Legal

This notice is issued by the companies operating under the ELEV8 CAPITAL brand. Depending on the company you engage with, the controller responsible for your personal data is:

• ELEV8 Qatar, in the process of registering with the Qatar Financial Centre, Doha, State of Qatar — for enquiries and engagements originating in the Middle East, Africa and Asia.
• ELEV8 USA Inc., 6192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, United States, registered number 10709276 — for enquiries and engagements originating in the Americas.

Where an enquiry does not clearly belong to one company, ELEV8 Qatar acts as controller until the enquiry is allocated. Questions about this notice, and requests to exercise your rights, should be sent to contact@elev8-capital.com.

It explains how we collect, use, share, transfer and protect personal data through www.elev8-capital.com and in the course of enquiries and engagements arising from it. It does not apply to third-party websites we link to, which publish their own notices.

Information you give us:

• Your name, your organisation and your email address.
• The content of your enquiry, and any information you choose to include in it.
• Correspondence between us, and records of meetings and calls.

Information collected automatically:

• Your IP address, approximate location derived from it, browser type and version, operating system and device type.
• Pages visited, time spent, referring page, and the date and time of your visit.

We do not knowingly collect special categories of personal data — data revealing health, racial or ethnic origin, religious or political beliefs, trade union membership, genetic or biometric data, or data concerning sexual orientation. Please do not include such information in an enquiry.

We use personal data for the following purposes, and on the following legal bases:

• To respond to your enquiry and to correspond with you — on the basis of our legitimate interest in responding to those who contact us and, where relevant, steps taken at your request before entering a contract.
• To complete conflicts, counterparty, sanctions and financial-crime screening before any substantive discussion — in compliance with legal obligations to which we are subject, and on the basis of our legitimate interest in preventing financial crime.
• To provide advisory and structuring services under an engagement letter — for the performance of a contract with you or with the entity you represent.
• To maintain records of engagements, correspondence and diligence — in compliance with legal obligations, including record-keeping expectations under anti-money-laundering rules, and on the basis of our legitimate interests.
• To operate, secure and improve the website, and to prevent abuse — on the basis of our legitimate interest in the security and integrity of our systems.
• To measure how the website is used — on the basis of your consent, given through the cookie banner and withdrawable at any time.

Where the Qatar Personal Data Privacy Protection Law applies, we process personal data on the basis of your consent or of a legitimate purpose consistent with that law and with this notice.

Before any substantive discussion of a mandate we complete conflicts and counterparty screening. This may involve checking your name and your organisation against sanctions lists, politically-exposed-person data and adverse-media sources maintained by third-party providers. This screening is a condition of engagement and is carried out on every prospective counterparty without exception.

• The other ELEV8 company, where your enquiry concerns it or is allocated to it.
• Professional advisers acting for us — legal, audit, tax and compliance — under duties of confidentiality.
• Service providers acting on our written instructions, including website hosting, email, secure file transfer and screening providers.
• Licensed institutions with whom a regulated element of a mandate is carried out, where you have engaged us and disclosure is necessary to perform it.
• Regulators, courts, law enforcement and other authorities where we are required to disclose, or where disclosure is necessary to establish, exercise or defend legal claims.

We do not sell personal data. We do not share personal data with third parties for their own marketing purposes. We do not use personal data for automated decision-making that produces legal or similarly significant effects.

We operate between Qatar, the United States and the European Union, and personal data will be transferred between those jurisdictions. Where personal data is transferred out of the European Economic Area or the United Kingdom, we rely on an adequacy decision where one applies, and otherwise on the European Commission’s standard contractual clauses or the United Kingdom’s international data transfer addendum, together with any additional measures required. Where personal data is transferred out of the State of Qatar, we transfer it in accordance with the Personal Data Privacy Protection Law. A copy of the safeguards applied to a particular transfer is available on request.

• Enquiries that do not proceed to engagement — 24 months from the last correspondence.
• Engagement files, including diligence and screening records — the duration of the engagement and 10 years after it ends, consistent with anti-money-laundering record-keeping expectations.
• Website analytics — 26 months.
• Cookie consent records — 12 months, after which consent is requested again.

We keep personal data for longer where a legal, regulatory or tax obligation requires it, or where it is necessary to establish, exercise or defend legal claims.

Subject to the law that applies to you, you have the right to ask us for a copy of the personal data we hold about you; to have inaccurate data corrected; to have data erased; to restrict or object to our processing of it; to receive it in a portable form; and to withdraw consent where our processing relies on consent. Withdrawing consent does not affect processing carried out before withdrawal.

To exercise any of these rights, write to contact@elev8-capital.com. We will respond within one month, and will tell you if we need longer. We may ask you to verify your identity before we act.

If you are in the European Economic Area or the United Kingdom, you may complain to the supervisory authority in the country where you live or work. If you are in the State of Qatar, you may complain to the competent authority under the Personal Data Privacy Protection Law. We would ask you to raise the matter with us first.

We protect personal data in transit using encryption, limit access to those who need it for their work, and place written confidentiality obligations on our personnel and our service providers. No transmission over the internet is completely secure. Please do not send confidential transaction information through the enquiry form; confidential material is exchanged under a signed non-disclosure agreement.

This website is not directed at persons under the age of 18 and we do not knowingly collect their personal data.

We may update this notice. The current version is always posted here with its effective date. Where a change is material and we hold your contact details, we will tell you.

A cookie is a small text file placed on your device when you visit a website. Cookies allow a site to remember your actions and preferences, and to understand how the site is used. This policy also covers similar technologies such as local storage and pixels.

We use cookies in three categories only:

• Strictly necessary — required for the website to function and to keep it secure, including recording your cookie choices. These are set without consent because the site cannot work without them.
• Preference — remember choices you make, such as language. Set only with your consent.
• Analytics and performance — tell us, in aggregate, which pages are visited and how the site performs, so that we can improve it. Set only with your consent.

We do not use advertising cookies, retargeting cookies, social-media tracking pixels or cross-site tracking of any kind, and we do not sell or share cookie data with advertising networks.

When you first visit the website you are shown a banner. Strictly necessary cookies are set at that point because the site cannot function without them. No preference or analytics cookie is set unless and until you accept it. You may accept all, reject all, or choose by category.

You can change or withdraw your choice at any time by selecting “Cookie settings” in the footer of any page. Withdrawing consent is as straightforward as giving it, and does not affect anything done before you withdrew it.

Most browsers let you see what cookies are set, delete them, and block them entirely or by site. Blocking all cookies will prevent parts of this website from working. Instructions are published by each browser vendor in its own help pages.

Where an analytics provider sets a cookie, that provider processes the data on our written instructions and is not permitted to use it for its own purposes. Any such provider is named in this policy before its cookies are used, and international transfers are addressed in our Privacy Policy.

There is no accepted standard for how websites should respond to a browser “Do Not Track” signal. We do not currently respond to it, and we set no tracking cookie without consent in any event.

We may update this policy. The current version is always posted here with its effective date.