This Privacy Policy applies to all websites and mobile applications operated by 91.community and its parent company, Ninety-One 91 Ltd ("we," "us," or "our"). The company is a limited company registered with the license number 07010414 and headquartered at RAK DAO Business Centre, Al Rifaa, Sheikh Mohammed Bin Zayed Road, Ras Al Khaimah, United Arab Emirates.This Privacy Policy describes how we collect, use, store, disclose, and process information that we obtain from you through our platforms. These include websites and mobile applications linking to or posting this Privacy Policy (each a "Platform"), and any investment advisory service we provide (collectively, the "Products or Services"). Additionally, this policy covers information provided to us through non-Platform interactions, such as email.

Please read this Privacy Policy carefully before accessing any of our Platforms or using our Products and Services. By accessing our Platforms or using our Products and Services, you agree to the terms of this Privacy Policy and our Terms of Service.Our Products and Services are only available to individuals who are at least 18 years old. If you are under 18, you may not use our Products and Services.Your information is protected in accordance with the United Arab Emirates Federal Law No. 45 of 2021 (UAE Data Protection Law).

1. Information
We CollectWe collect various types of information when you use our Platforms and Services:Information You Provide You provide information directly to us when you register on the website, subscribe to a newsletter, respond to surveys, or contact us. This may include:Contact Information: Your name, email address, phone number, and any message content you provide.Account Information: If you apply to open an account, we collect additional details such as your birth date, Social Security Number, financial information, and other relevant details for account management.Geolocation Information: In limited circumstances, we may request your location to provide geo-specific services.Information Collected AutomaticallyActivity Information: We record information like your Internet Service Provider (ISP), IP address, the pages you visit, and the duration of your visit.Cookies and Similar Technologies: We use cookies to enhance your experience and collect data on how you interact with our Platforms. You can control cookies via your browser settings.SMS MessagesWe may send transactional or marketing SMS text messages with your consent. You can opt out at any time by texting “STOP.”

2. How We Use and Share Information
We use and share your personal information to:Onboard you as a customer and verify your identity (AML, KYC checks, etc.).Provide and improve the Products and Services.Communicate with you regarding your account or inquiries.Fulfill legal obligations and safeguard our business.Share aggregated, anonymous data for research and marketing purposes.We take measures to protect your privacy and only share information with third parties under legal, professional, or contractual obligations.

3. Data Retention
We retain your information as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce agreements.

4. Security Measures
We implement reasonable technical, physical, and organizational security measures to protect your personal information. However, no system is entirely secure, and we cannot guarantee complete protection against unauthorized access or breaches.

5. Third-Party Links and Services
Our Platforms may contain links to third-party websites, whose privacy practices differ from ours. We are not responsible for the information practices of these third-party sites, and you should review their policies before submitting personal data.

6. Updating or Correcting Your Information
You can update or delete your personal information at any time by contacting us at legal@91.community.com.

7. Policy on Minors
Our Products and Services are not designed for individuals under 18. If we become aware that a minor has provided us with personal information, we will use reasonable efforts to delete the data from our systems.

8. Changes to This Policy
We reserve the right to update this Privacy Policy at any time. The date of the latest update will be posted at the top of the policy, and continued use of our Platforms or Services constitutes acceptance of any modifications.

9. International Users
Our Platforms and servers operate in the United Arab Emirates. By using our Services, you consent to the transfer and processing of your information as per UAE laws.Contact UsIf you have any questions regarding this Privacy Policy or our Products and Services, please contact us at legal@91.community.com.