Privacy Policy
Last Updated: 01/08/2025
1. INTRODUCTION
1.1 NOMAD Multi Family Office FZE ("NOMAD", "we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.nomad-mfo.com (the "Website") or engage our services.
1.2 This Privacy Policy complies with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and, where applicable, the EU General Data Protection Regulation (GDPR) 2016/679.
1.3 By accessing our Website or engaging our services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.
2. DATA CONTROLLER
3. INFORMATION WE COLLECT
3.1 Personal Information Provided Directly
We may collect the following categories of personal information:
Identity Data: full name, title, date of birth, nationality, passport/ID details
Contact Data: residential address, email address, telephone numbers
Financial Data: bank account details, investment portfolio information, assets under management, source of wealth
Tax Data: tax identification numbers, tax residency status
Professional Data: employment details, business interests, directorships
Family Data: family structure, beneficiary information (where relevant)
Technical Data: IP address, browser type, time zone settings, operating system
Usage Data: information about how you use our Website and services
Communication Data: your preferences for receiving communications from us
3.2 Sensitive Personal Information
In certain circumstances, we may process sensitive personal information including:
Health data (for estate planning or insurance purposes)
Criminal convictions data (for anti-money laundering compliance)
Such information is only processed with your explicit consent or where required by law.
3.3 Information from Third Parties
We may receive information about you from:
Private banks and financial institutions
Professional advisers (lawyers, accountants, tax advisers)
Credit reference agencies
Sanctions screening databases
Public sources and registries
4. LEGAL BASIS FOR PROCESSING
4.1 We process your personal information on the following legal bases:
Contract: Processing necessary for the performance of our family office services agreement
Legal Obligation: Processing necessary to comply with legal obligations including anti-money laundering, counter-terrorist financing, and tax reporting requirements
Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, network security, and service improvement
Consent: Where you have provided explicit consent for specific processing activities
Vital Interests: In exceptional circumstances, to protect vital interests
5. HOW WE USE YOUR INFORMATION
5.1 We use your personal information for the following purposes:
Providing family office services including wealth management supervision, estate planning, and administrative support
Conducting know-your-customer (KYC) and anti-money laundering (AML) checks
Complying with legal and regulatory obligations
Managing our relationship with you
Communicating with you about our services
Improving and developing our services
Protecting our legal rights and interests
5.2 We do not sell, rent, or share your personal information with third parties for their marketing purposes.
6. DISCLOSURE OF YOUR INFORMATION
6.1 We may share your personal information with:
Service Providers: private banks, investment managers, legal advisers, accountants
Regulatory Authorities: UAE Central Bank, Dubai authorities, tax authorities, law enforcement
Professional Advisers: lawyers, auditors, insurers
Group Companies: other NOMAD entities for administrative purposes
Third Parties: in connection with a business transfer or restructuring
6.2 We require all third parties to respect the confidentiality of your personal information and to treat it in accordance with applicable law.
7. INTERNATIONAL TRANSFERS
7.1 Your personal information may be transferred to and stored in countries outside the UAE which may have different data protection laws.
7.2 Where we transfer personal data outside the UAE, we ensure appropriate safeguards are in place including:
Adequacy decisions
Standard contractual clauses
Binding corporate rules
Your explicit consent
8. DATA RETENTION
8.1 We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including:
The duration of our business relationship plus 10 years
As required by applicable laws and regulations
To establish, exercise, or defend legal claims
8.2 When determining retention periods, we consider:
Legal and regulatory requirements
Limitation periods for legal claims
Guidelines from regulatory bodies
Our legitimate business needs
9. DATA SECURITY
9.1 We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction, including:
Encryption of data in transit and at rest
Regular security assessments and audits
Access controls and authentication procedures
Staff training and confidentiality agreements
Incident response procedures
10. YOUR RIGHTS
10.1 Under applicable data protection laws, you have the following rights:
Access: Request access to your personal information
Rectification: Request correction of inaccurate information
Erasure: Request deletion of your information (subject to legal obligations)
Restriction: Request restriction of processing
Portability: Request transfer of your information
Objection: Object to certain processing activities
Automated Decision-Making: Rights related to automated decision-making
Consent Withdrawal: Withdraw consent where processing is based on consent
11. COOKIES
11.1 Our Website uses cookies. Please refer to our Cookie Policy for detailed information.
12. CHILDREN'S PRIVACY
12.1 Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children.
13. CHANGES TO THIS POLICY
13.1 We may update this Privacy Policy periodically. The updated version will be indicated by an updated "Last Updated" date.
14. COMPLAINTS
14.1 If you have concerns about our processing of your personal information, please contact us. You also have the right to lodge a complaint with the relevant supervisory authority.