Privacy policy

1) Who We Are

"Alex Chiniborch", "we", "us", or "our" means Alex Chiniborch and any owned or controlled affiliates, including Aluka Financial group entities, that operate this website, collectively the "Controller" under the PDPL.

Contact, privacy: alex@allucapmc.com
Postal: Dubai, United Arab Emirates

If any specific affiliate acts as a separate controller, it will be identified at the point of collection or in a relevant service agreement.

2) Scope

This Policy explains how we collect, use, disclose, and protect personal data of website visitors, newsletter subscribers, event registrants, prospective clients, and other users, collectively "you". If you enter into a separate contract, for example consulting, speaking, advisory, investment related engagement, that agreement will prevail where it conflicts with this Policy.

3) Definitions, PDPL

• Personal Data: Any information relating to an identified or identifiable natural person.
• Processing: Any operation performed on personal data, for example collection, storage, use, disclosure.
• Controller, Processor, Data Subject: As defined by the PDPL.
• PDPL: UAE Federal Decree Law No. 45 of 2021 and Cabinet Decision No. 34 of 2022, Executive Regulations.

If you are in DIFC or ADGM, local data protection rules may also apply, we endeavor to meet or exceed those standards.

4) What We Collect

We may collect and process:

We do not intentionally collect Special Category data via the website. Please do not submit sensitive medical, biometric, religious, or similar data through public forms.

5) Lawful Bases, PDPL

We process your personal data on one or more of the following bases:

• Consent, for example newsletter subscriptions, certain cookies and marketing.
• Contract, to provide requested materials or pre contractual steps.
• Legal obligation, record keeping, compliance.
• Legitimate interests, site security, audience analytics, improving content, preventing fraud, balanced against your rights and expectations.
• Vital interests or public interest only where strictly applicable.

You may withdraw consent at any time, see section 13.

6) How We Use Personal Data

• To operate, secure, and improve the website.
• To respond to inquiries and provide requested content.
• To send newsletters, insights, event notices, or marketing where permitted.
• To personalize content and measure engagement.
• To manage events, bookings, or meetings.
• To enforce our Terms & Conditions, section T&C, and comply with law.
• To protect our rights, users, and the public, fraud and abuse prevention.

We do not sell your personal data.

7) Disclosures and International Transfers

We may share data with:

• Processors, hosting, cloud storage, analytics, email or SMS providers, CRM, security vendors, web developers, cookie consent tools.
• Professional advisers, lawyers, auditors.
• Authorities where legally required.
• Successors in connection with a merger, sale, or reorganization.

Cross border transfers: Data may be stored or processed outside the UAE. We will transfer data only to countries deemed adequate under PDPL, or subject to appropriate safeguards, for example contractual clauses, or with your explicit consent, or as otherwise permitted by PDPL. Details available on request.

8) Data Retention

We retain personal data only as long as necessary for the purposes set out above, to satisfy legal or contractual requirements, or to resolve disputes. When no longer needed, data is deleted or irreversibly anonymized.

9) Security

We use administrative, technical, and physical safeguards proportionate to the risk, including encryption in transit, access controls, least privilege, logging, vulnerability patching, and vendor diligence. No system is 100% secure, please take care when transmitting data online.

10) Children

This site is not intended for persons under 18. We do not knowingly collect personal data from children. If you believe a child has provided data, contact us and we will delete it promptly.

11) Cookies and Similar Technologies

We use essential cookies for site functionality and may use optional cookies for analytics and marketing.

Where required, we obtain consent via a cookie banner. You can change preferences in the banner or your browser settings. Blocking some cookies may impact site functionality.

12) Third Party Links

Our site may contain links or embeds, for example YouTube, X or Twitter, LinkedIn. These third parties process your data under their own policies. We are not responsible for their practices.

13) Your Rights, PDPL

Subject to legal exceptions, you have the right to:

• Access your personal data and obtain copies.
• Request correction or erasure.
• Restrict or object to processing, including direct marketing.
• Data portability, where technically feasible.
• Not be subject to automated processing that produces legal or similarly significant effects, unless permitted by law.
• Withdraw consent at any time, without affecting earlier lawful processing.
• Lodge a complaint with the UAE Data Office.

How to exercise: email alex@allucapmc.com. We may need to verify your identity and the scope of your request.

14) Data Breach

If a breach occurs that is likely to result in a risk to your rights, we will follow PDPL requirements, including notifying the UAE Data Office and affected individuals when required.

15) Do Not Track and Global Privacy Controls

We currently do not respond to browser "Do Not Track" signals. Where local law requires honoring recognized global privacy signals for marketing cookies, we will endeavor to do so via our consent tool.

16) Changes to This Policy

We may update this Policy periodically. Material changes will be signposted on the site and take effect upon posting unless otherwise stated.

17) Contact

Questions or requests: alex@allucapmc.com
Postal: Dubai, United Arab Emirates