McLevin & Neilson Wealth Management Ltd.

Data Protection Policy

Gate Village 10, Level 3 Office # 13, Dubai International Financial Centre, Dubai, United Arab Emirates

Regulated by the Dubai Financial Services Authority (DFSA)

Last Updated: 28^th December, 2023

1. Introduction

McLevin & Neilson Wealth Management Ltd. (“the Company”) is committed to protecting the privacy and confidentiality of personal and sensitive information entrusted to us by our clients, employees, and other stakeholders. This Data Protection Policy outlines our approach to data protection, ensuring compliance with applicable laws and regulations, including the regulations set forth by the Dubai Financial Services Authority (DFSA).

2. Scope

This policy applies to all personal and sensitive information collected, processed, stored, and transmitted by McLevin & Neilson Wealth Management Ltd. in the course of our business operations.

3. Data Collection and Processing

We collect and process personal information for legitimate business purposes, such as client onboarding, account management, and regulatory compliance. The information collected may include, but is not limited to, names, addresses, contact details, financial information, and other relevant data.

4. Data Protection Principles

The company adheres to the following principles in the collection and processing of personal information:

a. Lawfulness, Fairness, and Transparency: Personal information is collected and processed lawfully, fairly, and transparently.

b. Purpose Limitation: Personal information is collected for specified, explicit, and legitimate purposes, and it will not be further processed in a manner incompatible with those purposes.

c. Data Minimization: We only collect and process personal information that is necessary for the purposes for which it is being processed.

d. Accuracy: We take reasonable steps to ensure that personal information is accurate and up-to-date.

e. Storage Limitation: Personal information is kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which it is processed.

f. Integrity and Confidentiality: We implement appropriate technical and organizational measures to ensure the security, integrity, and confidentiality of personal information.

5. Data Subject Rights

Individuals have the right to access, rectify, erase, and restrict the processing of their personal information. The company is committed to facilitating the exercise of these rights in accordance with applicable data protection laws.

6. Information Security

McLevin & Neilson Wealth Management Ltd. employs robust information security measures to protect personal information from unauthorized access, disclosure, alteration, and destruction. These measures include encryption, access controls, and regular security assessments.

7. Data Breach Response

In the event of a data breach, the company has established procedures to identify, assess, and respond promptly to mitigate the impact on affected individuals and to comply with legal obligations.

8. Data Protection Officer (DPO)

A Data Protection Officer has been appointed to oversee compliance with this policy and relevant data protection laws. The DPO can be contacted at [email protected]

9. Training and Awareness

Employees and contractors are regularly trained on data protection principles and their responsibilities under this policy.

10. Policy Review

This Data Protection Policy is regularly reviewed to ensure its continued effectiveness and compliance with applicable laws and regulations.

For inquiries or requests related to data protection, please contact our Data Protection Officer at [email protected].

This Data Protection Policy is effective as of the last update date and supersedes any prior versions.