Privacy Policy

1. Introduction

Dulair Private Family Office (“we”, “our”, or “us”) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or engage with our services.

We are registered in England and Wales and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

We may collect the following types of information:

• Personal Identification Information: Name, email address, phone number, postal address
• Financial Information: Investment preferences, net worth declarations (for investor certification purposes)
• Technical Data: IP address, browser type, device information, pages visited
• Communication Data: Records of correspondence and enquiries

3. How We Use Your Information

We use the information we collect for the following purposes:

• To provide and maintain our investment advisory services
• To process investor certifications in compliance with FCA regulations
• To respond to your enquiries and provide customer support
• To send you relevant investment opportunities and market insights (with your consent)
• To comply with legal and regulatory obligations
• To improve our website and services

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Consent: Where you have given explicit consent for specific purposes
• Contract: Where processing is necessary for the performance of a contract
• Legal Obligation: Where we are required to comply with regulatory requirements
• Legitimate Interests: Where processing is necessary for our legitimate business interests

5. Data Sharing and Disclosure

We do not sell your personal information. We may share your data with:

• Professional advisors (lawyers, accountants) bound by confidentiality obligations
• Regulatory authorities (such as the FCA) when required by law
• Service providers who assist in our operations under strict data protection agreements
• Third parties in connection with a business transfer or merger

6. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. This includes encryption, secure servers, and access controls. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. For investor certification records, we retain data for a minimum of 5 years as required by FCA regulations.

8. Your Rights

Under UK GDPR, you have the following rights:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data (subject to legal obligations)
• Right to Restrict Processing: Request limitation of how we use your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time

9. Cookies

Our website uses cookies to enhance your browsing experience. Cookies are small text files stored on your device. We use essential cookies for website functionality and analytics cookies to understand how visitors interact with our site. You can manage cookie preferences through your browser settings.

10. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:

11. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically to stay informed about how we protect your information.