Privacy Policy
Last updated: May 8, 2026
1. Introduction
NEOM Pay ("we", "us", "our") respects your privacy and is committed to protecting your personal data in accordance with the UAE Personal Data Protection Law (PDPL) and the DIFC Data Protection Law.
2. Information We Collect
We collect (a) identity and contact data (name, email, location, organization), (b) investment profile data (capacity range, accreditation status), (c) technical data (IP address, browser type, device identifiers), and (d) communications you send to us.
3. How We Use Your Information
Your information is used to: evaluate investor suitability, fulfil regulatory KYC/AML obligations, provide investor relations, send fund updates, improve the Platform, and respond to inquiries.
4. Legal Basis for Processing
We process personal data based on (a) your consent, (b) the performance of a contract, (c) compliance with legal obligations, and (d) our legitimate interests in operating a regulated investment vehicle.
5. Data Sharing
We share data only with (a) regulated service providers (custodians, auditors, legal counsel), (b) deployment partners such as FarmersMarket.asia and The Climate Company strictly for operational reporting, and (c) competent authorities where required by law. We do not sell personal data.
6. International Transfers
Where data is transferred outside the UAE, we ensure adequate safeguards through standard contractual clauses or equivalent mechanisms recognized under DIFC and UAE PDPL.
7. Data Retention
We retain personal data for as long as necessary to fulfil the purposes outlined here and to comply with regulatory record-keeping obligations (typically 7 years post-relationship).
8. Your Rights
Subject to applicable law, you may request access, rectification, erasure, restriction, or portability of your data, and object to certain processing. To exercise your rights, contact us at unifoxdigital@gmail.com.
9. Security
We employ administrative, technical, and physical safeguards including TLS encryption in transit, encryption at rest, role-based access control, and periodic security reviews.
10. Cookies
The Platform uses essential cookies for session management and analytics cookies to understand usage patterns. You may disable non-essential cookies through your browser settings.
11. Changes to This Policy
We may update this Privacy Policy periodically. Material changes will be communicated via the Platform or email.
12. Contact
Data Protection Officer — NEOM Pay, Prime Tower, Burj Khalifa Blvd, Business Bay, Dubai, UAE. Email: unifoxdigital@gmail.com.