nature.

6.2 You may withdraw your consent at any time, although if you do so, it does not mean that anything we have done with your Personal Information with your consent up to that point is unlawful and we may be able to continue to process your Personal Information to the extent required or permitted by law, including in order to comply with our legal or regulatory obligations. This includes your right to withdraw consent to us using your personal information for marketing purposes. If you wish to withdraw your consent to certain collection, retention, use or disclosure of personal information, please contact us using the website contact form.
 

7. DO WE CARRY OUT AUTOMATED DECISION MAKING?

No, Lunate does not carry out automated decision making when processing your Personal Information.

8. WHAT HAPPENS IF YOU DO NOT PROVIDE US WITH THE PERSONAL INFORMATION WE REQUEST OR ASK THAT WE STOP PROCESSING YOUR PERSONAL INFORMATION?

If you do not provide the necessary Personal Information, or you refuse or withdraw your consent at any time for the processing of your Personal Information, we may be unable to provide certain services, products or information to you, and you may not be able to make use of certain products, services and information offered by us.

9. WHO DOES LUNATE SHARE PERSONAL INFORMATION WITH?

9.1 We share your Personal Information with trusted third parties where we have retained them to perform functions on our behalf and who also provide services to us, such as professional advisors, IT consultants carrying out testing and development work on our business technology systems, research and mailing houses and function coordinators and, to the extent necessary in connection with our products and services, sub-processors, suppliers and subcontractors. We may also share your Personal Information with third parties who provide products and/or services that you have requested. These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.

9.2 We may also share your Personal Information with our other group companies for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us, your Personal Information may be disclosed to such entity. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible it will be sold or transferred to third parties.

9.3 Where required, we may share your Personal Information with other third parties, including: (a) to comply with a legal or regulatory obligation; (b) when we believe in good faith that an applicable law requires it; (c) with governmental, public or regulatory authorities and institutions (e.g. the ADGM Financial Services Regulatory Authority, the Securities and Commodities Authority, or other financial authorities, tax authorities, criminal prosecution authorities or courts) insofar as a statutory or regulatory obligation exists; (d) with auditors or dispute resolution bodies; (e) other financial services institutions, credit institutions and comparable institutions for the purposes of providing our services and/or products to you; (f) to verify or enforce our applicable policies; (g) to detect and protect against fraud, or any technical or security vulnerabilities; (h) to respond to an emergency; or (i) otherwise to protect the rights, property, safety, or security of third parties, visitors to our website, our business or the public.
 

10. WILL YOUR PERSONAL INFORMATION BE TRANSFERRED TO ANOTHER JURISDICTION?

Your Personal Information may be processed by Lunate, its group companies and the third parties described above, outside of the country in which you are based. Where the data protection regulator in your home country has not issued an adequacy decision in relation to the jurisdiction where your Personal Information is to be processed, we will ensure that there are adequate mechanisms in place to protect your Personal Information in accordance with applicable data protection and privacy laws, including, where applicable, through use of data transfer agreements implementing standard data protection clauses. Lunate shall transfer data in accordance with applicable laws and regulations and shall employ appropriate security measures for the transfer of data, which are technically and reasonably possible. You can receive further information about the data transfer agreements that concern your Personal Information, and the mechanisms we implement to protect your Personal Information, by using the contact form set out below.

11. HOW DOES LUNATE SAFEGUARD YOUR PERSONAL INFORMATION?

We use various technical and organizational methods to help protect and safeguard your Personal Information. The nature of the safeguards we implement varies depending on the nature and sensitivity of the Personal Information, the scope of the Personal Information, whether that Personal Information will be transferred outside of the country in which you are based and the method of storage of that information. More sensitive types of Personal Information will be safeguarded by a higher level of protection, such as encryption. If you would like more information about the safeguards we have in place, please contact us by using the contact form set out below.

12. HOW LONG DOES LUNATE RETAIN YOUR PERSONAL INFORMATION?

12.1 Personal Information collected by Lunate will be retained for such periods as necessary to fulfil the purposes set out in this Privacy Notice, or for longer periods in accordance with applicable data protection laws. Otherwise, we will only keep your personal information for no more than six years thereafter.

12.2 We will irretrievably delete your Personal Information upon the expiry of the applicable retention period described in Section 12.1 above.

13. WHAT ARE YOUR RIGHTS?

13.1 By law you have a number of rights when it comes to your Personal Information, as further detailed below. Further information and advice about your rights can be obtained by the data protection regulator in your country.

  • The right to object to processing: You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
  • The right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Information and your rights. This is why we are providing you with the information set out in this Privacy Notice.
  • The right of access: You have the right to obtain access to your Personal Information (if we are processing it), and certain other information (similar to that provided in this Privacy Notice). This is so you are aware and can check that we are using your Personal Information in accordance with data protection law.
  • The right to rectification: You are entitled to have your Personal Information corrected if it’s inaccurate or incomplete.
  • The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your Personal Information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
  • The right to restrict processing: You have rights to ‘block’ or suppress further use of your Personal Information. When processing is restricted, we can still store your Personal Information, but may not use it further. We keep lists of people who have asked for further use of their Personal Information to be ‘blocked’ to make sure the restriction is respected in future.
  • The right to data portability: You have rights to obtain and reuse your Personal Information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your Personal Information easily between our IT systems and theirs safely and securely, without affecting its usability.
  • The right to lodge a complaint: You have the right to lodge a complaint about the way we handle or process your Personal Information with your national data protection regulator.

13.2 You may exercise any of the above rights by submitting a request using the contact form below.

13.3 Lunate will usually act on requests and provide information free of charge, but may: (a) charge a reasonable fee to cover administrative costs for providing information; or (b) refuse to act on request in respect of:

  • unreasonable or excessive or repeated requests; or
  • requests for further copies of the same information. 
     

13.4 Lunate will respond to requests as soon as it can, which will generally be within one month from our receipt of your request. Lunate will inform you if we expect that our response to your request will exceed this period.

13.5 In certain circumstances and in accordance with applicable data protection laws, Lunate may not be able to provide you with access to all your Personal Information it holds, for example, if the Personal Information in question relates to information to be disclosed by applicable law (including by court order) or in connection with legal proceedings, obtaining legal advice or establishing, exercising or defending legal rights, or relates to information in respect of which a claim to legal professional privilege could be maintained in legal proceedings or in respect of which a duty of confidentiality is owed by a legal professional advisor is owed to its client.

14. HOW CAN I MAKE COMPLAINTS OR ASK QUESTIONS?

14.1 You may direct any questions or inquiries with respect to the privacy principles outlined above or about Lunate’s privacy practices described in this Privacy Notice using the contact form on our website.

14.2 Lunate will investigate all complaints and respond to all questions asked by you. If a complaint is found to be justified, Lunate will take appropriate measures to resolve the complaint, which may include amending its policies and procedures.

15. YOUR ROLE IN PROTECTING YOUR PERSONAL INFORMATION

Please remember that this Privacy Notice and our use of your Personal Information only applies to the Personal Information you provide directly to Lunate, by accessing and using our website and receiving our products or services. Our website or marketing email messages sometimes include links to other websites which are not within our control. Once you have left our website/marketing email message, we cannot be held responsible for the content of other websites or the protection and privacy of any information which you provide to those websites. You should exercise caution and look at the privacy statement applicable to the website in question.

16. UPDATING THIS PRIVACY NOTICE

Lunate will update this Privacy Notice from time to time to reflect the changes in our practices, business needs, how we use your Personal Information and in order to comply with applicable laws and regulatory requirements. Where we do make any changes to this Privacy Notice, we will let you know. You may determine when this Privacy Notice was last updated by referring to the date found at the end of this Privacy Notice.

17. CONTACT

17.1 We may contact you by phone or email, based on the information you provide us with.

17.2 If you have any enquiries about the processing of your Personal Information, please contact us through our website contact form.