1. Introduction

At Tanami Capital, we recognize the importance of protecting personal data and are committed to processing it responsibly and in compliance with the Personal Data Protection Law (PDPL) of Saudi Arabia as well as the Kingdom of Bahrain. This policy outlines how we collect, use, secure, and disclose personal data.

2. Definitions

Definitions in this policy are in alignment with those provided by the PDPL. Key terms include:

• Personal Data: Data that identifies or could be used to identify an individual.
• Processing: Operations performed on personal data, including but not limited to collection, storage, use, and destruction.
• Data Subject: The individual to whom the personal data relates.
• Controller: Tanami Capital, as the entity that determines the purposes and means of processing personal data.
• Processor: Any entity that processes personal data on behalf of Tanami Capital.

3. Data Collection and Consent

3.1 Collection Methods:

Personal data is collected directly from Data Subjects or through legal and compliant methods, ensuring transparency and adherence to lawful grounds under the PDPL.

3.2 Consent:

Consent is obtained explicitly for the processing of personal data, except in situations where the PDPL allows otherwise, such as for the performance of a contract, compliance with legal obligations, or other scenarios outlined under Article 6 of the PDPL.

4. Purpose of Data Processing

Data is processed for explicitly stated purposes related to our business operations, such as providing services, customer management, improving our offerings, and legal compliance. Changes to the purpose of data processing will be communicated to Data Subjects and handled as per PDPL requirements.

5. Data Security and Confidentiality

5.1 Security Measures:

We implement robust security measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. Measures include encryption, access controls, and secure data handling protocols.

5.2 Breach Notification:

In the event of a data breach, we will notify the competent authority and affected Data Subjects promptly, in accordance with PDPL regulations.

6. Data Subject Rights

Data Subjects have rights under the PDPL, including:

• Access to their personal data.
• Correction and updating of their data.
• Destruction of data when it is no longer necessary.
• Withdrawal of consent at any time.

Requests to exercise these rights can be directed to our designated Data Protection Officer (DPO) at info@tanamicapital.com.

7. Data Retention

Personal data will be retained only for as long as necessary to fulfil the purposes for which it was collected or as required by law. Once the retention period expires, data will be safely destroyed.

8. Transfers and Disclosures

Personal data will not be transferred or disclosed to third parties except under conditions that meet PDPL requirements, such as with consent or for the performance of a contract. All transfers will ensure adequate protection of personal data.

9. Amendments to This Policy

This policy may be updated periodically to reflect changes in legal requirements or our processing practices. Any amendments will be posted on our website and communicated to Data Subjects as necessary.

10. Contact Us

For any questions or concerns regarding this policy or the processing of your personal data, please contact our Data Protection Officer at:

Email: info@tanamicapital.com