Iceberg Capital Limited Notice v1 (effective July 2022)

Data Privacy Notice

We value your privacy and are committed to using your personal data in compliance with applicable data protection laws. This privacy notice describes the types of personal data that we may collect, the purposes of collecting it and how it is used, shared and safeguarded during and after your relationship with us.

  1. General information about this privacy notice

This privacy notice is in relation to Iceberg Capital Limited (which we refer to as “ICEBERG”, or “we”/ “us”/ “our” and we may also refer to our “Associates” which consist of our related legal entities, details of which can be obtained by contacting us).

ICEBERG is subject to the Abu Dhabi Global Markets (“ADGM”) Data Protection Regulations 2021, (which we refer to as “ADGM Data Law”), for purposes of which we are the data controller.

This privacy notice applies to (a) parties we conduct business with (such as current or potential clients, suppliers, business partners, professional advisers or anyone connected with a transaction or client’s matter we are involved with) (b) visitors to our offices or website or other business contacts.

You may contact us in relation to this privacy notice on [EMAIL ADDRESS] or writing to [NAME OF PERSON], Office [add] , UAE (which are also available in ‘Section 9: Contacting ICEBERG at the end of this notice).

  1. What personal data we collect

In the ordinary course of our business and operations, ICEBERG, and its affiliates, collect, use, and share personal data pertaining to you. The term “personal data” or “personal information” means any information about an individual from which that person can be identified, which we have in our possession or control.

The personal data on that we collect, use, store, share or otherwise process includes information that:

If you are a party we conduct business with (such as current or potential clients, suppliers, business partners, professional advisers or anyone connected with a transaction or client’s matter we are involved with), such information may include:

If you are a visitor to our office/ website or other business contact (such as a person who has emailed us or met one of our representatives but does not conduct business with us), such information may include:

  1. How we use your personal data and our legal basis for doing so

We may collect, process and store this personal data for the purposes of:

ICEBERG is entitled to use personal data in these ways because:

  1. Disclosure and transfer of personal data

Data sharing with ICEBERG’s Associates

ICEBERG may share your personal data its Associates for internal management and administrative purposes or to provide the services or perform its obligations in connection with your contract or transaction. In such cases, ICEBERG will take steps to ensure that the personal data is accessed only by those persons who need to do so for the purposes described in this privacy notice.

Data sharing with Third Parties

ICEBERG may also share your personal data with Third Parties where required by law, where it is necessary to administer our relationship with you or where we have another legitimate interest in doing so. “Third Parties” include third-parties that provide products and services to ICEBERG including vendors and contractors).

We share personal data with Third Parties as follows:

Transfers of data outside the Abu Dhabi Global Markets

As our Associates and many of our third party service providers are based outside of the ADGM, personal data may be transferred to or stored at a destination outside the ADGM (including staff operating outside of the ADGM who work for ICEBERG and/or its Associates and its third party service providers or contractors.

When we transfer your personal data out of the ADGM, we will ensure a similar degree of protection is afforded to it, which may be achieved in one of the following ways:

In other circumstances the law may permit or require ICEBERG to otherwise transfer personal data outside the ADGM. In all cases, however, ICEBERG will ensure that any transfer of personal data is compliant with applicable data protection law.

You can obtain further details of the protection given to your personal data when it is transferred outside the ADGM by contacting us on the details provided in ‘Section 9: Contacting ICEBERG”).

  1. Web Data

We may also collect information on how the service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking and Cookie Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collet and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies are

  1. Data security

We have put in place appropriate measures to protect the security of your personal information.

Third parties will only process your personal information where they have agreed to treat the personal information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to access it. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

  1. Retention of personal data

The time period for which we retain your personal data will be determined by various criteria as described below. To determine the appropriate retention period, 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 the applicable legal requirements.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

  1. Your rights in relation to personal data

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Under certain circumstances, under the ADGM Data Law you have the right to:

You can exercise your rights by contacting ICEBERG using the details set out in "Section 9” Contacting ICEBERG" section below. You can also find out more information about your rights by contacting the office ADGM Commissioner of Data Protection.

  1. Contacting ICEBERG

If you would like further information about ICEBERG’s processing of your personal data or would like to exercise of any of your rights referred to above, please contact us as follows:

By Email:  [ENTER]

By Writing to us:      Attn: Ms.


By Phone:                  [Phone Number]