Last Updated: 10th December 2025

This Privacy Policy explains how Vivat Investment Management (“Vivat”, “we”, “our”, or “us”) collects, uses, stores, and protects your personal information when you engage with our investment management services or visit our website. By using our services, you agree to the practices described in this policy.

1. Who We Are
Vivat Investment Management
Office 206, Level 2, Park Heights Square 1, Dubai Hills
P.O. Box 31750, Dubai – UAE

Contact Details:
Tel: +971 4 430 8767
Fax: +971 4 514 8455

2. Information We Collect
We may collect the following information:
• Personal details such as your name, date of birth, nationality, and identification documents (passport, Emirates ID, etc.)
• Contact details including address, phone number, and email
• Financial information relevant to investment suitability
• Investment preferences and objectives
• Communications, agreements, and documents you share with us
• Website usage data such as IP address, browser type, device information, and cookies

3. How We Use Your Information
Your data may be used for:
• Providing investment advisory and management services
• Fulfilling regulatory requirements including KYC and AML checks
• Communicating with you regarding your account or our services
• Preparing investment reports, assessments, and communications
• Improving website performance and security
• Meeting legal and compliance obligations in the UAE or other applicable jurisdictions

4. Legal Basis for Processing
We process your information based on:
• Performance of a contract
• Compliance with legal or regulatory obligations
• Legitimate business interests
• Your consent, where required

5. Sharing Your Information
We may share your information with:
• Regulatory and governmental authorities
• Third-party service providers (IT systems, compliance partners, auditors, custodians, etc.)
• Legal advisors and consultants
• Affiliates or subsidiaries, if applicable
We do not sell your personal information to third parties.

6. International Transfers
Your personal data may be transferred to countries outside the UAE. We ensure appropriate safeguards are in place to protect your information in accordance with relevant data protection laws.

7. Data Security
We apply administrative, technical, and physical measures to protect your data from unauthorized access, loss, or misuse. However, no method of transmission or storage is completely secure.

8. Data Retention
We retain your information only as long as necessary to:
• Deliver our investment services
• Fulfill contractual obligations
• Comply with legal and regulatory requirements, including AML retention periods

9. Your Rights
Depending on applicable laws, you may have the right to:
• Access your personal data
• Request correction or updates
• Request deletion where legally permissible
• Object to or restrict certain types of processing
• Withdraw consent where processing is based on consent
• Request a copy of your data in a portable format
To exercise your rights, please contact us using the details provided above.

10. Cookies and Tracking Technologies
Our website may use cookies and analytics tools to enhance user experience and website performance. You may disable cookies through your browser settings, though this may affect certain functionalities.

11. Third-Party Websites
Our website may contain links to external websites. We are not responsible for their privacy practices. Please review their policies before providing personal information.

12. Updates to This Policy
We may update this Privacy Policy from time to time. Changes will be posted on our website along with the updated effective date.

13. Contact Us
If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at:

Vivat Investment Management
Office 206, Level 2, Park Heights Square 1, Dubai Hills
P.O. Box 31750, Dubai – UAE

Tel: +971 4 430 8767
Fax: +971 4 514 8455