Privacy Policy
This Privacy Policy is under final review with NWM's Compliance function. The current version is provided for reference and is subject to update.
Scope
This Privacy Policy describes how Neovision Wealth Management Limited ("NWM", "we", "our", or "the firm") collects, uses, stores, and protects personal data in connection with this website and the firm's services. NWM is incorporated in the Abu Dhabi Global Market (ADGM) and is subject to the ADGM Data Protection Regulations 2021, not the EU General Data Protection Regulation (GDPR).
Data controller
The data controller is Neovision Wealth Management Limited, Office 2306, 23rd Floor, Tamouh Tower, Al Reem Island, PO Box 7851, Abu Dhabi, UAE.
What data we collect
NWM collects personal data in the following circumstances:
- Website enquiries: when you submit a contact form, email, or make an enquiry, we collect your name, contact details, organisation, and the content of your enquiry.
- Client onboarding: when you become a client, fund investor, or counterparty, we collect the identification, wealth, source-of-funds, and due-diligence information required under our regulatory obligations (KYC, AML/CFT, FSRA Conduct of Business Rules).
- Ongoing client relationship: we collect transaction, portfolio, communication, and service-delivery data required to manage the relationship.
- Website analytics: with your consent, we use Google Analytics 4 (delivered via Google Tag Manager) to understand how visitors use our website. Google Analytics may set first-party cookies (typically prefixed _ga) and process aggregate data including IP address (anonymised), browser, device, referrer, and page-view events. We do not use advertising or personal-profiling cookies. Without your consent, Google Analytics is configured in privacy-preserving mode (Consent Mode v2 default-denied), which sends only anonymised pings without setting cookies. You can change your choice at any time via the “Cookie preferences” link in the footer. For Google’s data-handling practices, see policies.google.com/privacy.
Legal basis and purposes
We process personal data on the following legal bases under the ADGM Data Protection Regulations 2021:
- Performance of a contract or pre-contractual steps: to respond to enquiries, onboard clients, and deliver services.
- Legal and regulatory obligation: to comply with our FSRA regulatory obligations, AML/CFT laws, and tax reporting requirements (including FATCA, CRS).
- Legitimate interests: to operate the firm, secure our systems, prevent fraud, and maintain an audit trail.
- Consent: where consent is specifically obtained (e.g. optional marketing communications).
Who we share data with
We share personal data only with:
- Regulators (FSRA, ADGM Registration Authority) to the extent legally required.
- Fund service providers (administrators, custodians, auditors, legal counsel) where required for the operation of a fund in which you invest.
- Authorised third-party processors (e.g. IT, email, secure document storage providers) who act on our instruction under appropriate data-protection terms.
- Law enforcement or other authorities where legally compelled.
We do not sell personal data. We do not share personal data with advertising networks.
International transfers
Where personal data is transferred outside the ADGM, we ensure appropriate safeguards are in place as required by the ADGM Data Protection Regulations 2021, including the use of approved contractual clauses or transfer to jurisdictions with adequate data-protection frameworks.
Retention
We retain personal data for the period required to fulfil the purposes for which it was collected, including regulatory record-keeping obligations (typically a minimum of six years under FSRA rules for client and transaction records) and any longer period required by applicable law.
Your rights
Under the ADGM Data Protection Regulations 2021, you have the following rights, subject to certain limitations:
- To be informed about how your data is processed.
- To access the personal data we hold about you.
- To request correction of inaccurate data.
- To request erasure (where permitted; our regulatory record-keeping obligations may prevent erasure in many cases).
- To object to processing on certain grounds.
- To request restriction of processing in certain circumstances.
- To data portability in certain circumstances.
- To lodge a complaint with the ADGM Office of Data Protection.
Security
We maintain appropriate organisational and technical security measures to protect personal data against unauthorised access, alteration, disclosure, or loss. These include access controls, encryption, secure infrastructure, and regular review.
Contact
For any question relating to this Privacy Policy or your personal data, please contact our Compliance function at compliance@neovision-wealth.com or through our general channels.
Updates
We may update this Privacy Policy from time to time. The current version and effective date will always be displayed on this page.