Privacy Policy

In force on January 1^st2026

ARTICLE 1 – PREAMBLE
This Privacy Policy aims to inform users (“Users”) of the website https://www.investdubai.com/ (the “Site”) about how their personal data may be collected and processed, in accordance with applicable data protection regulations.

It is established in particular with regard to:
- Regulation (EU) 2016/679 of 27 April 2016 on the protection of personaldata (GDPR), for Users located in the European Union;
- Federal Decree-Law No. 45/2021 on the protection of personal data of theUnited Arab Emirates;
- As well as, where applicable, other local legislation depending on theUser’s place of residence.
The Site is for informational and promotional purposes only.It does not allow the creation of user accounts, direct investment subscriptions, or the execution of financial transactions on its own interfaces.

This Policy supplements the Legal Notices, the General Terms and Conditions of Use, and the Cookie Policy, which are accessible at any time on the Site.
ARTICLE 2 – DATA CONTROLLER
The processing of personal data implemented in connection with the operation of the Site is carried out under the responsibility of:

GREENBULL SERVICES FZ LLC, a limited liability company incorporated under the laws of the United Arab Emirates, and specifically under the authority of Creative City Fujairah Free Zone, with a share capital of AED 150,000, whose registered office is located at Creative Tower, P.O. Box 4422, Fujairah, United Arab Emirates, holder of license no. 13322/2018 issued by the Fujairah Culture & Media Authority (hereinafter “Greenbull” or “the Data Controller”).

Telephone: +33 7 57 95 75 04
Email: [email protected]
ARTICLE 3 – SCOPE OF DATA PROCESSING CARRIED OUT VIA THE WEBSITE
3.1 No Account Creation or Investment on the Website
The www.investdubai.com website does not allow the creation of user accounts or the execution of investment transactions.

When the User clicks on features such as "Get Started," they are redirected to an interface operated by a third-party partner, specifically the SmartCrowd® platform, which may be presented with a different branding or joint trademark such as "InvestDubai powered by SmartCrowd."

All account creation, login credentials, KYC processing, investment, and payment are carried out exclusively on these third-party platforms, under the responsibility of their operators, acting as separate data controllers.The User is advised to consult their privacy policies before transmitting any personal data.
3.2 Data Processed by the Publisher During Browsing
When simply browsing the Site, the DataController may process limited personal data, including:
- Technical browsing data (IP address, browser type, security logs);
- Audience and traffic data (aggregated or anonymized statistics);
- Data voluntarily provided by the User when requesting contact or information.
This processing is not for the purpose of providing investment services.
ARTICLE 4 – CATEGORIES OF DATA PROCESSED AND PURPOSES
In the course of operating the website www.investdubai.com, the Data Controller processes personal data in a limited manner, exclusively for the purposes described below.
4.1 Data processed directly by the Publisher
4.2 Data Processed by Partner Platforms
The Site does not allow the creation of user accounts, the execution of investment transactions, or the implementation of Know Your Customer (KYC) verification procedures.

Personal data relating to account creation, user identity, financial situation, investments, or any regulated transaction are collected and processed exclusively by third-party partner platforms, including SmartCrowd®, acting as separate data controllers, in accordance with their own privacy policies.

The Data Controller has no access to, control over, or responsibility for this processing.
4.3 Data Retention Periods
Personal data is retained for a period not exceeding that strictly necessary for the purposes for which it was collected. When the retention period cannot be determined in advance, the criteria used to determine it are communicated to the User in accordance with applicable regulations.
ARTICLE 5 – RECIPIENTS OF PERSONAL DATA
Personal data processed in connection with the operation of the Site is intended exclusively for:
- The Data Controller's strictly authorized internaldepartments;
- Its technical service providers, including the Site's hosting provider, acting as data processors within the meaning of applicable regulations.
The Data Controller does not sell Users' personal data or use it for advertising or marketing purposes without the User's prior consent when required.

Data necessary for creating an account, making an investment, or providing investment services is processed exclusively by third-party partner platforms, including SmartCrowd®, under their own responsibility. Users are encouraged to consult the privacy policies of these partners before transmitting any personal data.
ARTICLE 6 – DATA TRANSFER AND SERVICE PROVIDERS
The Site is hosted by WEBFLOW, whose servers may be located in the United States.
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When personal data of Users located in the European Union is processed, the Data Controller ensures that transfers to countries outside the European Union are governed by appropriate safeguards, in accordance with Articles 44 et seq. of the GDPR.
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The Data Controller may also be required to disclose personal data when such disclosure is required by law, applicable regulation, or a decision of a competent authority.
ARTICLE 7 – DATA RETENTION PERIOD
Personal data processed via the Site is retained for a period not exceeding that strictly necessary for the purposes for which it was collected.
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Certain data may be retained beyond this period when required to comply with legal or regulatory obligations, or for the establishment, exercise, or defense of legal claims.
ARTICLE 8 – DATA HOSTING
The website https://www.investdubai.com is hosted by:
Webflow Inc.
398 11th Street, 2nd Floor
San Francisco, CA 94103
USA
📞 +1 415 964 0555
📧 [email protected]
ARTICLE 9 – USER RIGHTS
In accordance with applicable data protection regulations, and in particular Regulation (EU) 2016/679 (“GDPR”) where applicable, any User whose personal data is processed by the Data Controller has the following rights, under the conditions provided for by applicable law.
9.1 Right to Information
The User has the right to obtain clear, transparent, and understandable information about how their personal data is processed, including the purposes for which it is processed, the categories of data concerned, the potential recipients, and their rights.
9.2 Right of Access, Rectification, and Erasure
The User may request:
- Access to their personal data;
- Rectification of inaccurate or incomplete data;
- Erasure of their data, where the conditions provided for by the regulations are met.
These rights can be exercised by sending a request to the Data Controller by email or post, using the contact details provided in Article 2 of this Privacy Policy.

Since no personal space or user account is created on the www.investdubai.com website, these rights are exercised exclusively through contact.

In case of reasonable doubt regarding the identity of the requester, the Data Controller may request any information or document necessary to verify their identity, in order to prevent identity theft.
9.3 Right to Data Portability
When processing is based on consent or the performance of a contract and is carried out using automated means, the User may request to receive the personal data they have provided to the Data Controller in a structured, commonly used, and machine-readable format, or to have it transmitted to another data controller where technically feasible.

This right applies only to data actually processed by the Data Controller in connection with the operation of the Website.
9.4 Right to Restriction and Right to Object
The User may request the restriction of the processing of their personal data or object to its processing, under the conditions provided for by applicable regulations, in particular when the processing is based on the legitimate interest of the Data Controller, unless there are compelling legitimate grounds justifying the continuation of the processing.
9.5 Right to Lodge a Complaint
The User may exercise their rights or lodge a complaint:
- Directly with the Data Controller, by contacting them using the contact details provided in Article 2 of this Privacy Policy. The Data Controller will endeavor to respond within one (1) month of receiving the request, a period that may be extended under the conditions provided for by applicable regulations;
- For Users located in the United Arab Emirates, to the competent data protection authority;
- For Users located in the European Union, to the competent supervisory authority of their country of habitual residence, in particular the Commission Nationale de l’Informatique et des Libertés (CNIL) for France, in accordance with Article 77 of the GDPR.
Independently of any administrative complaint, any User residing in the European Union may also lodge a legal claim with the competent courts, in accordance with Article 79 of the GDPR.
ARTICLE 10 – UPDATES
This Privacy Policy may be amended at any time to reflect legal, regulatory, or technical developments.

The applicable version is the one published on the Website on the date of consultation.
ARTICLE 11 – SECURITY AND CONFIDENTIALITY
The Data Controller implements appropriate technical, organizational, and security measures, taking into account the nature of the data processed, the purposes pursued, and the risks presented by the processing, to protect personal data against destruction, loss, alteration, unauthorized disclosure, or access.

These measures include, in particular, the use of recognized technical service providers, subject to contractual obligations regarding confidentiality and security, as well as mechanisms designed to preserve the integrity and availability of the data.

However, the Data Controller draws Users' attention to the fact that data transmission via the Internet involves inherent risks and that no technology can guarantee absolute security for the exchange or storage of information. Consequently, total security cannot be guaranteed.

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