Privacy Policy


Privacy Policy of Farringdon Capital Ltd

Effective date: 23 July 2026 | Version 1



Farringdon Capital Ltd (“Farringdon”, “we”, “us” or “our”) is incorporated in and regulated within the Dubai International Financial Centre (DIFC) and is regulated by the Dubai Financial Services Authority (DFSA). This Privacy Policy explains how we collect, use, disclose and protect Personal Data when you visit www.farringdon.ae (the “Site”) or otherwise interact with us, and explains your rights in relation to that data.



This Policy is issued in accordance with the DIFC Data Protection Law No. 5 of 2020, as amended by DIFC Laws Amendment Law No. 1 of 2025 (the “Data Protection Law”). Terms such as Controller, Processor, Data Subject and Personal Data Breach have the meanings given to them in the Data Protection Law.



1. Scope of this Policy

This Policy applies to Farringdon as a Controller incorporated in the DIFC, regardless of where our processing of Personal Data takes place, and to any processing of Personal Data we carry out within the DIFC, in each case in line with the extraterritorial scope confirmed by the 2025 amendment to the Data Protection Law.



2. Information We Collect

We may collect the following categories of Personal Data:

  • Identity and contact information you provide to us, such as your name, email address, phone number and postal address, for example when you contact us or subscribe to updates.
  • Log Data collected automatically when you visit the Site, including your IP address, browser type and version, the pages you visit, and the date, time and duration of your visit.
  • Information collected via cookies and similar technologies (see Section 5 below).

We do not knowingly collect more Personal Data than is necessary for the purposes described in this Policy.



3. How We Use Your Information

We use Personal Data to:

  • Operate, maintain and improve the Site and respond to your enquiries;
  • Provide information about our services where you have requested this;
  • Meet our legal, regulatory and risk-management obligations, including obligations under DFSA and DIFC rules; and
  • Detect, investigate and prevent fraud, unauthorised activity or security incidents.



4. Legal Basis for Processing

Where required under the Data Protection Law, we process Personal Data on one or more of the following bases: your consent (which you may withdraw at any time, as set out in Section 8); where processing is necessary to respond to your request or provide a service to you; where processing is necessary to comply with a legal or regulatory obligation to which we are subject; and where processing is necessary for our legitimate business interests, provided these are not overridden by your rights.



5. Cookies

Cookies are small data files stored on your device that help us recognise your browser and improve your experience of the Site. Where required, we will request your consent before placing non-essential cookies, and you can manage or withdraw that consent at any time through your browser settings or, where available, our cookie preference tool. Refusing cookies may limit some functionality of the Site.



6. How We Share Your Information

We do not sell Personal Data. We may share Personal Data, on a need-to-know basis and under appropriate contractual safeguards, with:

  • Service providers who perform functions on our behalf (for example, IT hosting or professional advisers), who are contractually obliged to protect your data and use it only for the purpose instructed;
  • Other entities within the Farringdon group, only where necessary for the purposes described in this Policy; and
  • Regulators, law enforcement or courts, where we are legally required to do so or where necessary to establish, exercise or defend legal claims. Before sharing Personal Data with a public authority, we take reasonable steps to verify the legitimacy and proportionality of the request and document the legal basis relied upon.



6 A. Use of Artificial Intelligence (AI)

We may use artificial intelligence (“AI”) tools to support certain internal administrative, operational and business functions, including document preparation, data organisation, summarisation, quality assurance and workflow management. Where these tools process Personal Data, they do so under appropriate contractual and security safeguards and in accordance with applicable data protection laws. AI is used to assist our personnel and is subject to appropriate human oversight. We do not use AI to make solely automated decisions that produce legal or similarly significant effects on individuals.



7. International Transfers

If Personal Data is transferred outside the UAE, we will only transfer it to jurisdictions that provide an equivalent or higher standard of data protection, or where appropriate safeguards (such as approved contractual clauses) are in place.



8. Your Rights

Subject to applicable law, you have the right to: request access to the Personal Data we hold about you; request correction of inaccurate data; request erasure or restriction of processing in certain circumstances; object to processing based on legitimate interests; withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal; and lodge a complaint with the DIFC Commissioner of Data Protection. Following the 2025 amendment to the Data Protection Law, you also have the right to bring a claim before the DIFC Courts for compensation, including financial loss and distress, arising from a breach of the Data Protection Law.



9. Data Retention

We retain Personal Data only for as long as necessary to fulfil the purposes described in this Policy, including to satisfy legal, regulatory, accounting or reporting requirements, after which it is securely deleted or anonymised.



10. Security

We maintain technical and organisational measures designed to protect Personal Data against unauthorised access, loss, misuse or alteration, consistent with our internal Data Protection and Information Security Policy. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.



11. Personal Data Breaches

If a Personal Data Breach occurs that is likely to result in a high risk to your rights, we will notify you and the DIFC Commissioner of Data Protection as required under the Data Protection Law, describing the nature of the breach and the steps we are taking in response.



12. Children’s Privacy

The Site is intended for a business and professional audience and is not directed at children. We do not knowingly collect Personal Data from children. If you believe a child has provided us with Personal Data, please contact us using the details in Section 15 and we will take appropriate steps to delete it.



13. Links to Other Websites

The Site may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites, and we encourage you to review their privacy policies before providing any Personal Data.



14. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices or in applicable law. The “Effective date” at the top of this Policy indicates when it was last revised, and material changes will be notified on this page.



15. Contact Us / Exercising Your Rights

To exercise any of your rights, or if you have questions about this Policy, please contact our Data Protection Officer:

  • Email: dpo@fam-asset.com
  • Post: Farringdon Capital Ltd, Office 204A, 2nd Floor North Tower, Emirates Financial Towers, PO Box 507182, DIFC, Dubai, UAE

We will verify your identity before responding to any request and will aim to respond within one month of receiving it, free of charge.