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PRIVACY POLICY (AMKM)

Last updated: 26 January 2026

This Privacy Policy (the "Policy") explains how AMKM (the "Office," "AMKM," "we," "us," "our") collects, uses, discloses, stores, and protects personal information in connection with the website www.amkm.ae and any pages under it (the "Site"), and in connection with communications and engagement requests submitted through or arising from the Site.

AMKM operates as a private office with discretion by design. The Site is provided for informational purposes and as a controlled engagement gateway. Nothing in this Policy creates any advisory relationship, fiduciary duty, commitment, or obligation on AMKM to engage or respond.

1. Definitions

For the purposes of this Policy:

"Personal Information" means any information relating to an identified or identifiable natural person (including information that can reasonably identify a person, directly or indirectly).

"Processing" means any operation performed on Personal Information (e.g., collection, recording, storage, use, disclosure, deletion).

"Controller" means the entity that determines the purposes and means of Processing Personal Information.

"Processor" means an entity that Processes Personal Information on behalf of a Controller.

"Cookies" means small text files and similar technologies stored on your device when you visit a website.

"Engagement Inquiry" means any message, request, submission, or approach made to AMKM through the Site, by email, or via any contact channel referenced on the Site.

2. Scope and Application

This Policy applies to:

  • visitors to the Site;
  • individuals who contact AMKM using published email addresses or contact mechanisms;
  • individuals submitting Engagement Inquiries on their own behalf or on behalf of an organisation;
  • representatives, agents, introducers, advisors, or intermediaries communicating with AMKM; and
  • any Personal Information AMKM receives as part of assessing whether to proceed with an engagement.

This Policy does not apply to third-party websites linked from the Site, or to services not controlled by AMKM. Where third-party links exist, you access them at your own risk and subject to their terms and policies.

3. Controller and Contact Details

Unless stated otherwise, AMKM acts as the Controller for Personal Information Processed in connection with the Site and Engagement Inquiries.

Privacy Contact (AMKM):
Email: Contact Us
Subject line: "Privacy Request"

AMKM may request reasonable identity verification to protect confidentiality, discretion, and security before responding to any privacy request.

4. Categories of Individuals We Process Information About

AMKM may Process Personal Information relating to:

  • Site visitors (technical and usage data as described below);
  • inquirers and prospective counterparties;
  • representatives of legal entities (e.g., directors, officers, employees, shareholders, beneficial owners where relevant);
  • introducers, intermediaries, and advisors;
  • suppliers and service providers contacting AMKM through the Site; and
  • other individuals where their Personal Information is included in an Engagement Inquiry or subsequent communications.

5. Categories of Personal Information We Collect

The Personal Information AMKM collects and Processes depends on how you interact with the Site and AMKM. It may include:

5.1 Information you provide directly

  • Full name
  • Organisation / employer / affiliation
  • Role / title
  • Email address
  • Telephone number (if provided)
  • Country / location (if provided)
  • Purpose of inquiry and summary of request
  • Any other information contained in your message or attachments you choose to send (although we do not request attachments at the initial stage)

5.2 Information collected automatically when you use the Site

Depending on Site configuration and your browser settings, AMKM (and/or our hosting/security providers) may collect:

  • IP address (and approximate location derived from it, such as country/city)
  • Date/time of access and request logs
  • Device type, operating system, browser type/version, language settings
  • Pages visited, time spent, navigation paths and referrer URLs
  • Basic security and integrity signals (e.g., bot indicators, suspicious activity patterns, failed requests)

5.3 Information we may receive from third parties (limited)

In connection with an Engagement Inquiry, AMKM may receive information from:

  • your colleagues or representatives;
  • introducers or intermediaries;
  • professional advisors; and/or
  • publicly available sources (e.g., corporate websites, professional profiles)

Such information is Processed strictly for evaluation, context verification, governance, and risk control.

6. Sensitive Information and Confidentiality Warnings

6.1 Sensitive information

AMKM does not request and does not intend to collect "special category" or highly sensitive Personal Information (e.g., health data, biometrics, religious beliefs, political opinions). You should not submit such information through the Site or in initial communications.

6.2 Confidential materials

AMKM's engagement process begins with a controlled gateway. Do not submit sensitive documents, confidential deal materials, personal identification documents, or proprietary information at the initial stage unless AMKM has specifically requested them through an appropriate controlled channel.

AMKM may require a separate confidentiality arrangement (including an NDA) before receiving or reviewing certain materials.

7. Purposes of Processing

AMKM Processes Personal Information for the following purposes:

7.1 Site operation and functionality

  • providing access to the Site and its content;
  • maintaining availability, performance, and usability;
  • enabling navigation and security features.

7.2 Engagement Inquiry intake and handling

  • receiving, logging, routing, and evaluating inquiries;
  • communicating with you about your submission;
  • requesting clarifications where appropriate;
  • determining whether an inquiry aligns with AMKM's mandate, standards, and governance requirements.

7.3 Governance, risk management, and reputation safeguards

  • conducting internal review on a need-to-know basis;
  • performing screening appropriate for a private office context (including integrity and reputational risk considerations);
  • documenting decision pathways for institutional discipline, continuity, and accountability.

7.4 Security and misuse prevention

  • detecting and preventing spam, fraud, malicious submissions, and other security incidents;
  • monitoring and protecting systems, networks, and communications;
  • enforcing rate-limiting and anti-abuse controls where implemented.

7.5 Legal compliance and protection of rights

  • complying with applicable legal obligations and lawful requests;
  • establishing, exercising, or defending legal rights;
  • investigating and responding to incidents, disputes, and claims.

8. Legal Bases for Processing

Where required under applicable law, AMKM relies on one or more of the following legal bases:

Legitimate Interests: operating a discretion-first engagement gateway; protecting the Office, its reputation, and stakeholders; ensuring security; evaluating inquiries; preventing misuse; maintaining governance continuity.

Consent: where you voluntarily submit information to AMKM; and for non-essential cookies where required.

Legal Obligation: where Processing is necessary to comply with applicable laws, regulations, legal process, or lawful requests.

Legal Claims: where Processing is necessary for the establishment, exercise, or defence of legal rights.

9. Cookies and Similar Technologies

AMKM may use cookies and similar technologies to support Site functionality, security, and preferences.

9.1 Categories of cookies (where implemented)

  • Strictly Necessary Cookies: required for core Site operation and security.
  • Functional Cookies: enable preferences and enhanced functionality (where used).
  • Analytics Cookies: used to understand general Site performance (only if enabled).
  • Advertising Cookies: AMKM does not use advertising cookies for tracking-based marketing.

9.2 Managing cookie preferences

If the Site includes a cookie banner or preference centre, you may control non-essential cookies through that mechanism and/or through your browser settings. Blocking certain cookies may affect Site functionality.

If AMKM publishes a separate Cookie Policy, it forms part of this Policy by reference.

10. Sharing and Disclosure of Personal Information

AMKM does not sell Personal Information. AMKM may disclose Personal Information only as necessary and appropriate, including:

10.1 Internal disclosures (need-to-know)

Personal Information may be shared internally with designated personnel involved in inquiry review, governance oversight, protocol, and operations, strictly on a need-to-know basis.

10.2 Service providers and processors

AMKM may use third-party service providers to support:

  • website hosting and content delivery;
  • email and communications infrastructure;
  • cybersecurity, threat detection, and anti-abuse controls;
  • IT support and maintenance.

Where such providers act as Processors, they are required to process Personal Information only on AMKM's instructions and to implement appropriate security and confidentiality measures.

10.3 Professional advisors

AMKM may share Personal Information with legal counsel, compliance advisors, auditors, or other professional advisors where necessary to protect AMKM's interests, enforce governance standards, or comply with obligations.

10.4 Legal and regulatory disclosures

AMKM may disclose Personal Information where required by applicable law, court order, regulatory request, or lawful process, or where necessary to protect rights, security, or integrity.

10.5 Business transfers

If AMKM undertakes a restructuring or transfer of certain operations, Personal Information may be disclosed as part of due diligence and completion steps, subject to confidentiality safeguards and lawful requirements.

11. International Transfers

AMKM is based in the United Arab Emirates. Your Personal Information may be processed in the UAE and may be accessed or processed in other jurisdictions depending on the location of service providers, infrastructure, and counterparties involved in engagement evaluation.

Where cross-border transfers occur, AMKM will implement reasonable safeguards appropriate to the context and applicable legal requirements.

12. Data Security

AMKM applies reasonable technical and organisational measures designed to protect Personal Information against unauthorised access, loss, misuse, alteration, or disclosure. Measures may include:

  • access controls and need-to-know routing;
  • controlled internal handling protocols;
  • secure communications practices;
  • logging and security monitoring;
  • anti-abuse controls for inbound submissions.

No internet transmission is fully secure. You acknowledge that any transmission is at your own risk. You should avoid sending sensitive information at the initial stage.

13. Data Retention

AMKM retains Personal Information only for as long as reasonably necessary for the purposes described in this Policy, including:

  • evaluating and responding to inquiries;
  • maintaining governance continuity and institutional discipline;
  • security and incident management;
  • legal compliance and limitation periods for claims.

Retention periods may vary based on the nature of the inquiry, risk profile, and legal requirements. AMKM may retain records longer where necessary to protect legitimate interests, manage disputes, or comply with legal obligations. Where information is no longer required, AMKM will take reasonable steps to delete or anonymise it.

14. Your Rights

Depending on the laws applicable to you, you may have rights including:

  • Right of access: request confirmation and access to Personal Information held about you.
  • Right to correction: request correction of inaccurate or incomplete information.
  • Right to deletion: request deletion, subject to lawful retention needs.
  • Right to restriction: request limits on Processing, where applicable.
  • Right to object: object to certain Processing based on legitimate interests.
  • Right to withdraw consent: where Processing is based on consent (withdrawal does not affect prior lawful Processing).

AMKM may refuse or limit a request where permitted by law, including where necessary to protect confidentiality, legal privilege, third-party rights, or AMKM's governance and security standards.

Requests should be sent to Contact Us with the subject line "Privacy Request."

15. Automated Decision-Making

AMKM does not make decisions producing legal or similarly significant effects solely by automated means through the Site. Engagement evaluation is handled with human oversight and governance discipline.

16. Children

The Site is not intended for children and AMKM does not knowingly collect Personal Information from minors through the Site.

17. External Links

The Site may contain links to third-party websites. AMKM is not responsible for the privacy or security practices of those third parties. Access is at your own risk, and you should review their policies.

18. Changes to This Policy

AMKM may update this Policy from time to time without notice. The updated version will be posted on the Site and will be effective as of the "Last updated" date above. You are encouraged to review this Policy periodically.

19. Language and Interpretation

This Policy is drafted in English. If any translation is provided, the English version shall prevail to the extent of any conflict, unless mandatory law provides otherwise.

20. Contact

For questions, concerns, or rights requests relating to this Policy or AMKM's processing of Personal Information, contact:

Email: Contact Us
Subject: Privacy Request