Privacy Policy

1. Introduction

Tahsin Investments & Co Limited (License No. MC 12779) ("TIC," the "Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website https://tahsininvestmentsco.com/ (the "Website") and use our Services. This policy applies to all users and Clients worldwide, regardless of geographic location.

This Privacy Policy is governed by and should be read in conjunction with the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021, as amended) ("PDPL") and any implementing regulations thereunder.

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

2. Information We Collect

We may collect information about you in a variety of ways. The information we may collect on the Website includes:

• Personal Data: Personally identifiable information, such as your name, email address, telephone number, date of birth, nationality, residential address, and government-issued identification, that you voluntarily provide to us when you book a consultation, register for services, or contact us.
• Derivative Data: Information our servers automatically collect when you access the Website, such as your IP address, browser type, operating system, device information, access times, pages viewed, and referring URL.
• Trading Activity Data: Performance data, trading patterns, behavioral analytics, and aggregated statistics derived from your use of our AI Copy Trading, PAMM, or AI Trading services, collected through our systems or third-party integrations (e.g., MyfxBook, brokerage APIs).
• Third-Party Integration Data: Information received from third-party service providers, brokerage platforms, and analytics tools that you have authorized to share data with us.

We do not collect or store any of your financial data directly, as all financial transactions are handled through your own Third-Party Brokerage account.

3. Lawful Basis for Processing

We process your personal data based on one or more of the following lawful bases:

• Consent: We process your data based on your explicit consent, which you provide by using our Services and can withdraw at any time.
• Contractual Necessity: We process data that is necessary to fulfill our contractual obligations to you.
• Legal Obligation: We may process your data to comply with applicable laws and regulations, including AML/KYC requirements.
• Legitimate Interest: We may process your data for our legitimate business interests, including analytics, fraud prevention, service improvement, and security, provided such interests are not overridden by your data protection rights.

4. How We Use Your Information

We use the information we collect to:

• Schedule and manage your consultation and onboarding.
• Provide, operate, and maintain our Services.
• Communicate with you about our services, updates, and promotional materials (with your consent).
• Monitor and analyze usage to improve our Website and Services.
• Develop, improve, and train our AI and algorithmic trading models using anonymized and aggregated data.
• Generate anonymized and aggregated performance statistics for marketing, reporting, and investor relations purposes.
• Detect, prevent, and address technical issues, fraud, and security threats.
• Comply with legal and regulatory obligations, including AML/KYC requirements.
• Respond to legal requests and prevent harm.

5. Data Retention

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, or as required to comply with our legal obligations. Specific retention periods are as follows:

• Active Client Data: Retained for the duration of the Client relationship plus seven (7) years following termination of the Client Agreement, in accordance with applicable financial record-keeping requirements.
• Marketing and Communication Data: Retained until you withdraw your consent or unsubscribe, and for a maximum of two (2) years following your last interaction with us.
• Website Usage Data: Retained for a maximum of twenty-four (24) months from the date of collection.
• Legal and Compliance Data: Retained for the period required by applicable law, which may exceed the periods stated above.

When your personal data is no longer needed, it will be securely deleted or anonymized.

6. Disclosure of Your Information

We do not sell, rent, or trade your personal information. We may share your information with:

• Third-Party Service Providers: Such as MyfxBook for performance verification, analytics providers, email service providers, and hosting providers who perform services on our behalf. These providers are contractually obligated to protect your data and may only use it for the purposes specified by TIC.
• Legal Authorities: If required by law or to protect our rights and the safety of others, including in response to court orders, subpoenas, or regulatory requests.
• Business Transactions: In the event of a merger, acquisition, reorganization, sale of assets, joint venture, or due diligence process, your information may be disclosed to potential acquirers, investors, partners, or their advisors, subject to appropriate confidentiality obligations.
• Professional Advisors: Including lawyers, auditors, and accountants, in the context of the professional services they render to us.

7. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, we will notify the relevant data protection authority and the affected individuals within seventy-two (72) hours of becoming aware of the breach, in accordance with applicable laws, such as the UAE Personal Data Protection Law (PDPL).

Notification will be delivered via email to the address on file and, where appropriate, by posting a notice on our Website.

8. Cross-Border Data Transfers

Your information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ. We acknowledge that some of these jurisdictions may not have equivalent data protection laws.

By using our Services, you consent to such transfers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, including implementing appropriate safeguards such as Standard Contractual Clauses, encryption in transit and at rest, access controls, and data processing agreements with receiving parties.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track the activity on our Website and hold certain information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website.

Our cookie usage includes:

• Session Cookies: To operate our Service.
• Preference Cookies: To remember your preferences and various settings.
• Security Cookies: For security purposes.
• Analytics Cookies: Including Google Analytics, to understand how visitors interact with our Website and to improve user experience.

A cookie consent banner is displayed upon your first visit to the Website. You may manage your cookie preferences at any time through your browser settings or via our cookie consent mechanism.

10. Your Data Protection Rights

Depending on your jurisdiction, you may have certain data protection rights under applicable laws, including the UAE PDPL, GDPR, or other local data protection legislation. These rights may include:

• The right to access, update, or delete the information we have on you.
• The right of rectification.
• The right to object to processing.
• The right of restriction of processing.
• The right to data portability.
• The right to withdraw consent.

To exercise any of these rights, please contact us using the contact information provided below. We will respond to your request within thirty (30) days of receipt. We may charge a reasonable fee for manifestly unfounded, excessive, or repetitive requests.

11. Automated Decision-Making

Our Services utilize AI and algorithmic systems that may process your data to generate trading ideas, manage PAMM allocations, and provide personalized service recommendations. These automated processes do not make decisions with legal or similarly significant effects on you without human oversight.

You have the right to request information about the logic involved in any automated processing that affects you, and to request human review of any significant automated decision.

12. Children's Privacy

Our Services are not directed at anyone under the age of eighteen (18). We do not knowingly collect personal data from minors. If we become aware that we have collected personal data from a minor without appropriate consent, we will take steps to delete such information promptly.

13. Links to Other Websites

Our Website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page, updating the "Last Updated" date and version number, and, for material changes, by sending an email notification to the address on file.

15. Data Protection Contact

For all data protection inquiries, rights requests, or complaints, please contact: