Privacy notice

This notice covers personal data handled through this website: material submitted through the opportunity form, correspondence sent to the published addresses, and the technical records created when a page is served.

It does not cover any separate process that would follow a formal investment or subscription. Those are governed by their own documents.

The controller, and the data-protection law that applies, follow from the fund’s legal entity and place of establishment. Both are published here once final.

Four categories, and nothing beyond them:

• Application form fields. The details entered when an opportunity is submitted — name, email address, company, location, sector, stage and the written description of the opportunity.
• Uploaded documents. Decks, summaries or other files attached to a submission, together with whatever personal data those files happen to contain.
• Email correspondence. Messages sent to the published addresses, including the address they came from, any attachments and the routing headers.
• Technical records. The request data generated by serving a page — IP address, user agent, referring page, timestamp — held in infrastructure logs by the hosting provider for operation and security.

No special category data — health, biometrics, religious or political views and the like — is requested. Please do not include it in a submission.

This is a static site. At the time of writing it sets no advertising cookies, no cross-site tracking cookies and no third-party marketing pixels, and it does not build visitor profiles.

Where aggregate traffic measurement is in use, it is limited to page-level counts and referral sources and is not used to identify an individual visitor.

• To read and assess a submitted opportunity.
• To reply to the person who sent it, and to continue that correspondence.
• To keep an internal record of what was submitted, when, and what was decided.
• To operate, secure and debug the website, and to prevent abuse of the form.
• To meet record-keeping, anti-money-laundering, sanctions-screening and other legal or regulatory obligations that apply.

Personal data collected through this site is not sold, not rented, and not used for advertising or for automated decision-making that produces a legal or similarly significant effect.

Where the EU or UK General Data Protection Regulation applies, processing rests on one of the following:

• Legitimate interests — assessing opportunities sent unsolicited, keeping a record of decisions, and securing the site. These interests are balanced against the rights of the individual concerned.
• Steps prior to a contract — where material is exchanged at the sender’s request with a view to a possible transaction.
• Consent — where it is asked for, for example to stay in contact about future opportunities. Consent can be withdrawn at any time, without affecting anything done before withdrawal.
• Legal obligation — where retention or disclosure is required by law.

Where the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) applies, equivalent bases are relied on, and consent is obtained where that law requires it. A fund established in a financial free zone may instead be subject to that zone’s own data-protection law.

Material is kept for as long as it is needed for the purpose it was provided for, and then for any period a record-keeping or regulatory rule requires. Where no such rule applies, a submission that is not taken forward is held only as long as needed to maintain a record of the decision, and uploaded files are deleted ahead of the correspondence that refers to them.

Infrastructure logs are held on the hosting provider’s standard retention cycle.

Personal data is disclosed only in these circumstances:

• Service providers. Categories used to run this site and the intake process: website hosting and content delivery, form processing, file storage, transactional email delivery, business email and calendaring, and security or spam-filtering services. Each acts on instructions under written terms.
• Professional advisers. Legal, accounting and compliance advisers, where the disclosure is necessary for advice.
• Legal requirement. Regulators, law enforcement or courts, where disclosure is required by law or necessary to establish or defend a legal claim.

Personal data is not shared with any other party.

The fund keeps offices in Dubai, Scottsdale, and Laramie, so material submitted through this site may be accessed in the United Arab Emirates and the United States, and may be stored on infrastructure in other countries.

Where a transfer leaves a jurisdiction that restricts onward transfer, it is made on a recognized transfer mechanism — an adequacy decision, standard contractual clauses, or another basis the applicable law permits.

Traffic to and from this site is encrypted in transit. Submitted material is held in access-controlled systems, and access is limited to the people who need it to assess a submission or to operate the site.

No method of transmission or storage is completely secure, and no guarantee of absolute security is given. Do not send material through this site that is too sensitive to send by email.

Subject to the law that applies, an individual whose personal data is held may ask to:

• Confirm what is held, and obtain a copy of it.
• Correct data that is inaccurate or incomplete.
• Have data erased where there is no continuing basis to keep it.
• Restrict processing, or object to it, including processing that rests on legitimate interests.
• Receive data provided by them in a portable, machine-readable form.
• Withdraw consent, where consent was the basis for processing.
• Complain to the supervisory authority with jurisdiction.

Requests are handled without charge unless the law permits otherwise, and identity is verified before data is released. The supervisory authority to which a complaint can be made depends on where the fund is established.

This site is directed at businesses and professional contacts. It is not directed at children, and personal data is not knowingly collected from them. Where such data is identified it is deleted.

This notice may be amended. The version published on this page is the version that applies. It should be read together with the terms of use.

A data-protection request, or a question about anything in this notice, can be sent to the addresses below. Marking it “data request” helps it reach the right place.

Questions about this notice or your personal data can be sent to [email protected]. Material relating to a submitted opportunity should go to [email protected].