ZENGAGE

Privacy Policy

Zengage Capital

Introduction

Zengage Capital (“Zengage,” “we,” “our,” or “us”) is committed to protecting and respecting your
privacy and handling your personal data in a transparent, secure, and lawful manner.
This Privacy Policy describes how we collect, use, process, store, transfer, and protect personal
information obtained through https://zengagecapital.com (the “Website”), our investment
activities, investor onboarding processes, and related communications.
This Policy is designed to align with internationally recognized data protection standards,
including the UAE Data Protection Law, DIFC Data Protection Law, GDPR (where applicable), and
other relevant privacy regulations.

Categories of Information We Collect

We may collect and process the following categories of information
A. Information You Provide Voluntarily
• Full name
• Email address
• Telephone number
• Professional title and employer
• Company details
• Pitch decks, financial models, projections
• Investment preferences
• KYC/AML documentation (where applicable)
B. Automatically Collected Information
• IP address
• Browser type and device identifiers• Website usage data
• Cookies and tracking technologies
C. Investor Due Diligence Information
Where applicable, we may collect:
• Proof of identity
• Proof of address
• Source of funds documentation
• Accredited/Professional Investor confirmations
This information is collected to comply with anti-money laundering (AML), counter-terrorist
financing (CTF), sanctions screening, and regulatory obligations.

Lawful Basis for Processing

We process personal data based on:
• Legitimate business interests
• Contractual necessity
• Legal and regulatory obligations
• Consent (where required)

How We Use Your Information

We use personal information to:
• Evaluate investment opportunities
• Conduct due diligence
• Communicate with prospective investors and founders
• Provide consultancy, advisory, and educational services
• Comply with regulatory requirements
• Prevent fraud and financial crime• Improve Website functionality
• Conduct internal analytics and risk management
We do not sell personal data.

Disclosure of Information

We may disclose personal data to:
• Regulatory authorities
• Professional advisers (legal, compliance, auditors)
• Service providers (IT, hosting, CRM systems)
• Financial institutions
• Counterparties in transactions
• Government or law enforcement authorities
All third-party processors are subject to contractual confidentiality and data protection
obligations.

International Transfers

Given the global nature of our operations, personal data may be transferred across jurisdictions.
Where required, we implement appropriate safeguards including:
• Standard Contractual Clauses
• Regulatory-approved transfer mechanisms
• Adequate jurisdiction determinations

Data Retention

We retain personal data only as long as necessary for:
• Regulatory compliance
• Legal record-keeping requirements
• Dispute resolution• Risk management purposes
Investor due diligence records may be retained for periods required under applicable AML
regulations.

Data Security

We implement administrative, technical, and physical safeguards including:
• Encrypted data transmission
• Secure cloud infrastructure
• Restricted access controls
• Ongoing cybersecurity monitoring
However, no system is completely secure, and we cannot guarantee absolute security..

Your Rights

Subject to applicable law, you may have the right to:
• Access your data
• Correct inaccuracies
• Request deletion
• Restrict processing
• Withdraw consent
• Lodge a complaint with a supervisory authority
Requests may be directed to: invest@zengagecapital.com

Cookies

We use cookies and similar technologies for:
• Website functionality
• Performance analytics• Security monitoring
You may disable cookies via browser settings.