Priora Privacy Policy Statement

Priora Holding Ltd, Priora Management Holding Ltd and Priora Investment Ltd are private companies (referred to “Priora”) registered in the Dubai International Financial Centre (“DIFC”). Priora is committed to protect the Personal Data of the individuals when conducting its business. “Personal Data” is data about an individual who can be identified from that data. This Privacy Policy explains how Priora and its representatives deal with Personal Data. Our policies and procedures have been designed to reflect our business activities and to ensure that Personal Data is protected.

Priora Personal Data Protection Obligations

The nature of Priora`s business is such that the collection, use and disclosure of personal information is generally not relevant when rendering our services. Nonetheless, there might be situation where Personal Data are handled. We therefore work hard and do everything needed to respect personal privacy according to the requirements of the Dubai International Financial Centre Data Protection Law (DIFC Law No.1 of 2007, as amended) (“DPL”) when collecting, holding, processing or using Personal Data in the DIFC. We are also committed ensuring that all our employees and representatives uphold these requirements. Under the DPL, Priora is bound to the following obligations with respect to your Personal Data:

  1. Consent
  2. Purpose Limitation
  3. Notification
  4. Access and Correction
  5. Accuracy
  6. Protection
  7. Record Keeping
  8. Transfer Limitation
  9. Contact
  10. Other Rights


1 – Consent

The DPL prohibits Priora from collecting, using or disclosing an individual’s Personal Data unless the individual gives written consent for the collection, use or disclosure of his Personal Data or such collection, use or disclosure is necessary for specific reasons set out in the DPL or by law. By providing the Personal Data, you consent to us using and disclosing your Personal Data as set forth in this Privacy Policy Statement or by law.

This consent remains valid until you change or revoke it by providing written notice to the responsible person for data protection compliance at Priora (info@priora.com, reference “Data Protection”). Please note that if you withdraw your consent to any or all use your Personal Data, depending on the nature of your request, we may not be able to continue to provide our services to you or administer any contractual relationship in place.

2 – Purpose Limitation

The DPL limits the purposes for which and the extent to which a company may collect, use or disclose Personal Data. As mentioned above, the nature of the business of Priora does not foreseen to collect Personal Data. However, Personal Data such as e-mail address or phone numbers might be exchanged to be able to interact and thus to provide our services to you.

Priora will only collect Personal Data that is necessary to interact with you and to provide services as agreed.

3 – Notification

When we collect Personal Data directly from you, we will inform you of the purpose of the collection, use or disclosure by reference to this Privacy Policy or individual agreement, if any, concluded with you unless it is clear from the business context why we collect your Personal Data (e.g. to be able to communicate with you). We will only collect Personal Data by lawful and fair means. Personal Data is collected to be able to interact with you (e-mail address and phone number). Personal Data might also be processed when you use or visit our website and submit other information (including Personal Data) to us.

4 – Access and Correction

Under the DPL, you have the right to request:

Access to your Personal Data in our possession;
Information about the ways the Personal Data has been used or disclosed by us within a year preceding the date of your request.

Subject to certain exemptions under the DPL, we will grant access to and correct Personal Data as requested by you. In case we hold Personal Data about you and you are able to demonstrate that the Personal Data is not accurate, complete and up to date, we will take reasonable steps to correct your Personal Data so that it is accurate, complete and up to date.

Your request to access or correct your Personal Data will be dealt with as soon as reasonably possible from the time the access request is received. If we are unable to respond within 30 days, we will inform you within 15 days by when we will be able to respond.

5 – Accuracy

We will take practical steps to ensure that the Personal Data we collect, use or disclose is accurate, complete and up to date considering the purpose for which the Personal Data is or is to be used.

6 – Protection

We will take all practical steps to ensure that Personal Data we hold is protected against unauthorized or accidental access, processing, modification, or other use. We adopt clear security procedures.

Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at Priora (info@priora.com, reference “Data Protection”).

7 – Record Keeping – Retention

We will retain your Personal Data for only as long as necessary to serve the purposes set out in this Privacy Policy in compliance with all statutory and regulatory requirements in DIFC concerning the retention of Personal Data. We will take reasonable steps to destroy or permanently anonymize your Personal Data if it is no longer needed for such purposes.

8 – Transfer Limitation

Due to the international nature of our business, for the purposes set out in this Privacy Policy, we may transfer Personal Data to parties located in other countries that may have a different data protection regime compared to the one applicable in DIFC. Personal Data collected in DIFC by Priora may be transferred to parties which may be located in DIFC or outside DIFC, such as to other Priora group entities, lawyers, auditors, service providers and business partners; governmental or regulatory authorities in order to carry out the purposes, or directly related purposes, for which the Personal Data was collected. Where such a transfer is performed, Priora will take appropriate steps to ensure that the recipient of Personal Data is bound by legally enforceable obligations to provide a standard of protection to that Personal Data that is comparable to that of the DPL.

9 – Contact

If you would like to access a copy of your Personal Data, correct or update your Personal Data, or have a complaint or want more information about how Priora manages your Personal Data, please contact us at info@priora.com (reference “Data Protection”).

10 – Other Rights

Priora aims to comply with the requirements of the DPL and respects your choices.

If you have previously agreed that we can interact with you via phone and / or e-mail (please refer to section 1) we will continue to do so until you withdraw your consent.

Examples of the Personal Data which Priora may collect, use and/or disclose in order to interact with you to provide our services or potential services include (extract): your name, contact details and transaction patterns.

Depending on the service concerned, your Personal Data may be disclosed to: Priora group companies; third party financial institutions, insurers, securities and investment services providers; service providers who have been contracted by Priora to provide Priora with administrative, financial, research, professional or other services or anyone authorised by you.

THIS PRIVACY POLICY MAY BE MODIFIED AND AMENDED FROM TIME TO TIME.

October 1st, 2020