Legal

Privacy
notice.

This page contains two notices. Part 1 explains how we handle your personal data under the ADGM Data Protection Regulations 2021 (the “ADGM DPR”). Part 2 is our privacy notice under US federal law. Effective date: 14 October 2026.

Who we are.

Liwa Capital Advisors Ltd, a private company limited by shares incorporated in the Abu Dhabi Global Market (registered number 000010788), Suite 3502, Sky Towers, Al Reem Island, PO Box 32111, Abu Dhabi, United Arab Emirates, is the controller of your personal data. We are authorised and regulated by the ADGM Financial Services Regulatory Authority (Financial Services Permission number 240045)

Who this notice covers.

Our clients and investors, people who act for them (such as directors, signatories and beneficial owners), prospective investors, business contacts, and visitors to our website.

The personal data we hold.

Name, contact details, date of birth, nationality and identity documents; tax residency and tax identification numbers; source of wealth and source of funds; financial information, risk tolerance, wire transfer instructions and transaction history; politically exposed person and sanctions screening results; and information collected by cookies when you use our website.

Screening results can reveal political opinions or relate to criminal offences, which the ADGM DPR treats as special categories of personal data. We use them only where necessary for reasons of substantial public interest, to prevent and detect money laundering, terrorist financing and breaches of sanctions, and in line with our appropriate policy document.

Where we get it.

From you and your representatives, from our fund administrators, from screening databases and public sources, and when you use our website or investor portal.

Why we use it, and our lawful basis.

We use your personal data for the purposes below, each on one lawful basis.

Purpose	Lawful basis
To take you on as a client or investor, run your account and investments, and report to you	Contract: to enter into and perform our contract with you
To carry out anti-money laundering, sanctions and politically exposed person checks, keep the records the law requires, report to regulators and tax authorities, and respond to court orders and legal investigations	Legal obligation
To share information about your transactions and experiences with our affiliates for their everyday business purposes	Legitimate interests: running our business together with our affiliates
To tell you about our own funds and services	Legitimate interests: promoting our funds and services to investors and business contacts. You may object at any time, including through the unsubscribe link in each email.
For our affiliates to tell you about their products and services	Legitimate interests: allowing our affiliates to offer you their products and services. You may object at any time.
To measure use of our website and show you our advertising, through analytics and marketing cookies	Legitimate interests: understanding how our website is used, so we can improve it. You may object at any time
To run and secure our website and systems, and to establish or defend legal claims	Legitimate interests: keeping our systems secure and protecting our legal position

If you do not give us information.

We need your identity, tax, and source of wealth and source of funds information to meet our legal obligations and to enter into and perform our contract with you. If you do not provide it, we cannot accept your subscription or continue to act for you.

Who we share it with.

Our affiliates; our fund administrators; auditors; banks and custodians; legal and tax advisers; screening, IT and cloud service providers; and regulators, tax authorities, courts and law enforcement bodies where the law requires.

Transfers outside the ADGM.

We transfer personal data outside the ADGM, for example to our fund administrators and to our affiliate in the United States. Where the ADGM Commissioner of Data Protection has not recognised a destination as providing adequate protection, we use appropriate safeguards such as standard data protection clauses.

How long we keep it.

For as long as we need it for the purpose we collected it for, and then for six years after our relationship with you ends. We keep it longer only where a legal claim or a regulator requires it. We then securely delete or anonymise it.

How we protect it.

We use computer safeguards, secured files and buildings, access controls, encryption, staff training, and data processing agreements with our service providers. If a personal data breach is likely to result in a risk to your rights, we will notify the Commissioner of Data Protection without undue delay and, where feasible, not later than 72 hours after becoming aware of it. If it is likely to result in a high risk to you, we will also tell you without undue delay.

Your rights.

You may ask us to give you access to your personal data, to correct or erase it, to restrict or object to our use of it, and to give it to you in a portable format. You may object to direct marketing at any time. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Some rights are limited where the law requires us to keep information. For example, we cannot erase anti-money laundering records before the period the law sets has ended.

To use your rights, contact us using the details above. We will respond without undue delay and within two months of receiving your request. If a request is complex, or we receive a large number of requests, we may extend this by one further month; if we do, we will tell you within the first two months and explain why.

Cookies.

Our website uses essential cookies and analytics and marketing cookies (including Google, LinkedIn and Meta), which help us understand how visitors use the site and show our advertising on other websites. We use analytics and marketing cookies on the basis of our legitimate interests. You can object, and switch these cookies off, at any time.

Complaints.

You may complain to the ADGM Office of Data Protection by completing its complaint form, available at adgm.com/operating-in-adgm/office-of-data-protection/for-individuals and sending it to data.protection@adgm.com. We would welcome the chance to address your concern first.

Changes to this notice.

We may update this notice. The latest version is always on this page.

Facts: what does Liwa Capital do with your personal information?

Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and income; assets and risk tolerance; wire transfer instructions and transaction history. When you are no longer our customer, we continue to share your information as described in this notice.
How?	All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Liwa Capital chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Reasons we can share your personal information	Does Liwa Capital share?	Can you limit this sharing?
For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations	Yes	No
For our marketing purposes – to offer our products and services to you	Yes	Yes
For joint marketing with other financial companies	No	We don’t share
For our affiliates’ everyday business purposes – information about your transactions and experiences	Yes	No
For our affiliates’ everyday business purposes – information about your creditworthiness	No	We don’t share
For our affiliates to market to you	Yes	Yes
For nonaffiliates to market to you	No	We don’t share

To limit our sharing Call +971 2 622 2060 or visit liwacap.com.

Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Questions? Call +971 2 622 2060 or go to liwacap.com

Who we are

Who is providing this notice?	Liwa Capital Advisors Ltd.

What we do

How does Liwa Capital protect my personal information?	To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Liwa Capital collect my personal information?	We collect your personal information, for example, when you enter into an investment advisory contract or seek financial advice; make deposits or withdrawals from your account or give us your investment or retirement portfolio information; tell us about your employment history. We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
Why can’t I limit all sharing?	Federal law gives you the right to limit only sharing for affiliates’ everyday business purposes – information about your creditworthiness; affiliates from using your information to market to you; and sharing for nonaffiliates to market to you. State laws and individual companies may give you additional rights to limit sharing.
What happens when I limit sharing for an account I hold jointly with someone else?	Your choices will apply to everyone on your account.

Definitions

Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include Liwa Capital Advisors LLC (United States) and the general partners of the funds we manage; Liwa Capital GP & Liwa Core GP.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Liwa Capital does not share with nonaffiliates so they can market to you.
Joint marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Liwa Capital doesn’t jointly market.

Other important information

Part 1 above explains how we handle your personal data under the ADGM Data Protection Regulations 2021, including your rights under them and how to complain.

The ‘Can you limit this sharing?’ column above describes your rights under US federal law. If the ADGM DPR applies to you, you also have the rights set out in Part 1, including the right to object at any time to direct marketing and to our use of your information based on legitimate interests. For those individuals, once our relationship ends we keep and share your information only for the purposes and periods described in Part 1, ‘How long we keep it’.