Privacy Policy

Effective Date: 10th July 2025

Hashgraph Ventures Manager Ltd (“we“, ” us” or “our“) is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose and safeguard your information when you visit our website or engage with us.

This Privacy Policy applies to our website and online services. It does not apply to third-party websites or services that may be linked from our website, which have their own privacy policies.

We are committed to complying with the Abu Dhabi Global Market Data Protection Regulations 2021, the United Arab Emirates Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data and any other applicable data protection laws and regulations (together, the “Data Protection Laws“). Throughout this policy, reference to “personal data” means any information relating to an identified or identifiable living natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

We may be required to update or change this Privacy Policy from time to time. We will upload an updated Privacy Policy on this website.

• Information we collect

Information You Provide Directly

We may collect personal data that you voluntarily provide to us when you:

• Contact us through our contact forms, send us emails, or communicate with us through other channels.
• Subscribe to our communications through our newsletter, updates, or other communications.
• Request Information about our services, download materials or request meetings.
• Inquire about our venture capital fund management services.
• Register for events such as webinars and conferences.

This information may include: (i) name and contact details (email address, phone number, postal address); (ii) professional information (job title, company, industry); (iii) business information relevant to your inquiry or application; (iv) communication preferences; and (v) any other information you choose to provide.

Special categories of personal data

There are more limited bases for processing special category personal data. This is personal data which reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, genetic data, biometric data, health data, sex life and sexual orientation, or data relating to criminal convictions and offences or related security measures. We do not intend to actively collect special category data about you. Whilst we will use reasonable efforts to limit its holding of such data, please be aware that we may hold such data incidentally. For example, where:

• you volunteer special category data to us or to one of our service providers, such as if you send an email containing special category data.
• documents gathered for legal / regulatory purposes containing special category data, such as a passport copy which references ethnic origin or a due diligence search from public sources which includes special category data.

We will ensure that any processing of special category personal data complies with the principles outlined in the Data Protection Laws, including:

• Ensuring that only the minimum necessary amount of personal data is processed.
• Special category data will only be processed for legitimate purposes as specified by applicable laws and regulations.
• We will take reasonable steps to ensure that special category data is accurate and up to date.
• Appropriate technical and organizational measures will be implemented to safeguard the special category data from unauthorized access, disclosure, or loss.

We will retain special category personal data only for as long as it is necessary to fulfil the purposes for which it was collected, in accordance with this Privacy Policy and the Data Protection Laws. Once the data is no longer needed for these purposes, it will be erased or anonymized. If the data is no longer required, it will be securely erased.

Information We Collect Automatically 

When you visit our website, we may automatically collect certain technical information (IP address, browser type and version, time spent on pages, links clicked, etc.) through cookies and similar technologies. For detailed information, please refer to our separate Cookie Policy and Terms of Service.

Information from Third Parties

We may receive personal data about you from third parties, such as your professional advisers (with your consent), business partners or introducers, public databases and information sources and event organizers or co-hosts.

• How We Use Your Information

We process personal data that enables us to identify you as a unique individual in accordance with Data Protection Laws. This information is required to facilitate the opening of a relationship with us and to ensure its maintenance throughout its lifetime. Further we are required to maintain this information about our customers as per Abu Dhabi Global Market (“ADGM“) know your customer (“KYC“) and anti-money laundering (“AML“) requirements. This information may include, in addition to personal data, any financial information related to your business or investment activities and any other information you choose to provide.

We process personal data in accordance with the principles set out in section 4 of the ADGM Data Protection Regulations 2021, ensuring that personal data is processed lawfully, fairly and in a transparent manner; collected for specified, explicit and legitimate purposes; adequate, relevant and limited to what is necessary; accurate and kept up to date; kept in a form which permits identification only for as long as necessary; and processed in a manner that ensures appropriate security.

Please note that you can choose not to share your personal data with us. In such a case, we are likely to be limited in terms of what services we can offer you. Additionally, you may be unable to access our website or communications from us.

Where we need to collect your personal data due to the requirements of Data Protection Laws or professional standards, or for the performance of a contract between you and Hashgraph Ventures Manager Ltd or any of its affiliates, and you fail to provide that data when requested, we may have to decline your request for our services, or, if we are already supplying services, we may have to suspend or cease your access to them. We will notify you if this is the case at the time.

Lawful basis for processing your personal data

We can only process your personal data if we have a legal reason to do so, that is, if we have a “lawful basis” under section 5 of the ADGM Data Protection Regulations 2021 and article 4 of UAE Federal Decree Law No. 45 of 2021. We will use a different lawful basis to process different categories of personal data, as applicable.

Certain Data Protection Laws require us to explain what legal ground(s) justify our processing of your personal information (including when we share it with third-parties). For some processing more than one legal ground may be relevant (except where we rely on a consent). Below is a list of the legal grounds that are relevant to us in accordance with applicable Data Protection Laws:

• Processing is necessary to perform our contract with you or for taking steps prior to entering into it for the purpose of:

1. Investor onboarding and management: Processing investor applications, conducting suitability assessments, managing investor subscriptions and redemptions.
2. Fund administration: Managing your investment in our funds, processing capital calls and distributions, maintaining investor records and fund accounting.
3. Regulatory compliance: Meeting our obligations under ADGM applicable laws and regulations, including investor reporting and regulatory filings .

• Where we consider that, on balance, it is appropriate for us do so, and where we are able to do so in line with Data Protection Laws, processing necessary for the following legitimate interests:
  1. Investment management activities: Managing fund portfolios, conducting investment research and analysis, monitoring portfolio performance.
  2. Due diligence and risk management: KYC and AML checks, ongoing monitoring of investor relationships.
  3. Regulatory compliance: Adhering to guidance from the ADGM Financial Services Regulatory Authority and other relevant regulatory bodies.
  4. Business operations: Management and auditing of our fund management operations, including compliance monitoring and risk management.
  5. Service provider management: Sharing information with our service providers including: 

• Fund administrators and custodians;
• Legal and professional advisers, auditors and tax advisers;
• Prime brokers and counterparties;
• Regulatory authorities and tax authorities;
• IT service providers and data processors; and
• Potential acquirers in business transactions.

• Processing is necessary to comply with our legal obligations:
  1. Regulatory compliance: Compliance with ADGM fund management regulations and international regulatory standards and/or requirements.
  2. AML/KYC obligations: Identity verification, AML checks, and ongoing monitoring requirements.
  3. Tax compliance: Meeting tax reporting obligations including FATCA, CRS and other international tax reporting requirements.
  4. Investor rights: Processing requests from investors to exercise their rights under applicable laws.

• Processing with your consent:
  1. Marketing communications: Providing you with information about our investment strategies, fund performance, and market insights. 
  2. Enhanced services: Providing additional services or sharing information beyond our standard fund management activities.

• Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time (unless the personal data is required for our business operations related to the provisions of services to you). 

The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent, please email us at the email address set out in Section ‎14 below.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless we now have an alternative legal basis for doing so.

• Information Sharing and Disclosure

We may share your personal data with fund service providers including fund administrators, custodians, prime brokers, and auditors who provide services to funds we manage. We also share information with professional advisors including lawyers, tax advisers, and compliance consultants, as well as regulatory authorities including the Financial Services Regulatory Authority of the ADGM, tax authorities, and other governmental bodies when required by law. Additionally, we may share your personal data with technology providers who support our IT systems and data processing, portfolio companies and co-investors with your consent or where necessary for fund operations, and potential buyers and their representatives in connection with a business transaction such as a merger, acquisition, or sale of assets. We do not sell your personal data to third parties.

Where we engage processors to process personal data on our behalf, we ensure that such processors provide sufficient guarantees to implement appropriate technical and organisational measures and that processing will meet the requirements of the Data Protection Laws and ensure the protection of your rights. We enter into written contracts with all processors that set out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects, and the obligations and rights.

• Data Retention

We will retain your personal information only for as long as necessary to fulfil the purposes outlined in this Privacy Policy. Specific retention periods depend on contractual requirements for the duration of our relationship and any ongoing obligations, legal and regulatory requirements as required under ADGM regulations and international standards, and legitimate business interests including compliance monitoring, audit requirements, and potential legal claims. We regularly review our retention practices and will securely delete or anonymise personal data when it is no longer required, unless we are legally obliged to retain it for a longer period.

When the lawful basis for processing personal data changes or ceases to exist, we will securely delete the personal data, anonymise the personal data, pseudonymise the personal data or securely encrypt the personal data. Where this is not possible, we will archive the data beyond further use with appropriate safeguards.

• Data Security

We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights of natural persons. These measures include the pseudonymisation and encryption of personal data, the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services, the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident and a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing. We take steps to ensure that any natural person acting under our authority who has access to personal data does not process it except on our instructions, unless they are required to do so by applicable law. In assessing the appropriate level of security, we take into account the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed. We ensure appropriate safeguards are in place when transferring personal data outside ADGM and the UAE, in compliance with Data Protection Laws, including through adequacy decisions, standard contractual clauses, or other appropriate safeguards as recognised under the applicable regulations.

• Your Rights Under ADGM Data Protection Regulations

Under the Data Protection Laws, you have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and information including: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period.

You may have the following additional rights as an individual which you can exercise in relation to the information held about you under certain circumstances. These rights are to:

• request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
• request rectification of your personal data;
• request the restriction of processing of your personal data;
• object to the processing of your personal data; 
• request erasure of your personal data subject to certain conditions set out in the Data Protection Laws; and
• request the transfer of your personal data to another party.

To exercise these rights, please contact us using the details provided in the Contact Us section below. We may require further information from you in order to carry out any of the above requests. We may ask you to provide proof of your identity. To exercise these rights, please contact us using the details provided in the “Contact Information” section below. We will respond to your request without undue delay and in any event within two months of receipt of the request. That period may be extended by one further month where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within two months of receipt of the request, together with the reasons for the delay. We may require further information from you to verify your identity and may ask you to provide proof of your identity. Please note that some rights may not apply in all circumstances, and we may need to retain certain personal data to comply with our legal obligations or for the exercise or defence of legal claims.

• Data Protection Officer

We have appointed a Data Protection Officer in accordance with section 35 of the ADGM Data Protection Regulations 2021. Our Data Protection Officer is responsible for monitoring compliance with Data Protection Laws, providing advice on data protection matters, acting as a contact point for data subjects and the Commissioner of Data Protection, and conducting data protection impact assessments.

• Personal Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Commissioner of Data Protection within 72 hours of becoming aware of the breach. Where the breach is likely to result in a high risk to your rights and freedoms, we will also communicate the breach to you without undue delay. We maintain records of all personal data breaches, including the facts relating to the breach, its effects and the remedial action taken.

• Third-Party Links and Services

We ensure appropriate safeguards are in place when transferring personal information outside the ADGM and the UAE, in compliance with Data Protection Laws. Transfers will only take place where the Commissioner of Data Protection has decided that the third country, territory, sector, or international organisation ensures an adequate level of protection.

Our website may contain links to third-party websites, services, or applications that are not operated by us. This Privacy Policy does not apply to these third-party services, which have their own privacy policies and terms of use. We are not responsible for the privacy practices or content of third-party websites or services. We encourage you to review the privacy policies of any third-party services you access through our website. When you interact with third-party services through our website (such as social media plugins or embedded content), those services may collect information about you according to their own privacy policies.

We do not sell your personal information to third parties.

• Children’s Privacy 

Our website and services are not directed to children under the age of 18, and we do not knowingly collect personal data from children under 18. If we become aware that we have collected personal data from a child under 18, we will take steps to delete such information promptly. 

If you are a parent or guardian and believe that your child has provided us with personal data, please contact us using the information provided below. 

• Cookie Policy

Cookies: Cookies are small pieces of encrypted text saved in your web browser by a website you visit. Encrypted text can on be read by the website it was saved by. A cookie file is stored in your web browser and allows our website or a third-party to recognize you and make your next visit easier and our website more useful to you. Cookies can be “persistent” or “session” cookies.

How https://www.hashgraphvc.com/ and its affiliate sites uses cookies: When you use and access the https://www.hashgraphvc.com/, we may place a number of cookies files in your web browser.

We use cookies for the following purposes: to enable certain functions of the https://www.hashgraphvc.com/, to provide analytics, to store your preferences, to enable advertisements delivery, including behavioural advertising.

Session and Persistent Cookies: We may also use both session and persistent cookies on the https://www.hashgraphvc.com/ and its affiliate websites, and we use different types of cookies to run the https://www.hashgraphvc.com/.

Essential cookies: We may use essential cookies to authenticate users and prevent fraudulent use of user accounts.

Sharing Cookie Data: We may share any information and data with third parties based on your permission obtained for receiving information on special offers by using this site and you hereby explicitly agree to the collection and use of the said data by us for the purpose described above.

We and/or third parties may use such information or data to identify you on social media platforms in order to provide you with the latest products, offers or incentives offered by us or such third parties.

Third-party cookies: In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of https://www.hashgraphvc.com/, deliver advertisements on and through https://www.hashgraphvc.com/, and so on.

What are your choices regarding cookies: If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

• Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

Notification of Changes 

When we make changes to this Privacy Policy, we will update the “Last Updated” date at the top of this policy and post the updated policy on our website. For material changes, we may provide additional notice through email.

Material Changes 

For substantial changes that materially affect how we collect, use or share your personal data, we will provide advance notice and, where required by law, seek your consent for the new practices. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

• Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us: Hashgraph Ventures Manager Ltd

Hashgraph Ventures Manager Ltd
15-121, 15th Floor,
Al Khatem Tower, 
Abu Dhabi Global Market Square, Al Maryah Island, 
Abu Dhabi, United Arab Emirates

info@hashgraphvc.com

Regulatory Contact 

You have the right to lodge a complaint with the ADGM Commissioner of Data Protection or the UAE Office of Data Protection regarding our processing of your personal data. If you wish to make a complaint about our data processing practices, you may contact: 

Commissioner of Data Protection 
ADGM Office of Data Protection 
Abu Dhabi Global Market Al Maryah Island, 
Abu Dhabi, UAE 
Website: www.adgm.com