Privacy Policy

Effective Date: 24.06.2025

1. Introduction

RoboMarkets MENA for Financial Brokerage L.L.C. (“RoboMarkets”, “we”, “our”, or “us”) is a mainland UAE-registered financial brokerage firm. We are fully committed to protecting your privacy and ensuring transparent and lawful processing of your Personal Data in compliance with:

• UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL);
• Federal Law No. 4 of 2000, as amended, and relevant provisions in the Capital Market Authority (CMA) Rulebook;
• Guidelines and regulations issued by the UAE Data Office.

This Policy explains:

• How and why we collect and process your Personal Data;
• The legal basis for each type of processing;
• Who may access your data;
• How we protect your privacy;
• How long we keep your data;
• Your rights and how to exercise them;
• Our use of cookies and tracking technologies.

It applies to our website (www.robomarkets.com), trading platforms, mobile applications, communication channels, and interactions within the UAE mainland.

2. Definitions

• “Personal Data”: Any information relating to an identified or identifiable natural person, including identifiers like name, ID number, location or biometric identifiers.
• “Sensitive Personal Data”: Data revealing race, ethnicity, political views, religious beliefs, health status, or genetic/biometric data.
• “Processing”: Any operation performed on Personal Data — collection, storage, organisation, adaptation, retrieval, consultation, disclosure, erasure, or destruction.
• “Controller”: The entity that determines the purpose and means of processing; here, RoboMarkets.
• “Processor”: Third parties that Process Personal Data on behalf of RoboMarkets.
• “Affiliates”: Any legal entity controlling, controlled by, or under common control with RoboMarkets.
• “You” / “Your”: Any individual whose Personal Data is processed by RoboMarkets.
• “Services”: Products and services provided by RoboMarkets, including trading platforms, broker services, support, and communications.
• “Website”: Our online presence at www.robomarkets.com and associated subdomains.

3. Data Controller, Contact and DPO

RoboMarkets MENA for Financial Brokerage L.L.C. (the "Controller") determines the purposes and means of Processing Personal Data of individuals ("Data Subjects") in accordance with Federal Decree-Law No. 45 of 2021 (PDPL).

Business Address:
Office 903, Dubai Hills Business Park, Building 1,
Dubai Hills Estate, Dubai, United Arab Emirates

General Enquiries and Data Subject Requests:
Email: info@robomarkets.com
Telephone: +971-[4256 0604]

Data Protection Officer (DPO):
The Controller has appointed a Data Protection Officer responsible for overseeing PDPL compliance. Data Subjects may contact the DPO to exercise rights, lodge complaints, or clarify Processing activities.
Email: info@robomarkets.com

4. Categories of Personal Data Collected

• Identity & Regulatory Data: includes full name, date and place of birth, Emirates ID or passport details (including scanned copies), nationality, and occupation. This may also include regulatory information such as KYC documentation, FATCA/CRS declarations, and internal risk assessments.
• Contact Data: includes residential address, mailing address, email addresses, and phone numbers.
• Financial & Transactional Data: includes account numbers, balances, trading history, deposit and withdrawal records, linked bank/payment card details, and documentation verifying source of funds.
• Technical & Usage Data: includes IP address, browser type, device identifiers, operating system, log-in/out timestamps, cookies, and user behaviour logs.
• Communication Data: includes recorded telephone conversations (where permitted by law), emails, and live chat transcripts.
• Third-Party Data: includes data obtained from Processors such as KYC/AML vendors, credit reference agencies, sanctions screening databases, or fraud prevention services.
• Sensitive Personal Data: may be Processed in limited circumstances, such as biometric identity verification or compliance with legal obligations. Where applicable, explicit consent is obtained, and enhanced security measures are applied.
• The categories of Data Subjects whose Personal Data may be collected include clients, website visitors, authorised representatives of corporate clients, beneficial owners, and employees of service providers.

5. Purposes of Processing & Legal Grounds

The Controller Processes Personal Data for clearly defined and legitimate purposes. The table below illustrates typical Processing activities, types of Personal Data involved, and legal bases under the PDPL:

RoboMarkets may engage in profiling and limited automated decision-making for fraud detection or transaction verification. Data Subjects may request human intervention in such cases.

6. Disclosure to Third Parties

RoboMarkets may disclose Personal Data to authorised third parties, subject to confidentiality and legal safeguards. These include:

• Regulators and Enforcement Authorities: such as the Capital Market Authority (CMA), UAE Central Bank, Financial Intelligence Unit, law enforcement agencies, and courts.
• Affiliates: entities under common control with RoboMarkets, acting as joint Controllers or Processors for internal compliance, operational risk management, or customer analytics.
• Processors: third parties engaged to carry out specific Processing operations (e.g., cloud hosting, KYC verification, payment gateway providers). RoboMarkets performs due diligence to ensure PDPL-compliant contracts and security standards are in place.
• Professional Advisors: including legal counsel, auditors, or consultants acting under strict confidentiality terms.
• Financial Institutions & Brokers: to facilitate deposits, withdrawals, trade execution, and payment settlements.
• Corporate Counterparties or Acquirers: in case of a merger, acquisition, or transfer of business assets, subject to appropriate safeguards.

A full list of Processors and affiliates is available upon request from the DPO.

7. International Data Transfers

The Controller may transfer Personal Data outside the UAE to jurisdictions that ensure an adequate level of protection as defined by the UAE Data Office. Where adequacy is not established, RoboMarkets ensures appropriate safeguards such as:

• Standard contractual clauses approved by the UAE Data Office;
• Binding corporate rules for intra-group transfers;
• Explicit and informed consent of the Data Subject (where permitted);
• Legal necessity for performance of a contract with the Data Subject or in the Data Subject's interest.

All international transfers are subject to documentation and oversight by the DPO.

8. Data Security Measures

RoboMarkets implements physical, technical, and organisational controls to protect Personal Data from loss, misuse, unauthorised access, alteration, or destruction. These include:

• Data encryption (in transit and at rest);
• Role-based access control and authentication mechanisms;
• Secure storage infrastructure with restricted physical access;
• Regular penetration testing and vulnerability assessments;
• Formal data breach notification procedures;
• Staff training and confidentiality undertakings.

Where Sensitive Personal Data is Processed, enhanced security measures (e.g., restricted access, audit trails) are enforced.

9. Data Retention

Personal Data will be retained only for as long as necessary for the purposes stated in this Policy or as required by applicable laws:

• Active accounts: maintained for the duration of the client relationship.
• Post-closure: retained for a minimum of five (5) years, per CMA and AML regulations.
• Legal hold: extended retention applies where data is relevant to an ongoing investigation or dispute.
• Anonymisation or deletion: data no longer needed is either securely deleted or irreversibly anonymised.

Retention periods are monitored periodically by the DPO and documented in internal retention schedules.

10. Your Rights under PDPL

As a Data Subject, you have the following rights under the UAE Federal Decree-Law No. 45 of 2021:

• Right of Access: to obtain confirmation whether Personal Data is being Processed and to receive a copy.
• Right to Rectification: to correct inaccurate or incomplete Personal Data.
• Right to Erasure: to request deletion of Personal Data under certain lawful grounds.
• Right to Restriction: to limit Processing in defined cases.
• Right to Object: to object to Processing based on legitimate interests, including direct marketing.
• Right to Data Portability: to receive Personal Data in a structured, machine-readable format.
• Right to Withdraw Consent: to withdraw consent at any time, without affecting prior lawful Processing.
• Right to Lodge a Complaint: to contact the DPO or escalate to the UAE Data Office.

RoboMarkets will respond to validated rights requests within the timeframes prescribed by PDPL. Requests may be submitted via: privacy@robomarkets.com

11. Cookies & Tracking Technologies

RoboMarkets uses cookies and similar tracking technologies to enhance your browsing experience, facilitate secure logins, and collect usage statistics. Cookies are small text files stored on your device that help us identify repeat visits and improve platform performance.

Types of Cookies We Use:

• Strictly Necessary Cookies: Required for login, authentication, and secure navigation.
• Performance & Analytics Cookies: Help us understand how users interact with our website (e.g., Google Analytics).
• Functionality Cookies: Store preferences and user settings.
• Targeting/Marketing Cookies: Used for advertising or retargeting campaigns, only activated with your consent.

You can manage cookie preferences via our cookie banner or through your browser’s settings.

12. Minors’ Privacy

RoboMarkets does not knowingly collect or Process Personal Data from individuals under the age of 18. If we become aware that we have inadvertently collected such data, we will delete it immediately. Our Services are intended only for individuals who are legally eligible to enter into binding agreements.

13. Changes to the Policy

This Privacy Policy may be amended or updated from time to time to reflect changes in legal requirements, our Processing activities, or platform features. The most recent version will always be available at www.robomarkets.com/about/documents/ and marked with the date of last revision.

We recommend that you periodically review this Policy to remain informed of how we Process your Personal Data.

14. Contact & Complaints

If you have any questions regarding this Privacy Policy, your rights as a Data Subject, or the way your Personal Data is being handled, please contact:

Data Protection Officer
RoboMarkets MENA for Financial Brokerage L.L.C.
Office 903, Dubai Hills Business Park, Building 1
Dubai Hills Estate, Dubai, UAE
Email:info@robomarkets.com

You also have the right to file a complaint with the UAE Data Office using the platform at: https://u.ae/en/about-the-uae/digital-uae/data/data-protection.

We take all concerns seriously and commit to responding to complaints in accordance with our obligations under PDPL and other applicable laws.