Privacy Policy

This privacy policy (“Privacy Policy”) governs the websites krossbo.com and investors.krossbo.com (including both mobile and online versions) (collectively, the “Site”), which are made available by Krossbo, its subsidiaries and affiliates (“we” “our” or “us”). The Site is part of your agreement with Krossbo and as well as any fund vehicle (each, a “Fund”) you may choose to invest in via the Site.

What Personal Data do we collect about you?

The types of Personal Data we process, hold and share depends on the product or service you have with us and the nature of your investment. This can include or be related to:

  • Contact information (private or professional): full name, postal address, e-mail address, phone number.
  • Identification information: e.g. identity (identity card, social security number, passport information, etc.), place and date of birth, nationality, gender, photo.
  • Economic, financial and tax information: e.g. tax ID and tax status, income and other revenues, value of your assets.
  • Education and employment information: e.g. employer’s name, employment, education level, remuneration.
  • Banking and financial information: e.g. bank account details, product and services used, credit card details, money transfers, assets, declared investor profile, credit history.
  • Banking and financial information: e.g. bank account details, product and services used, credit card number, money transfers, assets, declared investor profile incl. investment experience, investment activity, risk tolerance and transaction history.
  • Transaction data including full beneficiary names, address and details including communications on bank transfers
    of the underlying transaction.
  • Data about your preferences (data which relate to your use of our products and services).
  • Activity and interaction on the Site, our other apps and our social media pages, (connection and tracking data such as cookies,
    connection to online services, IP address, geolocation data), call, chat, email, interview, phone conversation and information about your device (IP address, technical specifications and uniquely identifying data).
  • Login credentials used to connect to our Site and apps.
  • Accounts at other institutions such as private banks or family offices of whom you may be a client.
  • Only upon obtaining your explicit prior consent: biometric data such as fingerprint, voice pattern or face pattern which can be used for identification and security purposes and health data for insurance contracts; all such data is processed on
    a strict need-to-know basis.

The Personal Data collected about you will help us provide you with a better service and facilitate our business relationship.

  • We may combine Personal Data that you provide to us with Personal Data that we collect from, or about you, in some circumstances
  • This will include Personal Data collected in an online or offline context.

Where do we obtain your Personal Data?

We collect, and have collected, Personal Data about you from a number of sources, including from you directly:

Personal Data that you give us:

  • From the forms and any associated documentation that you complete when registering or subscribing for an interest in Krossbo. This can include information about your name, address, date of birth, passport details or other national identifier, driving license, your national insurance or social security number and income, employment information and details about your investment or retirement portfolio(s).
  • When you undergo certain verification checks and submit identity information such as identity card, passport, to us.
  • When you provide it to us in correspondence and conversations.
  • When you make transactions with respect to Krossbo.
  • When you purchase securities from us and/or tell us where to send money.

Personal Data we obtain from others:

  • Publicly available and accessible directories and sources.
  • Professional partners such as private banks or family offices of whom you may be a client.
  • Bankruptcy registers.
  • Tax authorities.
  • Governmental and competent regulatory authorities to whom we have regulatory obligations.
  • Credit agencies.
  • Fraud prevention and detection and anti-money laundering agencies, organizations and service providers.

Why do we process your Personal Data?

We may process or use your Personal Data for the following reasons or purposes:

1. Contract

It is necessary to take steps at your request prior to entering into a contract and to perform our contractual obligations with you to:

  • Evaluate (e.g. based on your investment experience) if we can offer you our Funds.
  • Administer, manage and set up your investor account(s) to allow you to purchase your holding (of interest) in our Funds and assist you in particular by answering your requests.
  • Meet the resulting contractual obligations we have to you.
  • Facilitate the continuation or termination of the contractual relationship between you and Krossbo.
  • Facilitate the transfer of funds, and administering and facilitating any other transaction, between you and Krossbo.

2. Compliance with law

It is necessary for compliance with an applicable legal or regulatory obligation to which we are subject to:

  • Undertake our client and investor due diligence, and on-boarding.
  • Prevent and detect money laundering and financing of terrorism and comply with regulation relating to sanctions and embargoes through our Know Your Customer (KYC) process (to identify you, verify your identity, screen your details against sanctions lists and determine your profile which might be carried out by third party service providers).
  • Verify the identity and addresses of our investors (and, if applicable their beneficial owners).
  • Record transactions for accounting purposes.
  • Record conversations for regulatory purposes.
  • Comply with requests from duly authorized local or foreign financial, tax, administrative, criminal, or judicial authorities, law enforcement, state agencies or public bodies.
  • Surveillance and investigation.
  • Carry out audit checks.
  • Maintain statutory registers.
  • Manage, prevent and detect fraud.
  • Sanctions.

3. Our legitimate interest

For our legitimate interests or those of a third party to:

  • Manage and administer your holding in any Funds in which you are invested, and any related accounts on an ongoing basis.
  • Assess and process any applications or requests made by you.
  • Open, maintain or close accounts in connection with your investment in, or withdrawal from, Krossbo.
  • Send updates, information and notices or otherwise correspond with you in connection with your investment in Krossbo.
  • Address or investigate any complaints, claims, proceedings or disputes.
  • Provide you with, and inform you about, our investment products and services and to improve them, perform client satisfaction and opinion surveys.
  • Monitor and improve our relationships with investors.
  • Comply with applicable regulatory obligations.
  • Manage our risk and operations.
  • Comply with our accounting and tax reporting requirements;
  • Comply with our audit requirements.
  • Assist with internal compliance with our policies and process.
  • Ensure appropriate group management and governance.
  • Keep our internal records.
  • Prepare reports on incidents / accidents.
  • Protect our business against fraud, breach of confidence, theft of proprietary materials, and other financial or business crimes (to the extent that this is not required of us by law).
  • Analyze and manage commercial risks.
  • Seek professional advice, including legal advice.
  • Enable any actual or proposed assignee or transferee, participant or sub-participant of the partnership’s or Funds’ rights or obligations to evaluate proposed transactions.
  • Facilitate business asset transactions involving Krossbo partnership or Fund-related vehicles.
  • Monitor communications to/from us using our systems.
  • Protect the security and integrity of our IT systems.

In any case, our legitimate interest remains proportionate and we verify according to a balancing test that your interests or fundamental rights are preserved.

Whom we transfer your Personal Data to

We may transfer your Personal Data to certain third parties, who will process your Personal Data on our behalf, including third party service providers that we appoint or engage to assist with the Fund’s management, operation, administration and legal, governance and regulatory compliance, and other Krossbo related entities. In certain circumstances, we may be required by law or regulation to transfer your
Personal Data and other information to governmental, regulatory, tax and law enforcement authorities.

How we safeguard your Personal Data

We work hard to incorporate commercially reasonable safeguards to help protect and secure your Personal Data. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk.

How long we retain your Personal Data

We will retain your Personal Data for as long as we require it to perform our contractual rights and obligations or for our legitimate interests or for such longer period as required by our legal or regulatory obligations. In general, we will retain your Personal Data throughout your investment. We will also retain certain of your Personal Data after you cease to be an investor. As a general principle, we do not retain your
Personal Data for longer than we need it.

Automated decision-making

We will not take decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of your Personal Data, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the requirements of the DPL (and other applicable laws).

Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive. Like many sites, we use “cookies” to collect 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 Site.

Changes to this Privacy Policy

Krossbo has the discretion to update this privacy policy at any time. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal data we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

By using this site, you signify your acceptance of this policy and terms of service. If you do not agree to this policy, please do not use our site. Your continued use of the site following the posting of changes to this policy will be deemed your acceptance of those changes.

Questions or concerns

If you have any questions or concerns about the contents of this privacy notice or our processing of your Personal Data,
please contact us at investments@krossbo.com.

Get in touch with us

Krossbo

Dubai

Boulevard Plaza, Tower 1

Level 9

Sheikh Mohammed bin Rashid Blvd

Dubai, United Arab Emirates

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No communication by Krossbo Investments Limited or any of its affiliates (collectively, “Krossbo”), through this website, the investment platform or any other medium, should be construed or is intended to be a recommendation to purchase, sell or hold any security or otherwise to be investment, tax, financial, accounting, legal, regulatory or compliance advice. Nothing on this website and the investment platform is intended as an offer to purchase or sell securities or a solicitation or recommendation of any securities transaction.

Any financial projections or returns shown on the website and the investment platform are estimated predictions of performance only, are hypothetical, are not based on actual investment results and are not guarantees of future results. Estimated projections do not represent or guarantee the actual results of any transaction, and no representation is made that any transaction will, or is likely to, achieve results or profits similar to those shown. In addition, other financial metrics and calculations shown on the website and the investment platform have not been independently verified or audited and may differ from the actual financial metrics and calculations for any investment, which are contained in the investors’ portfolios. Any investment information contained herein has been secured from sources that Krossbo believes are reliable, but we make no representations or warranties as to the accuracy of such information and accept no liability therefor.

Private placement investments are NOT bank deposits (and thus NOT insured or guaranteed by any federal governmental agency), are NOT guaranteed by Krossbo or any other party, and MAY lose value. No governmental or regulatory authority has recommended or approved any investment or the accuracy or completeness of any of the information or materials provided by or through the website and the investment platform. Investors must be able to afford the loss of their entire investment. Investments in private placements are speculative and involve a high degree of risk and those investors who cannot afford to lose their entire investment should not invest. Additionally, investors may receive illiquid and/or restricted securities that may be subject to holding period requirements and/or liquidity concerns. Investments in private placements are highly illiquid and those investors who cannot hold an investment for the long term (at least 5-7 years) should not invest.

Investing in securities (the "Securities") listed on Krossbo pose risks, including but not limited to credit risk, interest rate risk, and the risk of losing some or all of the money you invest. Before investing you should: (1) conduct your own investigation and analysis; (2) carefully consider the investment and all related charges, expenses, uncertainties and risks, including all uncertainties and risks described in offering materials; and (3) consult with your own investment, tax, financial and legal advisors. Such Securities are only suitable for accredited investors who understand and willing and able to accept the high risks associated with private investments.

Investing in private placements requires long-term commitments, the ability to afford to lose the entire investment, and low liquidity needs. This website and the investment platform provide preliminary and general information about the Securities and is intended for initial reference purposes only. This website and the investment platform do not summarize or compile all applicable information. This website and the investment platform do not constitute an offer to sell or buy any securities. No offer or sale of any Securities will occur without the delivery of confidential offering materials and related documents. This information contained herein is qualified by and subject to more detailed information in the applicable offering materials. Krossbo is not registered as a broker-dealer. Krossbo does not make any representation or warranty to any prospective investor regarding the legality of an investment in any Krossbo Securities on this website and the investment platform.

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