Privacy Policy

Effective Date: 27 March 2026

Last Updated: 27 March 2026

1. Introduction

This Privacy Policy (“Policy”) explains how AUM GROUP HOLDINGS LIMITED (ADGM Licence Number 33100), a holding company incorporated in the Abu Dhabi Global Market, with its registered office at Al Khatem Tower, WeWork Hub71, Abu Dhabi, UAE (“AUM”, “we”, “us”, or “our”), collects, uses, stores, shares, and protects personal data in connection with your use of our website at aum.money (the “Site”).

We are committed to safeguarding your privacy and processing your personal data in compliance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“UAE PDPL”), Cabinet Decision No. 33 of 2024, and any other applicable data protection legislation.

By accessing or using the Site, you acknowledge that you have read and understood this Policy. If you do not agree with the practices described herein, please do not use the Site.

2. Data Controller

The data controller for personal data collected through the Site is:

AUM GROUP HOLDINGS LIMITED
Al Khatem Tower, WeWork Hub71, Abu Dhabi, UAE
ADGM Licence Number: 33100
Email: privacy@aum.money

Our Data Protection Officer (DPO) can be contacted at: dpo@aum.money

3. Personal Data We Collect

3.1 Data You Provide Directly

When you interact with the Site, you may voluntarily provide us with personal data, including:

Name, email address, and contact details (e.g., through contact forms or enquiry submissions);
Professional or organisational details, where provided;
Any other information you choose to submit through the Site.

3.2 Data Collected Automatically

When you visit the Site, certain data is collected automatically through cookies and similar technologies, including:

Device and browser data: IP address, browser type and version, operating system, device type, screen resolution, and language preferences;
Usage data: Pages visited, time spent on pages, click patterns, referring URLs, and navigation paths;
Location data: Approximate geographic location derived from your IP address.

For further details on cookies and similar technologies, please refer to our Cookie Policy.

3.3 Data We Do Not Collect

At this stage, as AUM is not operational with respect to the offering of products or services, we do not collect:

Financial information, bank account details, or payment data;
Government-issued identification numbers, passport details, or similar identity documents;
Know-Your-Customer (KYC) or Anti-Money Laundering (AML) documentation;
Digital wallet addresses or blockchain transaction data.

Should this change in the future as our services become operational, this Policy will be updated accordingly and any additional data collection will be conducted under an appropriate legal basis with adequate notice to you.

4. Legal Basis for Processing

We process your personal data on the following legal bases, as applicable:

Consent: Where you have provided explicit, informed consent to the processing (e.g., subscribing to communications or submitting a contact form). You may withdraw consent at any time by contacting us at privacy@aum.money;
Legitimate interests: Where processing is necessary for our legitimate business interests, such as improving the Site, analysing usage patterns, preventing fraud, and ensuring security, provided that such interests are not overridden by your rights and freedoms;
Legal obligation: Where processing is necessary to comply with a legal or regulatory obligation applicable to AUM;
Contractual necessity: Where processing is necessary for the performance of a contract with you, or to take pre-contractual steps at your request.

5. How We Use Your Personal Data

We may use your personal data for the following purposes:

To operate, maintain, and improve the Site;
To respond to your enquiries, requests, or feedback;
To analyse usage patterns and trends in order to enhance the user experience;
To ensure the security and integrity of the Site;
To comply with applicable laws, regulations, and legal processes;
To detect and prevent fraud, abuse, or unauthorised access;
To communicate with you about changes to these Terms, our policies, or the Site (where applicable and where you have consented to such communications).

We will not use your personal data for purposes materially different from those described above without providing you with adequate notice and, where required, obtaining your consent.

6. Data Sharing and Disclosure

We do not sell your personal data to third parties.

We may share your personal data with the following categories of recipients, to the extent necessary for the purposes described in this Policy:

Group companies: AUM Group subsidiaries, for internal administrative purposes;
Service providers: Third-party providers who assist us in operating the Site (e.g., web hosting, analytics, and IT support providers), acting as data processors on our behalf under appropriate contractual safeguards;
Legal and regulatory authorities: Where disclosure is required by applicable law, regulation, legal process, or governmental request, including in response to lawful requests by the ADGM, the Telecommunications and Digital Government Regulatory Authority (TDRA), or other competent authorities;
Professional advisors: Lawyers, auditors, and consultants, where necessary for the exercise or defence of legal claims;
In connection with corporate transactions: In the event of a merger, acquisition, restructuring, or sale of assets, personal data may be transferred to the relevant parties, subject to appropriate confidentiality undertakings.

7. International Data Transfers

Your personal data may be transferred to, stored, and processed in jurisdictions outside the UAE. Where such transfers occur, we will ensure that appropriate safeguards are in place in accordance with the UAE PDPL, including:

Transfers to jurisdictions recognised by the TDRA as providing an adequate level of data protection;
Implementation of standard contractual clauses or equivalent data transfer mechanisms;
Appropriate data processing agreements with all recipients.

Our primary data storage is located within the UAE. Where data is stored or processed outside the UAE, we take all reasonable steps to ensure that it is treated securely and in accordance with this Policy and applicable law.

8. Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

Website usage and analytics data: Up to 13 months from collection;
Contact form submissions and enquiry records: Up to 2 years from the date of last interaction, unless a longer retention period is required by law;
Legal and regulatory records: As required by applicable law (e.g., up to 5 years for AML/CFT-related records, where applicable in future operations).

When personal data is no longer required, it will be securely deleted or anonymised in accordance with our data retention procedures.

9. Your Rights

Under applicable data protection law, you may have the following rights in relation to your personal data:

Right of access: To obtain confirmation as to whether personal data concerning you is being processed, and to access a copy of such data;
Right of rectification: To request the correction of inaccurate personal data, or the completion of incomplete data;
Right of erasure: To request the deletion of personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention requirements;
Right to restrict processing: To request the restriction of processing in certain circumstances;
Right to data portability: To receive your personal data in a structured, commonly used, and machine-readable format, and to request the transmission of such data to another controller;
Right to object: To object to processing based on legitimate interests, or to processing for direct marketing purposes;
Right to withdraw consent: Where processing is based on consent, you have the right to withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, please contact us at: privacy@aum.money

We will respond to all valid requests within 30 calendar days. In complex cases, this period may be extended by a further 30 days, in which case we will notify you of the extension and the reasons for it.

If you are dissatisfied with our handling of your request, you have the right to lodge a complaint with the relevant supervisory authority, including the TDRA or the ADGM data protection authority, as applicable.

10. Data Security

We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:

Encryption of data in transit and at rest;
Access controls and authentication mechanisms;
Regular security assessments and penetration testing;
Staff training on data protection and information security;
Incident response procedures, including notification to the TDRA and affected individuals within 72 hours of becoming aware of a data breach that poses a risk to your rights and freedoms.

While we take all reasonable precautions, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

11. Children’s Data

The Site is not directed at, and we do not knowingly collect personal data from, individuals under the age of 18. If you become aware that a child has provided us with personal data, please contact us at privacy@aum.money and we will take steps to delete such data.

12. Third-Party Links

The Site may contain links to websites, platforms, or services operated by third parties. This Policy does not apply to such third-party sites, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, legal requirements, or the nature of our operations. Any changes will be posted on this page with an updated “Last Updated” date. Where changes are material, we will use reasonable efforts to provide you with notice (e.g., by posting a prominent notification on the Site).

Your continued use of the Site following the posting of any changes constitutes your acceptance of the revised Policy.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us at:

AUM GROUP HOLDINGS LIMITED
Al Khatem Tower, WeWork Hub71, Abu Dhabi, UAE
Email: privacy@aum.money

Data Protection Officer:
Email: dpo@aum.money

This Privacy Policy is effective as of the date first set out above.