Privacy Policy

At FJX Group, a multinational organization with diverse operations in advisory, IT development, and other sectors, we prioritize the protection of your personal data. Whether through our consulting services, technology solutions, or operational ventures, we ensure that any data collected or accessed is handled in strict compliance with applicable data protection regulations.

This Privacy Policy explains how we collect, use, and manage your personal information across all our businesses, spanning multiple industries and international markets. Should you have any inquiries, please refer to the relevant regional contact provided below.

WHEN THIS NOTICE APPLIES

This Privacy Notice explains how we manage personal information that we collect:

• During our business intake and onboarding processes;
• From individuals who are our clients or related to the services we provide to them;
• From individuals in the course of delivering our advisory, IT development, and operational services;
• In the general operation of our international businesses, including data from marketing efforts and digital initiatives.

If you are a partner, employee, or applicant of FJX Group, please refer to the specific privacy information provided to you concerning your role or application process.

HOW WE COLLECT PERSONAL INFORMATION AND THE TYPES OF PERSONAL INFORMATION

The personal information we collect from you will depend on the nature of your interactions with FJX Group, including whether you:

• Have engaged our advisory, IT development, or operational services;
• Are a recipient of our marketing communications or have attended events hosted by FJX Group;
• Have interacted with FJX Group’s websites, used similar digital technologies, or have participated in activities involving the use of our relationship management tools;
• Have a connection with any member of our team;
• Have a vendor, contractor, or similar relationship with FJX Group.

We may also gather personal information about you from third-party sources, which may include, but are not limited to, instructing clients (where your information is part of a client engagement) and providers of verification services during onboarding processes. Furthermore, we may monitor your interactions with our websites, the marketing materials we distribute, and any communications between you and FJX Group.

Depending on the circumstances, the types of personal information collected by FJX Group may include:

• Basic details such as your name, contact information, job title, and the name of your employer;
• Financial information, including billing addresses, bank account details, and payment information;
• Identification, background verification data, proof of ownership or source of funds collected for business onboarding and compliance with anti-money laundering regulations;
• Photographic, audio, and video content, including CCTV footage if you visit our offices or premises;
• Information provided by you regarding marketing preferences, event registration, and meeting attendance (which may include access requirements and dietary preferences);
• Information about your website usage and technical data gathered via tracking technologies and relationship management tools; and
• Any additional information that you or third parties may provide about you.

PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

We will only use your personal information when permitted by law. Most commonly, we will use your personal information in the following circumstances:

• When it is necessary to perform a contract we are about to enter or have entered into with you;
• When we need to comply with a legal obligation;
• Where permitted by law, when it is necessary for our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override those interests;
• When it is necessary to establish, exercise, or defend legal claims;
• If you have already made the information public; or
• If you have provided your consent

We may rely on more than one legal basis for processing your personal information, depending on the situation

To the extent permitted by law, the specific legitimate interests we rely on when processing your personal information include the following:

• For conducting business intake procedures: this includes using and/or obtaining information to carry out anti-money laundering, conflict checks, and other business intake screenings.
• For providing Advisory or Tech services to our clients: the information may include contact data, details of your employment or business activities, and any other relevant data for the project, transaction, or matter on which we are advising.
• For the purposes of marketing our services and business verticals: We may use information about you to promote our business. This could include responding to requests for information about our services, sending you communications on topics of interest, inviting you to events, or responding to comments on our blogs or social networks. Based on this information, we may also identify additional products, services, or events you might find relevant. You have the right to opt out of marketing communications at any time by contacting us or by using the appropriate options on the data collection forms.
• For the functioning of our business and its operations: We may use your personal information to support the management of our business, such as dealing with third-party suppliers, managing insurance arrangements, facilitating business sales, acquisitions, or restructuring, and seeking external legal advice when needed.
• For the purposes of operating our alumni website: We may use information already in our possession and any information you provide upon registering for the site or during its use. This information helps us improve the site, communicate with you on alumni matters, share marketing materials, and inform you of job opportunities. We may also analyze this data to assess relationships with clients and prospects. Information will only be shared with other alumni if you have consented to it.

CHANGE OF PURPOSE

We will only use your personal information for the purposes for which it was collected, unless we reasonably determine that it needs to be used for another purpose that is compatible with the original intent. Should we need to use your personal information for an unrelated purpose, we will only proceed if legally permitted and, where required by law, we will notify you and seek your consent.

If you would like further clarification regarding the legal basis on which we are processing your personal information, please contact us using the details provided below.

TRANSFERRING AND SHARING YOUR INFORMATION

FJX Group is a global organization. Your personal information may be stored on servers located in various countries and may be processed by FJX Group worldwide for business or administrative purposes. Information held in hard copy is stored either onsite or at secure offsite locations. The types of personal information and uses include those detailed above, where applicable.

Within FJX Group, we may transfer personal information outside of the European Economic Area ("EEA"), UAE, KSA, or the jurisdiction where you are located. When transferring personal information from our offices in these regions or your local jurisdiction to another, we do so under a Personal Data Transfer Agreement, adhering to applicable data privacy laws, including using Standard Contractual Clauses, or in compliance with the relevant laws of the applicable jurisdiction.

We may also provide personal information to third parties that perform operational services on our behalf, such as professional advisors (e.g., legal counsel or local consultants) or service providers (e.g., document review platforms), solely for use in providing services to clients with their consent. We will only transfer your personal information in these situations where we are confident that it will be appropriately protected and in compliance with any legal safeguards required.

Additionally, FJX Group may be legally obligated to disclose personal information to regulators, courts, or authorities in the UAE, KSA, Portugal, Spain, or other jurisdictions. Where necessary, and with appropriate safeguards, we may also share information with our professional advisors (e.g., legal and financial advisors), bankers, auditors, insurers, and insurance brokers.

IDENTITY ACCESS MANAGEMENT

Certain employees and contractors of FJX Group who use company-issued devices may choose to enable features that utilize personal information, which is securely stored on their devices. This information remains securely stored on their devices while these features are in use and is deleted within a reasonable period after their departure from the company, not exceeding three years in any case.

USE OF ONLINE IDENTIFICATION TECHNOLOGIES AND RELATIONSHIP INSIGHT TOOLS

We use online identification technologies, such as cookies, on FJX Group websites, collaboration platforms, blogs, apps, and other digital media ("Websites"). "Cookies" are small text files placed on your device's hard drive to help provide a more personalized experience. When you visit a site that uses cookies for the first time, a cookie is downloaded to your device. Upon subsequent visits, your device checks for a relevant cookie (i.e., one containing the site name) and sends the stored information back to the site. This enables the site to recognize previous visits and, in some cases, adjust the on-screen content accordingly.

You can access our Cookie Policy [here].

If your contact details are stored in our marketing database, FJX Group may use relationship insight tools that collect aggregated information about your interactions with us, such as emails, Outlook calendar invitations, business development activities, and other exchanges for business development purposes. These tools help us keep your contact details and profile up to date and provide insights into the nature and extent of your relationship with others within FJX Group.

Your marketing insight information is securely stored in the UAE and managed in line with our data retention policies. The lawful basis for processing this information, where required, is FJX Group’s legitimate interests in marketing, relationship management, and keeping information current.

If you would prefer us not to use relationship insight tools in relation to your profile, please email legal@thefjx.com. or use the ‘private’ tag in emails. Please update us if your contact details change.

CONFIDENTIALITY AND SECURITY

We take reasonable precautions to ensure that your personal information remains confidential and have implemented appropriate security measures to protect it. Access to your personal information is limited to individuals who have a legitimate business need, and they will only process your information according to our instructions and under a duty of confidentiality.

We have established procedures to manage any suspected personal data breaches and will notify you and any relevant regulator if required by law.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

FJX Group follows document retention and destruction practices that vary depending on the geographical region, practice area or business support team, the nature of the information, its format, and the type of documentation.

When determining the appropriate retention period for personal information, we consider factors such as the nature of the information, the purposes for which it is retained, applicable security measures, relevant technical constraints, and legal requirements.

If you would like further information about our record retention policies, please contact us.

DATA PRIVACY ENQUIRIES AND ACCESS TO INFORMATION

If you believe the information we hold about you is inaccurate or outdated, please contact us so that we can remove or correct the information as necessary.

If you are located in the European Union or your personal information is processed by us in the European Union, UAE (ADGM), or KSA, applicable data protection legislation provides you with the right to access the information held about you.