Privacy Policy

Introduction

This Privacy Policy explains how Spera Services (DIFC) Ltd. (“we,” “us,” or “our”), a licensed fund administrator operating within the Dubai International Financial Centre (“DIFC”), collects, uses, discloses, and safeguards the personal data of individuals (“you” or “your”) who interact with our website and online services. It also outlines the rights you have with respect to your personal data under applicable laws, including the DIFC Data Protection Law No. 5 of 2020 (“DIFC Data Protection Law”).

For the purposes of the DIFC Data Protection Law, we act as a ‘Data Controller’ when processing your personal data obtained through our Website. We are committed to ensuring that your privacy is protected and that all personal data we hold is processed lawfully, fairly, and transparently.

Scope of This Policy

This Privacy Policy applies to personal data collected through our website, including any related portals, mobile applications, or online platforms that link to this policy(collectively, the “Website”). It does not cover data we may process in our capacity as a fund administrator in connection with the provision of regulated services to clients, which may be subject to separate data protection provisions and agreements.

Who We Are

Spera DIFC is a licensed fund administrator regulated by the Dubai Financial Services Authority (“DFSA”) and operating within the DIFC. Our registered office is located at:
Spera Services (DIFC) Ltd
Innovation One, DIFC Dubai

For inquiries related to this Privacy Policy or the handling of your personal data, please contact us at: contact@spera.sg

The Personal Data We Collect

We may collect various types of personal data from you, including but not limited to:

  • Identification Information: Name, title, nationality, and date of birth.
  • Contact Information: Email address, mailing address, phone number.
  • Professional Information: Job title, employer, industry, and other professional details when provided.
  • Website Usage Data: IP addresses ,browser type, operating system, referring URLs, pages viewed, links clicked, and other technical information collected through cookies and similar technologies.
  • Communications: Records of communications (e.g., inquiries, requests, or comments you submit via our Website).

How We Collect Your Data

We may obtain your personal data through:

  • Information You Provide Directly: When you contact us, request information, subscribe to updates, submit forms, or otherwise interact with our Website.
  • Automated Technologies: Cookies, web beacons, and other tracking technologies that collect usage information as you navigate our Website.
  • Third Parties: Professional advisors, regulators, or service providers that may share your personal data with us, subject to applicable laws and regulations.

Legal Basis for Processing

We process your personal data only where we have a lawful basis to do so, including:

  • Performance of a Contract: To fulfill obligations under agreements we may have with you or your organization.
  • Legal Obligations: To comply with applicable laws, regulations, and regulatory obligations in the DIFC and other jurisdictions.
  • Legitimate Interests: To operate, improve, and secure our Website; to maintain our internal records; and to respond to inquiries.
  • Consent: Where required by law, we will request your explicit consent before processing certain personal data.

How We Use Your Personal Data

Your personal data may be used for the following purposes:

  • Service Delivery: To respond to your inquiries, provide requested information, and support your use of our services.
  • Website Administration: To maintain, optimize, and secure the Website, ensure its proper functionality, and improve user experience.
  • Regulatory Compliance: To comply with DIFC and DFSA requirements, cooperate with law enforcement, and fulfill other legal obligations.
  • Marketing and Communications: Where lawful and with your consent where required, to send newsletters, updates, and other information that may be of interest to you. You may opt out of such communications at any time.

Disclosure of Your Personal Data

We may share your personal data with:

  • Affiliates and Service Providers: Parties who assist us in operating our Website, conducting our business, or providing services to you (e.g., IT support, data hosting, marketing services).
  • Regulatory Authorities and Law Enforcement: As required by DIFC or other applicable laws, regulations, or legal processes.
  • Professional Advisors: Legal counsel, auditors, and consultants who require such data to provide advice and services to us.
  • Third Parties in Corporate Transactions: In the event of a merger, acquisition, restructuring, or similar transaction involving our business.

We require that any third party handling your personal data implement measures to protect it in accordance with applicable data protection laws and our internal policies.

International Data Transfers

Because of the global nature of the financial services industry, we may transfer your personal data to entities located outside the DIFC. Where we do so, we will ensure that appropriate safeguards are implemented. Such safeguards may include reliance on an adequacy decision issued by the DIFC Commissioner of Data Protection, or the execution of standard contractual clauses or equivalent measures designed to protect your personal data.

Data Retention

We will retain your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or to comply with legal, regulatory, or contractual requirements. Once no longer required, we will securely delete or anonymize your personal data.

Your Rights

Under the DIFC Data Protection Law, you may have the right to:

  • Access: Request a copy of the personal data we hold about you.
  • Rectification: Request that we correct any inaccuracies or incompleteness in your personal data.
  • Erasure: Request the deletion of your personal data under certain circumstances.
  • Restriction: Request that we limit the processing of your personal data.
  • Objection: Object to processing of your personal data based on legitimate interests or direct marketing.
  • Data Portability: Request the transfer of your personal data to another party.
  • Withdrawal of Consent: Where we rely on consent, you may withdraw your consent at any time.

To exercise these rights, please contact us at the details provided above. We will handle your request in accordance with the DIFC Data Protection Law and other applicable regulations.

Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, disclosure, or destruction. Despite our efforts, no data transmission or storage system can be guaranteed to be 100% secure.

Cookies and Similar Technologies

We use cookies and similar technologies to enhance your user experience, analyze site usage, and improve our services. For more information on how we use cookies, the types of cookies we employ, and how to manage your cookie preferences, please see our cookie policy or adjust your browser settings.

Third-Party Links

Our Website may contain links to third-party websites not operated by us. We are not responsible for the privacy practices or content of such websites. We encourage you to review their privacy policies before providing any personal data.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the scope of our services. When we make changes, we will revise the “Last Updated” date at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data handling practices, please contact our Data Protection Officer at:

Email: contact@spera.sg
Mailing Address: Spera Services (DIFC) Ltd, Innovation One, DIFC, Dubai

By using our Website, you acknowledge that you have read and understood this Privacy Policy and agree to our collection, use, and disclosure of your personal data as described herein.