This website and other related internet based applications (collectively referred to as "website" or "services") are owned and operated by Moonrock Investments Limited, a company incorporated in the DIFC, and regulated by the DFSA having its registered office at N411, Emirates Financial Towers, DIFC, PO Box 506883, Dubai, UAE (hereinafter referred to as "we", or "us" or our or "MRK"). In accordance with the DIFC Data Protection Law, this privacy policy gives you details about our data collection methods and usage. You are advised to read this privacy policy along with the Terms of Use, Disclaimer and other information in the website/applications.

The personal data collected from you, provided by you or obtained from other sources on your behalf will be held, disclosed and processed by MRK for the purposes of offering you our services and maintaining the relationship with you. Presently, we use your personal data for the following lawful purposes:

  • Performance of Contract/Agreement: At the time on onboarding you as a client upon receiving your application with the signed subscription/client agreements, KYC documents and while performing advisory services in managing your portfolio ongoing advising and managing your portfolio that may also involve additional subscriptions, redemptions, distribution of payments etc. We are also liable to disclosures to third parties identified in performing as per the agreements such as regulators, auditors, tax authorities and technology providers. In case of recording, maintaining, storing and using recordings of tele communication to & from you with MRK or its officers, employees, delegates or duly appointed business partners and any of their respective related, associated or affiliated companies for processing and verification of instructions, providing advisory services and administration of your account(s) and any other matters related to your investment with MRK or for dispute resolution, record keeping, security and/or training purposes. Personal data is also used when circulating periodic reports, newsletters, factsheets and when responding to queries or providing you support or for any other purpose as provided for in the agreements between us.
  • Compliance with legal obligations: While complying with any applicable legal, tax or regulatory obligations, legal obligations under the companies act, FTA Laws, the AML regulations and other relevant regulatory laws and regulations including but not limited to and in line with anti-money laundering requirements under the DFSA AML regulations and other related regulations set by globally recognized AML agencies, all clients are required to be identified for which certain standard KYC and additional KYC documents may be requested. MRK is also obliged to collect and share certain information about each investor’s tax arrangements for CRS, FATCA reporting purposes, and may be required to share information with other financial information with respect to investor’s interest with the relevant tax authorities under relevant jurisdictions. MRK shall engage in screening for the purpose of AML regulations and counter terrorist facing legislations including PEP screening and with UN, EU and other applicable sanctions regimes.
  • Legitimate interest: While carrying out any statistical analysis, market research, recording, maintaining, and storing any communication including telephones. Please note that where personal data is processed for purposes of legitimate interests, you have a right to object to such processing and MRK will no longer process the personal data unless MRK can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
  • Consent: From time to time, MRK may send you information about financial markets etc., by telephone, by email or by other reasonable means of communication. You have the right not to receive such information. Your consent is not required to process your personal data for the purposes referenced above. However, in order to process your personal data for the purposes of direct marketing, MRK seeks your consent. You have a right to withdraw this consent at any time. However, your withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. You can withdraw your consent by contacting us at N411, Emirates Financial Towers, DIFC, PO Box 506883, Dubai, UAE. Personal data relating to you which is collected from you or provided by you or on your behalf may be handled by MRK or their duly appointed agents and any of their respective related, associated or affiliated companies for the purposes specified above. These data processors will handle your information in accordance with applicable Data Protection Law. MRK may disclose your personal data to other third parties where required by law or for legitimate business interests. This may include disclosure to third parties such as auditors and the regulatory bodies, taxation authorities and technology providers. Your data may be processed outside of the DIFC. Personal data collected from you or provided by you or on your behalf may be transferred outside of transactions originating jurisdiction including to companies situated in countries that may not have the same data protection laws. Such data transfers will only involve companies, which are part of the same corporate group or acting as service providers to the MRK. MRK will retain your personal information for as long as is needed to fulfill the purposes outlined in our Data Protection Policy, unless a longer retention period is required or permitted by law.

    Your account information is and or will be password-protected for your privacy and security. You shall be the custodian of your password and comply with the applicable terms mentioned in the Website/Application in this regard. Our information security controls ensure that personal data is well protected and accessible only to authorised personnel. Your data protection rights are appended herein. You have a right of access to and the right to amend, complete and rectify. You have a right to be forgotten (right of erasure of personal data). You have a right to restrict processing and data portability. You also have the right to object to processing where MRK is processing personal data for legitimate interests. You have the right to withdraw your consent used for Direct Marketing Additionally, you have a right to lodge a complaint with relevant supervisory authority, in the DIFC of the alleged infringement if you consider that the processing of personal data relating to you carried out by MRK is not as per the regulation in force. We do not track your online activities across the Internet. We do not use your personal information for automated decision-making, including profiling. We do not sell or rent your personal information to third parties.