Privacy Policy

Last Updated: March 22, 2025

APPLICATION OF THIS PRIVACY POLICY

Soor Capital Group and its affiliated entities ("Soor Capital Group", "we", "us", "our") are committed to protecting the Personal Data of the individuals we encounter in conducting our business. This Privacy Policy explains how and why Soor Capital Group, its representatives and authorized administrators collect, process and disclose the Personal Data of customers, vendors, employees, and website visitors ("you", "your") and provides information about your rights.

The Soor Capital Group consists of:

Soor Capital Holding W.L.L. (Kuwait)
Soor Capital Management (DIFC) Limited (Dubai International Financial Centre)
Soor Capital Advisors Ltd. (Cayman Islands)
Soor Capital Properties UK Ltd. (United Kingdom)

Each entity within the Soor Capital Group complies with the data protection and privacy laws applicable in its jurisdiction. For specific information about how a particular entity handles your Personal Data, please refer to that entity's section on our website.

This Privacy Policy applies to our main website at www.soorcapital.com and covers how we handle Personal Data collected through this group website. Entity-specific privacy policies may apply when you interact directly with individual Soor Capital Group entities.

"Personal Data" means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

"Special Categories of Personal Data" means Personal Data revealing or concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, data concerning sex life or sexual orientation, or data relating to criminal convictions and offenses.

PLEASE READ THIS PRIVACYPOLICY CAREFULLY. THIS PRIVACY POLICY MAY BE MODIFIED FROM TIME TO TIME.

COLLECTION OF PERSONAL DATA

We may collect Personal Data from you through your use of the website, when you request information from us, when you engage with us for employment or for any services, or as a result of your relationship with any of our clients.

We may request and collect from you Personal Data and other information. Depending on the information or services you request, we may ask you to provide your name, phone numbers, address, email address, professional information, and other such personal information.

By providing us with any Personal Data, you are consenting to the use of your Personal Data as contemplated in this Privacy Policy. If you do not want us to use your Personal Data for any of these purposes, please do not provide us with your Personal Data.

In addition to the Personal Data you knowingly provide to us, with regard to each of your visits to our website, we may automatically collect the following information:

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, location, browser plug-in types and versions, operating system; and
Information about your visit; services you viewed or searched for; page response times, download errors, length of visits, page interaction information (such as scrolling, clicks, and mouse-overs).

COOKIES AND SIMILAR TECHNOLOGIES

Our website uses cookies and similar tracking technologies to distinguish you from other users and to improve your browsing experience. A cookie is a small file placed on your device when you visit our website.

We use the following types of cookies:

Essential cookies: Required for the website to function properly. These cookies are necessary for the website to function and cannot be switched off in our systems.
Functional cookies: Enable enhanced functionality and personalization. These cookies allow the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages.
Analytics cookies: Help us understand how visitors interact with our website by collecting and reporting information anonymously. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site.
Marketing cookies: Used to track visitors across websites for advertising purposes. These cookies may be set through our site by our advertising partners and are used to build a profile of your interests and show you relevant advertisements on other sites.

You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some services and functionalities may not work.

For more information about how we use cookies and how you can manage your preferences, please see our Cookie Banner when you visit our website.

PURPOSES

We will only use your Personal Data for our legitimate business purposes, including:

To process and respond to inquiries, and provide our services;
To process and respond to inquiries, and provide our services;
To market our services;
To comply with legal and regulatory obligations;
To compile anonymous statistics, such as website usage statistics and statistics on the effectiveness of invitations and other emails; and
Where otherwise required by law.

LEGAL BASIS FOR PROCESSINGYOUR INFORMATION

Soor Capital Group processes your Personal Data on the following legal bases:

‍Consent: Where you have given clear consent for us to process your Personal Data for a specific purpose.
‍Contract: Where our use of your Personal Data is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
‍Legal obligation: Where our use of your Personal Data is necessary for us to comply with the law (not including contractual obligations).
Legitimate interests: Where our use of your Personal Data is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your Personal Data which overrides our legitimate interests).

Depending on the specific circumstances, we may rely on one or more of these legal bases when processing your Personal Data. Where we rely on consent for processing, you have the right to withdraw that consent at any time.

SHARING YOUR INFORMATION

We may disclose your Personal Data to:

Other entities within the Soor Capital Group;
Third-party service providers who perform functions on our behalf (such as hosting providers, IT service providers, and marketing agencies);
Professional advisors such as lawyers, accountants, and auditors;
Regulatory authorities, courts, and government agencies where required by law; and
Potential buyers or investors in the event of a business transaction such as a merger, acquisition, or asset sale.

In relation to any other third parties, we will only disclose your information where you have given your consent or where we are required to do so by law, or where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights.

CROSS-BORDER TRANSFER OFYOUR INFORMATION

It may sometimes be necessary for us to share your Personal Data with other entities within the Soor Capital Group or with third-party service providers located in different jurisdictions around the world. These transfers may involve sending your Personal Data to countries where data protection laws may not provide the same level of protection as in your home country.

When we transfer your Personal Data internationally, we implement appropriate safeguards to ensure that your information remains protected. These may include:

Entering into standard contractual clauses approved by relevant data protection authorities;
Transferring to countries that have been deemed to provide an adequate level of protection; or
Obtaining your explicit consent to the proposed transfer.

DATA SECURITY

We have implementedappropriate technical and organizational measures to protect your Personal Dataagainst unauthorized or unlawful processing, accidental loss, destruction, ordamage. We regularly review and update these measures to maintain their effectiveness.

While we strive to protectyour Personal Data, no method of transmission over the Internet or electronicstorage is 100% secure. Therefore, we cannot guarantee absolute security.

RETENTION OF YOUR PERSONALDATA

We will retain yourPersonal Data for as long as necessary to fulfill the purposes for which it wascollected, including for the purposes of satisfying any legal, accounting, orreporting requirements. The criteria used to determine our retention periodsinclude:

The length of time we have an ongoing relationship with you;
Whether there is a legal or regulatory obligation to which we are subject; and
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

Your Personal Data that isprocessed for marketing purposes will be stored until you exercise the right towithdraw consent, and once such right is exercised, your Personal Data will bekept only during the applicable statute of limitations period for any disputesor liabilities that may arise.

YOUR RIGHTS

Depending on your locationand the applicable data protection laws, you may have some or all of thefollowing rights:

Right to Access: The right to obtain confirmation of whether we process your Personal Data and to receive a copy of that data.‍
Right to Rectification: The right to haveinaccurate Personal Data corrected and incomplete data completed.‍
Right to Erasure (Right to be Forgotten): The right to have yourPersonal Data erased in certain circumstances.‍
Right to Restriction of Processing: The right to require us to restrict processing of your Personal Data in certain circumstances.‍
Right to Data Portability: The right to receive your Personal Data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.‍
Right to Object: The right to object to our processing of your Personal Data in certain circumstances.‍
Right to Withdraw Consent: Where processing is based on consent, the right to withdraw that consent at any time.‍
Right to Lodge a Complaint: The right to lodge a complaint with a supervisory authority if you believe that our processing of your Personal Data infringes data protection laws.

If you wish to exerciseany of these rights, please contact us using the contact details provided atthe end of this Privacy Policy. We may need to request specific informationfrom you to help us confirm your identity and ensure your right to access yourPersonal Data.

CHILDREN'S PRIVACY

Our website and servicesare not directed at individuals under the age of 18. We do not knowinglycollect Personal Data from children. If you become aware that a child hasprovided us with Personal Data without appropriate parental consent, pleasecontact us so that we can take steps to delete such information.

CHANGES TO THIS PRIVACYPOLICY

We may update this PrivacyPolicy from time to time to reflect changes in our practices or for otheroperational, legal, or regulatory reasons. When we make material changes tothis Privacy Policy, we will provide notice through our website or by other means,such as email, before the changes take effect.

We encourage you toperiodically review this Privacy Policy to stay informed about how we areprotecting your information. This policy was last updated on March 22, 2025,and supersedes all previous versions.

CONTACT INFORMATION

If you have any questions,concerns, or requests regarding this Privacy Policy or our data processingpractices, please contact us at:

GroupData Privacy Office
Soor Capital Holding W.L.L.
Kuwait City, Kuwait
Email: info@soorcapital.com

For inquiries specific to any Soor Capital entity, please use the email address above and specify therelevant entity in your communication.

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