Data Privacy Policy

1. Introduction

1.1 Madkhol Financial Advisory JSC (“Madkhol”, “we”, “us” and/or “our”) currently offer Robo Advisory and digital wealth management (the “Services”) through Madkhol’s website, www.madkhol.com (the “Website”) and our mobile application (the “App”). This Privacy Policy describes how Madkhol treats your non-public personal information and other types of personal information (“Personal Data”).

2. General Privacy

2.1 By using this Website, you hereby acknowledge and agree that Madkhol, in its capacity as data controller, will process any Personal Data entered by you on this Website in compliance with applicable laws.

2.2 The Personal Data you provide to Madkhol will be processed for the following purposes:

(a) help you evaluate our Services

(b) offer you new products or services

(c) enhance our services

(d) for research and internal analysis; and/or

(e) any additional purposes which relate to Madkhol’s licensed activities.

2.3 Your Personal Data will be processed for the purposes specified above using both automated and non-automated tools, in accordance with the principles of confidentiality and security measures prescribed by applicable law. Other means by which we collect Personal Data include the following:

(a) Automatic Data Collection. We may collect certain information when you use our Services. This information may include your internet protocol (“IP”) address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, internet service provider, pages that you visit before, during and after using the Services, information about links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

(b) Anonymized or Aggregated Information. Madkhol’s Website and App record certain anonymized or aggregated information about your use or evaluation of our Services. Anonymized or aggregated information is used for a variety of functions, including the measurement of Users’ and Clients’ interest in and use of various portions or features of the Website and App. Anonymized or aggregated information is not Personal Data, and we may use such information in a number of ways, including internal analysis and research. We may share this information with third parties for our purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

(c) Cookies and Pixels. Similar to other consumer internet services, Madkhol uses cookies, a small piece of computer code that enables our web servers to identify Users and Clients, each time they initiate a session on our Website. A cookie is set in order to identify you and tailor the Website to you. Cookies do not store any of the Personal Data you provide to us; they are simply identifiers. You may delete cookie files from your hard drive at any time through your browser settings. However, cookies may be necessary to provide access to much of the content and many features of the Website.

(d) Pixel Tags. Along with cookies, we may use “pixel tags”, which are small graphic files that allow us to monitor the use of our Website. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.

(e) Website and App Activity. Madkhol may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on our Website and App.

2.4 For the purpose of this Privacy Policy, a “User” is an individual who creates an account on or uses our Website or App and a “Client” is an individual who signs or approves our Client Agreement that entitles the Client to maintain an account or investment portfolio managed by Madkhol.

2.5 If you choose to open an account on this Website or our App (whether as a User or a Client) using your email address, Madkhol’s web provider will collect your email address and any other information provided by you (including, without limitation, name, address and mobile number) and store this information indefinitely for purposes of creating and maintaining an account. If you then take steps to complete an application using the same email address, your application details will be saved to your account so you may return to complete the application later on. Madkhol may send you a follow-up email if you open an account but do not complete an application. By providing your name, email address, home address and/or mobile number and entering your information in an application, you agree that this information may be collected and stored.

2.6 We collect Personal Data from Users, including but not limited to your:

(a) name, e-mail address, telephone number, Internet Protocol address, date of birth

(b) investable assets, income information and other financial planning information about your household; and

(c) account numbers, routing numbers, and login credentials for the financial accounts you choose to link to our Services, any challenge and/or security questions associated with those accounts and any information contained in those accounts.

2.7 In addition to the information we collect from Users, Clients must provide us additional Personal Data, including but not limited to:

(a) your and your beneficiaries’ full legal name, contact information, address, birth date, citizenship, marital status, identification card number

(b) for purposes of identity verification, government-issued identification documents and a photograph; and

(c) your investment objectives, approximate net worth, tax and zakat information and other regulatory information that may be necessary and required by applicable laws

2.8 This Privacy Policy and these terms apply only to Madkhol operated Services and applications. Please note that our Website and App may contain links to other websites, applications, social media accounts, and information for your convenience that are not operated or controlled by Madkhol. Madkhol does not control these linked third-party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Any Personal Data you choose to give to linked third parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of any company or website before submitting your Personal Data. Some third parties may choose to share their users’ Personal Data with us; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

2.9 You hereby acknowledge and agree that:

(a) You are providing your Personal Data to be processed by Madkhol for the purposes specified in clause 2.2 above; and

(b) Madkhol may disclose your Personal Data if required to do so: (i) by applicable laws; (ii) at the request of any governmental authority; (iii) at the request of a financial institution; (iv) in the good faith belief that such action is necessary; (v) to comply with a legal obligation; (vi) to protect and defend the rights or property of Madkhol or its affiliates; or (vii) to protect Madkhol against legal liability.

3. Processing of Payment Information

3.1 Payments made on this Website and the App to Madkhol will be processed through Arab National Bank (ANB) or such other payment gateway or process provider (each a “Payment Gateway”) which we may choose. Any payment made through the Website and/or App, and all associated details provided by you, shall be provided directly to a Payment Gateway via a secure connection. Payments may be made using a Visa or Mastercard credit or debit card in Saudi Arabian Riyals or any other currency deemed acceptable by Madkhol from time to time.

3.2 By submitting an online payment, you agree that any Payment Gateway may collect, use, store, process and transfer data received from you in order to process the payment and as required by applicable laws. You further agree that any Payment Gateway is permitted to transfer such data to any third party if required for successful completion of the payment process. In all cases, Madkhol shall comply with applicable laws related to personal data privacy. Other than as stated in clause 2.9 and as required by the Payment Gateway under this Privacy Policy, no credit or debit card details or other personally identifiable information supplied by you will be stored, sold, shared, rented or leased to any third parties.

3.3 Madkhol will preserve all records related to purchases and refunds for two (2) years from the date such purchase or refund is processed. By submitting an online payment, you agree that Madkhol may keep records of such payment for up to two (2) years and permit any Payment Gateway to examine such records.

4. Opting Out

4.1 You have certain choices about the use and disclosures of your Personal Data, as set out in this Privacy Policy. You may decline to provide Personal Data to Madkhol. Declining to provide Personal Data may disqualify you from using the Services, Website, and App features that require Personal Data.

4.2 Where you have consented to Madkhol’s use of your Personal Data, you may withdraw consent at any time and opt-out by contacting us by email, phone or physical mail via the contacts indicated in clause 10 below. Clients and Users cannot opt-out of providing Madkhol with Personal Data and continue to use the Services. Clients and Users must close their account(s) in order to opt-out of further providing Madkhol with Personal Data. Additionally, before we use Personal Data for any new purpose, we will provide information regarding the new purpose. Even if you opt-out, we may still collect and use non-personal information regarding your activities on our Services and for other legal and regulatory purposes.

4.3 Madkhol may use your Personal Data to communicate with you regarding the Services or to tell you about Services that we believe will be of interest to you. If you decide at any time that you no longer wish to receive marketing communications from us, please follow the “unsubscribe” instructions provided in the communications or contact us at the email provided in clause 10 below.

5. Retention and Deletion

5.1 Madkhol retains Personal Data we receive as described in this Privacy Policy for as long as you use our Website, App, or Services or as necessary to fulfill the purposes for which it was collected, to provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or as otherwise required to comply with contracts and comply with all applicable laws.

5.2 Users may request information regarding the Personal Data we have collected about you and/or deletion of Personal Data by contacting us at the email provided in clause 10 below and providing us enough information to identify your account and prove that you are the owner of the identified account or an authorized representative.

6. Security

Madkhol takes reasonable steps, endeavoring to use appropriate technical or organizational measures, to protect your Personal Data from loss, misuse, unauthorized access, alteration, disclosure or destruction. However, no internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error-free, therefore, we cannot ensure or warrant the security of any information you transmit to us.

7. International Transfers

In certain cases, Madkhol may transfer Personal Data internationally. We handle any Personal Data transferred internationally in accordance with this Privacy Policy and take measures to protect that information.

8. Changes to this Privacy Policy

8.1 We may update this Privacy Policy from time to time as we deem necessary in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by the applicable law.

8.2 Madkhol encourages you to review this Privacy Policy periodically to be informed regarding how we are using and protecting your information and to be aware of any policy changes. Your continued relationship with Madkhol after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy will take effect immediately after being posted or otherwise provided by us. Each version of this Privacy Policy will be identified on this page by its effective date.

8.3 This document constitutes Madkhol’s complete Privacy Policy for Madkhol and its affiliates and the Services, Website and App.

9. Governing Law and Dispute Resolution

9.1 Madkhol is domiciled in the Kingdom of Saudi Arabia and this Privacy Policy shall be governed according to the laws of the Kingdom of Saudi Arabia.

9.2 In the event of a dispute arising from this Privacy Policy, you agree to cooperate with Madkhol in an attempt to resolve such dispute through good-faith negotiations. In the event such negotiations fail, you agree that such dispute shall be resolved by any court of competent jurisdiction in the Kingdom of Saudi Arabia.

10. Contact Us

Communications to Madkhol concerning this Privacy Policy may be directed to: Physical Office Address: 7193 King Abdulaziz Road, Salah Adeen District, 2403, zipcode 12434 Email: Contact@madkhol.com