Our Polices

Samena Capital Investments Ltd respects your privacy and is committed to protecting it. We provide this Privacy Information Notice ("Notice") to inform you of our privacy procedures and practices, including what information we collect about you, how we obtain your information and how we use your information.

For the purposes of this Privacy Policy "we", "our" and "us" refer to Samena Capital Investments Ltd. "Personal data" means any information that Samena processes that relates to identifiable or identified individuals.

Please take a moment to read this Notice so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

We may from time to time update this Notice to ensure it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements.

Principles we adhere to

We will comply with applicable data protection laws, such as the Dubai International Financial Centre ("DIFC") Data Protection Law (DIFC Law No. 5 of 2020), that apply to our processing of your personal data. We will:

process your personal data in a lawful, fair, transparent and secure way;

collect your personal data only for specific, explicit and legitimate purposes as explained to you when collecting your personal data;

not use your personal data in any way that is incompatible with those purposes;

process your personal data in a manner that is adequate and relevant to the purposes for which we have collected it and limited only to those purposes;

keep your personal data accurate and, where necessary, up to date; and

keep your personal data in a form that identifies you only as long as necessary for the purposes we have informed you and/or as permitted by law.

Data collection and use

The information we may collect from you includes:

information establishing your identity (for example, name, address, email address, date of birth, passport or Emirates ID);

documents to verify information supplied, such as bills issued by third parties or endorsements issued by employers or institutions such as banks;

reference checking information obtained via third parties, such as credit reference agencies, and sanctions lists;

financial information (for example, credit card details, bank account details);

information that you provide when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;

reference checking information obtained via third parties, such as credit reference agencies, and sanctions lists;

information relating to your use of our website (for example, domain name, IP address and cookies);

CCTV images if you visit our offices or premises;

any information you independently choose to provide to us (for example, if you send us an email or call us).

How do we obtain your information

We may collect your information during the course of our relationship with you and will only use your personal data in accordance with applicable data protection laws.

We may obtain this information from a variety of sources, including:

from you (for example, when you access or purchase services from us, when you use our website, when you make an inquiry about a service or investment, send emails, or otherwise provide us with your personal data);

from credit information or identity checks;

from suppliers;

from screening tools and information available in the public domain.

How we use your information

We may use or process your personal data for the following purposes:

to provide you with information about our services and investments and other information that we think may be valuable to you;

verifying or confirming investments or instructions from you or for your account;

to establish your financial situation, risk profile, investment experience and investment objectives to help you consider the suitability of the products you have invested or intend to invest;

to verify your identity and customer due diligence;

for audit purposes;

to resolve complaints and handling requests and enquiries;

preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks (including but not limited to preventing and detecting loss of our proprietary and sensitive information);

to respond to any queries, requests, or comments that you may have;

to process your payments;

to review, develop and improve the services which we offer; and

to comply with legal obligations.

On what basis we use your information

We use your personal data on the following bases:

for our legitimate interests. Using your personal data helps us to operate, improve and minimise any disruption to the products, services and investments that we may offer to you. We also have a legitimate interest in sending you information on the products, services and investments we believe will be of interest to you;

because the information is necessary for the performance of a contract with you or to take steps at your request to enter into a contract;

because you have given your consent (if we expressly ask for consent to process your personal data, for a specific purpose); and

to comply with legal and regulatory obligations.

With whom do we share your information?

We will only disclose or transfer your personal data for the purposes set out in this notice to:

third party service providers and sub-contractors who provide a service to us (including but not limited to marketing and advertising, data processing, IT and office services);

counterparties and their respective banks in relation to transactions for your account;

credit reporting agencies;

our professional advisers such as our auditors and lawyers;

any member of our group; and

any competent authorities if we are legally required to comply with a request for data.

Countries to which we transfer your information.

The information you submit may be transferred, stored and hosted outside of the DIFC, and may be transferred to countries which do not have data protection laws or to countries where your privacy and other fundamental rights will not be protected as extensively. These and all other transmissions will remain secure and under our sole control.

We will implement appropriate measures to ensure that your personal data remains protected and secure while and for as long as it remains under our control for example, implementing specific contractual clauses with the entities to whom we share your personal data.

Website and Cookies

Cookies are small pieces of information that your browser stores on your computer when requested by a website.

We may request your browser to store a cookie when you access our website and may request your browser to store one or more cookies when you make purchases, request or personalise information, or register yourself for certain services. We may use analytics cookies to evaluate use of our website and compile reports on activity on our website. You can usually amend the settings on your browser to reject cookies.

We may also use an application which records sessions on our website. This application will record the internet protocol address used to access the website and how you use our website during your visit (such as where you scroll and where your mouse cursor moves) by recording your session. The application will record the time your session started and the length of the session. The application will also tell us how you came to our website (such as via a particular search engine) if you have the necessary cookies enabled.

For further information on the cookies that we collect from time to time, how our website operates and its terms of use please see our website terms at

Data retention

We will keep your data only for as long as is necessary to respond to any queries or complaints, to improve the services that we offer to you or to comply with any legal obligations to which we may be subject.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve such purposes through other means, and the applicable legal requirements.

Your rights

Please contact us if you would like to:

Access your data – request a copy of your personal data that we process about you;

Rectify your data – request us to amend or update your personal data where it is inaccurate or incomplete;

Erase your data – request us to delete your personal data where it is no longer necessary for the purpose(s) for which your information was originally collected;

Restrict your data – request us temporarily or permanently to stop processing all or some of your personal data;

Object to the use of your data – at any time, object to us processing your personal data where it is based exclusively on our legitimate interests (see above) or for direct marketing purposes;

Receive or transmit your data in a machine-readable and structured format (otherwise known as "data portability") – request the receipt or transmission of your personal data to another organisation, in a structured and machine-readable format;

Withdraw your consent – withdraw your consent at any time to the use of your personal data for a particular purpose (where we have asked you for consent to use your information for that particular purpose).

For any of the above, please email us at or send postal mail to the following address: Samena Capital Investments Limited Emirates Financial Tower Level 14, South Tower United Arab Emirates Subject to any overriding legal obligations, requirements and/or exemptions, we will endeavour to respond to your request within thirty (30) days of receipt, unless we require further information from you. We may ask you to provide proof of your identity. If you feel that we do not comply with applicable data protection and privacy rules, you may lodge a complaint with a competent data protection authority.


We are committed to protecting the information you provide us. We have implemented security policies, rules and technical measures to protect the personal data that we have under our control, in accordance with applicable data protection laws. The security measures are designed to prevent unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.


Our websites may provide links to third-party websites for your convenience. If you access those links, you will leave our website. We do not control those websites or their privacy practices, which may differ from ours. We do not endorse or make any representations about third-party websites. This Notice does not cover the personal data you choose to give to unrelated third parties. We encourage you to review the privacy policy of any company before submitting your personal data. Some third-party companies may choose to share their personal data with us; that sharing is governed by that third-party company's privacy policy.

Notification of changes

We may be required to update or change our Privacy Policy from time to time. We will upload an updated Privacy Policy on this website. If there are any significant changes to the Privacy Policy (e.g. if we decide to use your personal data in a manner different from that stated at the time it was collected), we will notify you by way of an email.

Contacting us

This Notice sets out in broad terms how we handle your personal data and safeguard our privacy. If you have any questions relating to our Notice send postal mail to the following address:

Samena Capital Investments Limited Emirates Financial Tower Level 14, South Tower DIFC, 506713 United Arab Emirates