Privacy Policy

Effective Date: 1 June 2024

Last Update: 23 July 2025

1. Introduction

Three Pins Capital Limited ("we," "our," or "us") is a company incorporated in the Dubai International Financial Centre (DIFC) and regulated by the Dubai Financial Services Authority (DFSA) as a prudential Category 3C firm. We are licensed to carry on the following financial services activities only:

Managing a Collective Investment Fund
Advising on Financial Products
Arranging Deals in Investments
Arranging Credit and Advising on Credit

Our services are exclusively available to Professional Clients and Market Counterparties as defined under DFSA Rules. Our website and services are not directed toward or intended for Retail Clients, and we are not authorized to deal with Retail Clients.

We are committed to protecting the privacy and security of your personal information in accordance with the DIFC Data Protection Law No. 5 of 2020 and other applicable regulations.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us in connection with our licensed financial services activities.

2. Information We Collect

Personal Information

We may collect the following types of personal information:

Client Onboarding & Account Information

Name, address, phone number, and email address
Date of birth and Social Security number
Employment information and income details
Investment experience and financial objectives
Risk tolerance and investment preferences
Bank account and financial institution information

Website Usage Information

IP address and browser information
Pages visited and time spent on our website
Cookies and similar tracking technologies
Device information and operating system

Professional Client and Market Counterparty Information

Corporate registration and organizational details
Authorized representative and signatory information
Financial statements and audited accounts
Investment committee and decision-maker details
Professional Client or Market Counterparty classification documentation
Regulatory and compliance status information
Credit assessment and due diligence information
Risk profile and risk management framework information
Treasury operations and liquidity management details

3. How We Use Your Information

We use your personal information for the following purposes:

Licensed Financial Services

Managing collective investment funds and fund administration
Providing advisory services on financial products and investment strategies
Risk management advisory to corporates, institutions and sovereigns
Arranging deals in investments and facilitating investment transactions
Arranging credit facilities and advising on credit-related matters
Fund structuring, development and management services
Distribution and marketing of select third-party funds and financial products
Treasury and risk management advisory services

Business Operations

Communicating with you about our services
Responding to inquiries and providing customer support
Sending account statements and regulatory notices
Conducting identity verification and fraud prevention

Legal and Regulatory Compliance

Fulfilling DFSA regulatory reporting requirements for Category 3C firms
Complying with DIFC laws and regulations
Conducting anti-money laundering (AML) and counter-terrorism financing (CTF) checks
Meeting Professional Client and Market Counterparty due diligence obligations
Verifying and maintaining client classification status under DFSA Rules
Maintaining records as required by DIFC and DFSA regulations for our licensed activities
Responding to regulatory inquiries and investigations

Marketing (with consent)

Sending newsletters and market updates
Providing information about new services
Inviting you to events and webinars

4. Information Sharing and Disclosure

We may share your personal information in the following circumstances:

Service Providers. With third-party vendors who assist us in providing our licensed financial services, including:

Fund administrators and institutional custodians
Prime brokers and investment platforms
Technology providers and data processors
Professional service providers (accountants, lawyers, auditors)
Compliance and regulatory reporting services
Credit assessment and due diligence service providers
Fund distribution and marketing partners
Risk management and treasury advisory specialists

Legal Requirements. When required by DIFC law, DFSA regulation, or legal process, including:

DFSA regulatory examinations and investigations
DIFC Court orders and legal proceedings
Anti-money laundering and suspicious transaction reporting
Counter-terrorism financing compliance obligations

Business Transfers. In connection with a merger, acquisition, or sale of our business assets

Consent: With your explicit consent for other purposes not covered by this policy

5. Data Security

We implement appropriate technical and organizational security measures to protect your personal information, including:

Encryption of sensitive data in transit and at rest
Multi-factor authentication for system access
Regular security assessments and updates
Employee training on data protection practices
Secure data centers and network infrastructure

6. Data Retention

We retain your personal information for as long as necessary to:

Provide our services to you
Comply with DFSA and DIFC legal and regulatory requirements
Resolve disputes and enforce our agreements
Meet our business and operational needs

Financial records are typically retained for at least six years after account closure, or as required by DFSA regulations and DIFC law.

7. Your Rights and Choices

Under the DIFC Data Protection Law, you have certain rights regarding your personal information:

Right of Access: Request access to your personal information and receive a copy of the data we hold about you

Right to Rectification: Request correction of inaccurate, incomplete, or out-of-date personal information

Right to Erasure: Request deletion of your personal information, subject to legal and regulatory retention requirements

Right to Restrict Processing: Request limitation of processing of your personal information in certain circumstances

Right to Data Portability: Request to receive your personal information in a structured, commonly used format

Right to Object: Object to certain types of processing, including direct marketing

Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time

Right to Lodge a Complaint: You may lodge a complaint with the DIFC Commissioner for Data Protection if you believe your data protection rights have been violated

To exercise these rights, please contact us using the information provided below. We may need to verify your identity before processing your request.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to:

Ensure proper website functionality
Remember your preferences and settings
Analyze website usage and improve user experience
Provide personalized content and advertising

You can manage your cookie preferences through your browser settings, though disabling certain cookies may affect website functionality.

9. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites and encourage you to review their privacy policies.

10. International Data Transfers

As a DIFC-incorporated entity, we may transfer your personal information outside the DIFC to other jurisdictions for legitimate business purposes, including to service providers and group companies. When we transfer personal information outside the DIFC, we ensure appropriate safeguards are in place to protect your information, including:

Adequacy decisions by the DIFC Commissioner for Data Protection
Standard contractual clauses approved by the DIFC Commissioner
Binding corporate rules
Other appropriate safeguards as required by the DIFC Data Protection Law

We may transfer data to jurisdictions including European Union, India, Mauritius, Switzerland, the United States and other countries where our service providers or custodians are located.

11. Licensed Activities Only

Important Notice: We are authorized by the DFSA to carry on only the following financial services activities:

Managing a Collective Investment Fund
Advising on Financial Products
Arranging Deals in Investments
Arranging Credit and Advising on Credit

We do not provide any financial services outside of these licensed activities. Our services are exclusively available to Professional Clients and Market Counterparties as defined under DFSA Rules. We are not authorized to deal with Retail Clients.

12. Professional Clients and Market Counterparties Only

This website and our communications are intended for Professional Clients and Market Counterparties only, and should not be accessed by, Retail Clients.

If you do not qualify as a Professional Client or Market Counterparty under DFSA Rules, you should not use this website or our services. We reserve the right to verify client classification status and may decline to provide services if you do not meet the required criteria.

13. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors without parental consent.

14. DIFC Data Protection Law Compliance

This Privacy Policy is designed to comply with the DIFC Data Protection Law No. 5 of 2020. Our processing of personal information is based on lawful grounds including:

Performance of our contract with you for investment services
Compliance with legal and regulatory obligations
Legitimate business interests
Your explicit consent where required

We implement appropriate technical and organizational measures to ensure data protection by design and by default, including data minimization, purpose limitation, and storage limitation principles.

15. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, or legal requirements under DIFC law. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated" date. Where required by the DIFC Data Protection Law, we will seek your consent for material changes that affect how we use your personal information.

16. Contact Information

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or want to make a complaint, please contact us:

Three Pins Capital Limited
DIFC License No.: CL8262
Email: privacy@threepins.com
Phone: +971 4 549 9700
Address: Central Park Offices, Level 2, Unit OT 02-44, DIFC, PO Box 454201, Dubai, United Arab Emirates

DIFC Commissioner for Data Protection:
If you wish to lodge a complaint about our handling of your personal information, you may contact:
Email: dataprotection@difc.ae
Website: www.difc.ae

This Privacy Policy should be reviewed by qualified legal counsel familiar with DIFC Data Protection Law and DFSA regulations to ensure full compliance with applicable laws and regulations. As a DFSA-regulated entity, additional privacy and confidentiality obligations may apply under DFSA rules and DIFC laws.