Privacy policy
This policy describes the personal data that Stratos Private Vault Holding Ltd processes, the purposes for which it is processed, and the rights of the persons concerned.
1. Controller
Stratos Private Vault Holding Ltd, a Private Company Limited by Shares registered in the Abu Dhabi Global Market (ADGM), United Arab Emirates (number 39697), acts as data controller for the personal data it processes in connection with this website and with engagements with counterparties.
2. Legal framework
We process personal data in accordance with applicable law, including UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (the “PDPL”) and its implementing regulations, applicable ADGM data-protection rules, and — where relevant — the EU General Data Protection Regulation (GDPR) for individuals located in the European Economic Area.
3. Personal data we collect
Identification data (name, professional title, employer, professional contact details); eligibility data (information needed to determine your classification as a professional, institutional or qualified counterparty); KYC and source-of-wealth data (identity documents, residence, ownership and control, source-of-wealth and source-of-funds, sanctions and PEP screening results); communication data (information submitted through the enquiry form and correspondence); and technical data (IP address, browser characteristics, language, time of access, pages viewed).
4. Purposes and legal bases
To assess enquiries and determine eligibility (pre-contractual measures, legitimate interest); to perform identity verification, sanctions screening and due diligence (legal obligation under AML/CTF rules); to administer the relationship with admitted counterparties (performance of contract); to communicate with you and respond from a verified address (legitimate interest); to operate and secure this website and prevent fraud (legitimate interest); and to comply with legal and regulatory obligations and defend legal claims (legal obligation).
5. Recipients
Personal data may be shared with our administrators and professional advisers, identity-verification and screening providers, IT and hosting providers acting under contract, and competent authorities where required by law. We do not sell personal data.
6. International transfers
Where data is transferred outside your jurisdiction, we rely on an adequacy decision or appropriate safeguards (such as standard contractual clauses) as required by applicable law.
7. Retention
We retain personal data only as long as necessary for the purposes above and to meet legal, regulatory and record-keeping obligations, after which it is deleted or anonymised.
8. Your rights
Subject to applicable law, you may request access, rectification, erasure, restriction or portability of your personal data, and object to certain processing. To exercise these rights, contact us through the confidential enquiry form.
9. Security
We apply appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure or destruction.
10. Updates & contact
This policy is reviewed periodically and updated as circumstances change. Questions regarding this policy or your personal data should be sent through the confidential enquiry form.