Personal Data Protection
Updated Date: Jan 2024
Effective Date: Nov 2023
Sahm Capital Financial Company ("we", "us" or "Sahm Capital") respects your privacy and is committed to protecting the privacy and security of your Personal Data (as defined below). This Privacy Policy describes how and when we collect, use, process and share your information across our websites, mobile applications (apps), SMS, APIs, email notifications, buttons, and our other covered services to which this Privacy Policy applies (collectively, the "Services").
This Privacy Policy applies to all Personal Data we collect about you when you access or use our Services. The contents of this Privacy Policy, as outlined below, form an integral part of the conditions for accessing or using the Services. Sahm Capital will not collect your Personal Data unless you agree to provide us with such information. By accessing or using the Services, you thereby confirm that you have read, understood, and agreed to our collection, storage, use, and disclosure of your Personal Data in accordance with this Privacy Policy.
Our Services are not intended for any natural person under the age of eighteen (18) years and we do not knowingly collect Personal Data relating to any natural person under the age of eighteen (18) years.
It is important that you read this Privacy Policy carefully together with the general terms and conditions of use available at https://www.sahmcapital.com/, provided by Sahm Capital so that you are fully aware of how and why we are using your Personal Data.
This Privacy Policy is divided into the following sub-sections:
- Personal Data We Collect and How We Collect it
- Why We Collect and How We Use Personal Data
- Cookies and Similar Technologies
- How We Share Personal Data
- How We Transfer Personal Data
- How We Secure Personal Data
- Retention of Personal Data
- How to Access and Control Your Personal Data
- Contacts, Notices, and Revisions
1. Personal Data We Collect and How We Collect it
We may collect your Personal Data about you in the course of providing Services to you.
"Personal Data" means every statement - whatever its source or form - that would lead to the identification of an individual species, or make it possible to identify him directly or indirectly, including name, personal identification number, addresses, contact numbers, and license numbers records, personal property, bank account and credit card numbers, still or moving photos of an individual, and other data of a personal nature. It does not include data where the identity has been removed (anonymous data).
Here are the types of Personal Data we may collect about you:
1.1 Personal Data You Provide
We collect Personal Data you provide (as described below) when you access or use our Services or otherwise engage or communicate with us. For example, when you choose to create an investment account on our apps with your email address or mobile phone number, you will be asked to fill in a 'Know Your Client Form' under applicable laws and regulations, through which we will collect identity data, contact data and financial data, each of which are detailed as follows:
Identity Data: full name, date of birth, ID numbers/passport number., marital status, educational level, citizenship, biometric identifiers, and other data on government-issued identification documents;
Contact Data: email address, mailing address, office location, residential address and telephone number;
Financial Data: bank account and payment card details, and information about your income, account balances, financial transaction history, debit card numbers, credit history, tax information, and credit scores;
Profile Data: username, your employment information, your knowledge/risk assessment results, your interests, preferences, feedback, and survey responses;
Stored Data: device camera and photo album when you upload photos or device calendar in your mobile device with your permission when you want to add alerts or economic data to your calendars (please note we only collect this kind of data with your permission); and
Additional Data You Provide: via focus groups, survey responses, contests/sweepstakes, customer support, or any other mean.
1.2 Personal Data We Collect Automatically
When you access or use our Services, we also collect certain Personal Data automatically, which are as follows:
Usage Data: We collect information about your activity on our Services, which includes device identifiers (i.e., IP address or mobile device identifiers), pages or features you use, time and date of access, and other similar usage information.
Transactional Data: When you receive, submit, or complete a transaction via platforms offered by Sahm Capital, we collect data about the transaction, such as transaction amount, type and nature of the transaction, and time and date of the transaction.
Data Collected Through Cookies and Similar Technologies: We also use technologies, including cookies and similar technologies, to automatically collect certain types of usage and device data when you access or use our Services or interact with others in connection with the Services. The data collected through these technologies includes your IP address, browser type, internet service provider, platform type, device type, operating system, date and time stamp, a unique device or account ID, usage data and other similar information.
1.3 Information We Collect from Other Sources
We also obtain Personal Data from other sources as described below:
Vendors and Business Partners: Subject to your prior written consent, we may collect information about you from companies that we do business with, such as name, contact data, inferences about your preferences and attributes, as well as inferred fraud risk, from identity verification and fraud prevention partners.
Connected Services: Subject to your prior written consent, if you link, connect, or log in to your account with Sahm Capital with a third-party service provider (e.g., Google, Apple), the third-party service provider may send us information such as your profile information from its service. This information varies and is controlled by that service or as authorised by you via your privacy settings at that service.
Publicly Available Data: We collect content that you share publicly in connection with our Services, including contact information, your interactions with our social media platforms, and other information from publicly available sources, such as public websites.
Advertising Data: We collect information in connection with our advertisement campaigns that surface on other platforms, such as the advertisements you clicked on and other interactions with our advertisements. Please note that we also collect, use and share aggregated data for any purpose, such as statistical or demographic data, which may be derived from your Personal Data but is not considered Personal Data since it does not directly or indirectly reveal your identity under the applicable laws and regulations. In no event will we collect any Personal Data about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, and genetic characteristics, unless required by applicable laws and regulations. Furthermore, we do not collect any information about criminal convictions and offenses.
2. Why We Collect and How We Use Personal Data
To provide our Services: We use your Personal Data to provide our Services to you, including setting up and maintaining your account, processing transactions on your instruction, providing customer support and completing payments.
To measure and improve our Services: By monitoring and analyzing how users interact with our Services to help us measure, understand and forecast users’ performance and preferences to improve and develop our products and services; by detecting security incidents to fix problems with our Services;
To market and promote our Services: We may use your Personal Data to market and promote our Services. We might send you marketing information about the Services and other information which we believe may be of interest to you or be relevant to you, to promote our products and services.
To Prevent Fraud and Abuse and Credit Risks: By detecting and protecting against malicious, deceptive, fraudulent, or illegal activity to protect the security of our clients, Sahm Capital and others.
To Comply with Legal Obligations: In certain cases, we have a legal obligation to collect, use, process or retain your Personal Data. For example, we are required to collect your identity and financial information when you access our Services, in accordance with the laws and regulations of the Kingdom of Saudi Arabia.
To communicate with you: By different channels to communicate with you in relation to our Services, such as texting you to verify your account, sharing information with you we think will be of interest to you, emailing you to ask for your feedback or respond to your requests. If you do not want to hear from us, you can opt out of communications at any time.
3. Cookies and Similar Technologies
Sahm Capital may use cookies and similar technologies to support the operation of our Services. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a device of a visitor (for example, a computer, tablet, or mobile phone). Cookies help us to collect data about users of our Services, including date and time of visits, pages viewed, and amount of time spent using our Services, or general information about the device used to access our Services. For 'cookies' in our Services, you can manage 'cookies' in the content settings as your preference. At the same time, you can enable the "Do Not Track" feature so that you will not be tracked by cookies.
4. How We Share Personal Data
Data about our clients is an important part of our business and we are not in the business of selling Personal Data of our clients to others, nor do we ever do so. We share Personal Data only as described below:
Share with Third-Party Service Providers: We may engage third-party service providers to perform functions and provide services. For example, we use a variety of third-party services to help us understand and improve the use of our Services. Subject to your prior written consent, we may share your Personal Data with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your Personal Data only on our behalf and pursuant to our instructions. These third-party service providers have access to Personal Data needed to perform their functions but may not use it for other purposes. Further, they must process that data in accordance with this Privacy Policy and as permitted by applicable data protection laws and regulations.
Share with Affiliates: Subject to your prior written consent, we may share Personal Data about you with various Sahm Capital corporate affiliates including internal service providers, which perform software development services or, data processing and analysing services, subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the affiliates use your Personal Data only on our behalf and pursuant to our instructions. Additionally, if you interact with Sahm Capital directly as an individual investor (including joint account holders), we may exchange certain information for their use in marketing products and services as allowed by applicable law.
Protection of Sahm Capital and Others: Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose your Personal Data if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our clients’ rights or property. However, nothing in this Privacy Policy is intended to limit any legal defences or objections that you may have to a third party’s, including a request to disclose your information by any governmental entity.
Share Your Public Data: We may share or disclose your public data, such as your public user profile information, and public comments.
5. How We Transfer Personal Data
We will not transfer Personal Data outside the Kingdom of Saudi Arabia or disclose it to a party outside the Kingdom of Saudi Arabia unless permitted by the applicable laws and regulations.
Subject to the applicable laws and regulations, your Personal Data, excluding sensitive data, may be transferred to the country or region where you use our product and services or where our affiliate locates with your authorisation and consent, and such Personal Data will have a fully compliant level of protection outside the Kingdom of Saudi Arabia.
6. How We Secure Personal Data
We have put in place appropriate security measures to limit the possibility of your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and third-party service providers who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Retention of Personal Data
We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. How to Access and Control Your Personal Data
To the extent required by the applicable laws, you may have the right to: (i) access to your Personal Data we maintain about you, without prejudice to the provisions of the credit information system regarding financial compensation, and without prejudice to the provisions of the Kingdom of Saudi Arabia's Personal Data Protection law (as may be amended, restated or supplemented from time to time) (the “PDPL”); (ii) request correction, completion or updating of your Personal Data held by us; (iii) request destruction of your Personal Data available to us, without prejudice to the provisions of the PDPL; and (iv) other rights stipulated in the PDPL or other applicable laws. You hereby acknowledge and agree that we may decline your request if we have reasonable grounds to believe that your request is fraudulent, unfeasible, or may jeopardize others’ legitimate rights, or violate the applicable laws.
9. Contacts, Notices, and Revisions
If you have any questions, comments or suggestions regarding this Privacy Policy or the collection or use of Personal Data, please contact us at customerservice@alsahm.com.
We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your Personal Data. If we make any change to this Privacy Policy, at our sole discretion, is material, we will update the policy on our website without a separate notification sent to you. Please pay attention to the most updated version of our Privacy Policy on our website, at https://www.sahmcapital.com/. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.
