Privacy Policy

---

1. Introduction

Keystone Financial Solutions (DIFC) Limited (“Keystone”, “we”, “our”) is committed to protecting the confidentiality and security of personal and financial information entrusted to us by our clients.

This Privacy Policy explains how we collect, use, store, and protect information in connection with our regulated investment and custody services.

2. Information We Collect

In the course of providing regulated financial services, we may collect and process the following categories of information:

• Identification and verification information (including KYC and AML documentation)
• Contact and corporate information
• Financial, transactional, and custody-related data
• Regulatory, compliance, and reporting information

We collect information only where it is necessary, lawful, and proportionate to the services we provide.

3. Purpose of Use

Client information is used strictly for the purposes of:

• Providing regulated investment and custody services
• Safeguarding and administering client assets
• Meeting legal, regulatory, and supervisory obligations
• Risk management, compliance, and audit requirements

We do not use client information for marketing to third parties.

4. Confidentiality & Data Protection

Client information is treated as confidential and protected through:

• Controlled access and internal authorisation procedures
• Secure systems and data storage arrangements
• Segregation of client data from proprietary information

We take reasonable technical and organisational measures to prevent unauthorised access, loss, or misuse of information.

5. Disclosure of Information

We may disclose client information only where required or permitted by law, including to:

• Regulators and supervisory authorities
• External auditors, legal advisors, and compliance service providers
• Custodians, counterparties, or service providers involved in delivering our services

All disclosures are made on a need-to-know and confidentiality-bound basis.

6. Data Retention

Client information is retained only for as long as required to:

• Fulfil contractual and regulatory obligations
• Comply with applicable laws and DFSA requirements

Once retention periods expire, information is securely deleted or anonymised.

7. Client Rights

Clients may request access to or correction of their personal information, subject to applicable legal and regulatory limitations.

8. Updates to This Policy

This Privacy Policy may be updated from time to time to reflect regulatory or operational changes. The latest version will always be available on our website.

9. Contact

For privacy-related enquiries, please contact:

Keystone Financial Solutions (DIFC) Limited

📧 hasan@keystone-investor.com