Privacy notice

Please read this Privacy Notice carefully, as it sets out how Alpheya may use your personal information. Personal information is processed in accordance with the applicable Data Protection Regulations.

Last updated: 13 August 2026

  • 1.
    About this Privacy Notice

    Quantum Wealth Tech Limited, trading as Alpheya (“Alpheya”, “we”, “us” or “our”), is registered in the Abu Dhabi Global Market (“ADGM”).

    This Privacy Notice explains how and why we collect, use, store, disclose and otherwise Process Personal Data, the circumstances in which we may share or transfer it, how long we retain it, and the rights individuals may have in relation to their Personal Data.

    Quantum Wealth Tech Limited is subject to the ADGM Data Protection Regulations 2021 (the “ADGM DPR”). Depending on the nature and location of a particular Processing activity, other data protection or privacy laws may also apply.

    Where Alpheya determines the purposes and means of Processing Personal Data, Alpheya acts as a Controller.

    In certain circumstances, particularly where Alpheya provides technology or other services to its customers, Alpheya may Process Personal Data on behalf of a customer as a Processor. In those circumstances, the relevant customer generally determines the purposes and means of the Processing and is responsible for providing applicable privacy information to the individuals concerned. Alpheya will Process such Personal Data in accordance with the customer’s documented instructions, the applicable agreement and Applicable Data Protection Law.

    This Privacy Notice principally applies to Personal Data for which Alpheya acts as a Controller.

  • 2.
    Who This Privacy Notice Applies To

    This Privacy Notice applies to Personal Data that Alpheya Processes as a Controller in relation to individuals including:

    1. visitors to Alpheya’s website;
    2. individuals who contact or correspond with Alpheya;
    3. representatives, employees and other contacts of existing or prospective customers, suppliers, service providers and business partners;
    4. individuals who attend trade shows, conferences, meetings or other events at which Alpheya participates;
    5. individuals who request or receive information about Alpheya, its products, services or activities; and
    6. individuals who apply for employment or other roles with Alpheya.

    Where Alpheya Processes Personal Data solely as a Processor on behalf of a customer, the customer’s privacy notice or other privacy information will generally apply to that Processing.

  • 3.
    How We Collect Personal Data

    We may collect Personal Data in a number of ways.

    3.1

    Information You Provide Directly

    We may collect Personal Data directly from you when you:

    1. use or submit information through our website;
    2. contact us by telephone, email or other correspondence;
    3. make an inquiry, request or complaint;
    4. attend a meeting, conference, trade show or other event;
    5. engage with Alpheya in connection with an existing or proposed commercial or professional relationship;
    6. request information about our products or services; or
    7. apply for employment or another role with Alpheya.

    3.2

    Information Collected Automatically

    When you use our website or interact with certain electronic communications, we may automatically collect technical or usage information through cookies and similar technologies.

    Further information about the use of cookies is available in Alpheya’s Cookies Policy.

    3.3

    Information Obtained from Third Parties

    Where permitted by Applicable Data Protection Law, we may obtain Personal Data from third parties where relevant to our relationship or dealings with you.

    These may include, depending on the circumstances:

    1. your employer or organization;
    2. business partners or counterparties;
    3. event organizers;
    4. recruitment agencies and referees;
    5. professional advisers;
    6. public or professional sources; and
    7. other persons or organizations that lawfully provide Personal Data to us.
  • 4.
    Personal Data We Collect

    The Personal Data we collect depends on how you interact with Alpheya and the purpose for which the information is required.

    We may collect the following categories of Personal Data.

    4.1

    Identity and Contact Information

    This may include:

    1. name;
    2. email address;
    3. telephone number;
    4. postal or business address;
    5. employer or organization;
    6. job title; and
    7. other contact details you provide to us.

    4.2

    Business and Professional Information

    Where you interact with Alpheya in a professional or commercial capacity, we may collect information relating to:

    1. your employer or organization;
    2. your role and professional responsibilities;
    3. your business relationship with Alpheya;
    4. meetings, events or other interactions with us;
    5. contractual or commercial correspondence; and
    6. other information relevant to an existing or prospective business relationship.

    4.3

    Communications and Inquiries

    We may collect Personal Data contained in:

    1. website inquiries;
    2. emails;
    3. telephone calls;
    4. complaints or requests;
    5. meeting records;
    6. correspondence; and
    7. information you otherwise submit or upload to Alpheya.

    4.4

    Website and Technical Information

    When you use our website, we may collect information relating to your use of the website and your device, which may include:

    1. IP address;
    2. browser and device information;
    3. website activity and interaction information;
    4. logs; and
    5. information collected through cookies or similar technologies.

    4.5

    Events and Marketing Information

    Where relevant, we may collect information relating to:

    1. attendance at trade shows, conferences or other events;
    2. requests for updates or information;
    3. business interests or professional areas relevant to your dealings with Alpheya; and
    4. communications preferences.

    4.6

    Recruitment Information

    If you apply for a role with Alpheya, we may collect Personal Data relevant to the recruitment process.

    Depending on the stage of the recruitment process and the role concerned, this may include:

    1. name and contact information;
    2. nationality and age or date of birth, where relevant or required;
    3. academic and professional qualifications;
    4. experience certificates and reference information;
    5. resumes and CVs;
    6. employment history;
    7. remuneration and benefits information; and
    8. dependent or beneficiary information where relevant at a later stage of the recruitment or onboarding process.

    We will only collect and Process recruitment information that is reasonably necessary for the relevant recruitment, onboarding, legal or administrative purpose.

  • 5.
    How We Use Personal Data

    We may use Personal Data for the following purposes:

    1. operating and providing our website;
    2. providing information about Alpheya and its products and services;
    3. responding to inquiries, requests and complaints;
    4. establishing, administering and managing commercial and legal relationships;
    5. providing products and services;
    6. communicating with existing and prospective customers, suppliers, service providers and business partners;
    7. managing conferences, trade shows, meetings and other events;
    8. providing updates or other communications about our products, services or activities;
    9. improving and developing our website, products, services and business operations;
    10. conducting appropriate market or business research;
    11. maintaining internal business, operational and administrative records;
    12. protecting the security and integrity of our website, systems, information and proprietary materials;
    13. detecting, preventing and investigating unauthorized use, security incidents, fraud or other unlawful activity;
    14. recruiting and assessing candidates;
    15. managing employment-related recruitment and onboarding activities;
    16. establishing, exercising or defending legal rights and claims;
    17. complying with legal, regulatory, audit and compliance obligations;
    18. responding to lawful requests from courts, regulators, law-enforcement bodies and other competent authorities; and
    19. managing and operating Alpheya’s business.

    We will not Process Personal Data for a purpose that is incompatible with the purpose for which it was collected unless that further Processing is permitted under Applicable Data Protection Law.

  • 6.
    Lawful Bases for Processing

    We only Process Personal Data where there is an appropriate lawful basis under Applicable Data Protection Law.

    Under the ADGM DPR, depending on the circumstances, Alpheya may rely on one or more of the following lawful bases.

    6.1

    Performance of a Contract

    We may Process Personal Data where Processing is necessary:

    1. to perform a contract to which you are a party; or
    2. to take steps at your request before entering into a contract.

    6.2

    Compliance with a Legal Obligation

    We may Process Personal Data where necessary to comply with a legal or regulatory obligation applicable to Alpheya.

    6.3

    Legitimate Interests

    We may Process Personal Data where Processing is necessary for legitimate interests pursued by Alpheya or a third party, provided those interests are not overridden by your interests, rights or freedoms.

    Depending on the circumstances, these legitimate interests may include:

    1. operating and developing our business;
    2. managing business and professional relationships;
    3. responding to business communications and inquiries;
    4. improving our products, services and website;
    5. maintaining the security and integrity of our systems and information;
    6. preventing misuse of systems or proprietary materials;
    7. managing and administering our operations;
    8. conducting appropriate business development activities; and
    9. establishing, exercising or defending legal rights.

    6.4

    Consent

    Where we rely on consent, we will obtain it in accordance with Applicable Data Protection Law.

    Where the ADGM DPR applies, consent must be freely given, specific, informed and unambiguous and must be given through a statement or clear affirmative action.

    You may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of Processing carried out on the basis of consent before it was withdrawn.

    Where applicable, consent may be withdrawn through the relevant unsubscribe or withdrawal mechanism or by contacting us at privacy@alpheya.com.

    6.5

    Other Lawful Bases

    Where appropriate, Alpheya may rely on another lawful basis available under Applicable Data Protection Law, including where Processing is necessary to protect the vital interests of an individual or otherwise permitted by law.

  • 7.
    Special Categories of Personal Data

    Certain types of Personal Data are subject to enhanced protection under Applicable Data Protection Law.

    Alpheya does not seek to collect Special Categories of Personal Data unless such information is relevant and necessary for a lawful purpose.

    Where we Process Special Categories of Personal Data, including in connection with recruitment or employment, we will only do so where a lawful basis and any additional condition required under Applicable Data Protection Law applies.

  • 8.
    Marketing Communications

    Where permitted by Applicable Data Protection Law, we may use your business or contact information to provide information about Alpheya, its products, services, events or other activities that may be relevant to you.

    Where consent is required for a particular marketing communication, we will obtain consent before sending that communication.

    You may opt out of marketing communications at any time by using the unsubscribe mechanism included in the relevant communication or by contacting us at privacy@alpheya.com.

    Opting out of marketing communications will not prevent Alpheya from sending communications that are necessary for an existing business, contractual, legal or regulatory relationship.

  • 9.
    If You Do Not Provide Personal Data

    In some circumstances, we need certain Personal Data in order to:

    1. respond to a request or inquiry;
    2. provide information, products or services;
    3. enter into or perform a contract;
    4. assess an employment application;
    5. establish or manage a business relationship; or
    6. comply with legal or regulatory obligations.

    Where such Personal Data is required and is not provided, we may be unable to provide the relevant information, service or product, proceed with a relationship or application, or fulfill your request.

    Where appropriate, we will indicate whether providing particular Personal Data is mandatory or optional.

  • 10.
    Sharing Personal Data

    We may share Personal Data where reasonably necessary for the purposes described in this Privacy Notice and where permitted by Applicable Data Protection Law.

    Depending on the circumstances, we may share Personal Data with:

    1. other entities within the Alpheya group where necessary for legitimate administrative, business or operational purposes;
    2. service providers, contractors and suppliers providing services to Alpheya, including information technology, hosting, communications and other business support services;
    3. professional advisers, including lawyers, accountants, auditors, insurers and consultants;
    4. recruitment agencies, screening providers, referees and other persons involved in recruitment or onboarding;
    5. business partners and counterparties where appropriate to the relevant relationship;
    6. courts, regulators, law-enforcement bodies, government authorities and other competent authorities where disclosure is required or permitted by law;
    7. parties involved in an actual or proposed merger, acquisition, investment, financing, restructuring, sale of business or assets or similar corporate transaction; and
    8. other persons where you have authorized the disclosure or where disclosure is otherwise permitted by Applicable Data Protection Law.

    Where a third-party Processes Personal Data on our behalf as a Processor, Alpheya will take appropriate steps to ensure that the Processing is governed by appropriate contractual and data protection requirements.

    We will not share Personal Data for purposes incompatible with those described in this Privacy Notice unless permitted under Applicable Data Protection Law.

  • 11.
    International Transfers

    Because Alpheya operates internationally and may use service providers, group entities or systems in different locations, Personal Data may be transferred to, accessed from or otherwise Processed in jurisdictions outside ADGM.

    Under the ADGM DPR, making Personal Data available to a recipient outside ADGM may constitute an international transfer, including where the recipient is elsewhere in the United Arab Emirates.

    Where the ADGM DPR applies, Alpheya will only transfer Personal Data outside ADGM where the requirements of the ADGM DPR are satisfied.

    Depending on the circumstances, this may include:

    1. transferring Personal Data to a jurisdiction recognized by the ADGM Commissioner of Data Protection as providing an adequate level of protection;
    2. using appropriate safeguards permitted under the ADGM DPR, including the ADGM Standard Contractual Clauses where appropriate;
    3. relying on approved Binding Corporate Rules or another approved safeguard; or
    4. relying on an applicable derogation where permitted under the ADGM DPR.

    Where another Applicable Data Protection Law applies, Alpheya will also comply with any additional international transfer or data localization requirements imposed by that law.

    You may contact privacy@alpheya.com for further information about the safeguards applicable to transfers of your Personal Data, subject to any lawful limitations or redactions.

  • 12.
    Data Security

    Alpheya implements appropriate technical and organizational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access and other unlawful Processing.

    The measures applied are determined having regard to factors including:

    1. the nature, scope, context and purposes of the Processing;
    2. the sensitivity and volume of the Personal Data;
    3. the likelihood and severity of risks to individuals;
    4. the available state of technology; and
    5. the circumstances in which the Personal Data is Processed.

    Access to Personal Data is limited to employees, contractors, service providers and other persons who require access for legitimate purposes and who are subject to appropriate confidentiality, security and access requirements.

    Alpheya also maintains processes for responding to suspected or confirmed Personal Data breaches and will notify affected individuals and the relevant supervisory authority where required by Applicable Data Protection Law.

  • 13.
    Data Retention

    Alpheya retains Personal Data only for as long as reasonably necessary for the purposes for which it was collected or otherwise lawfully Processed.

    The applicable retention period will depend on factors including:

    1. the nature and sensitivity of the Personal Data;
    2. the purposes for which it is Processed;
    3. applicable legal, regulatory, accounting, audit and contractual requirements;
    4. applicable limitation periods;
    5. the existence of an actual or reasonably anticipated dispute, investigation or legal claim; and
    6. whether continued retention is otherwise required or permitted by Applicable Data Protection Law.

    Where Personal Data is no longer required and there is no lawful basis for continuing to Process it, Alpheya will take appropriate steps to securely delete, anonymize or otherwise cease Processing the Personal Data in accordance with Applicable Data Protection Law and Alpheya’s applicable retention and disposal procedures.

  • 14.
    Automated Decision-Making

    Alpheya does not currently make decisions about individuals based solely on automated Processing, including Profiling, that produce legal effects or similarly significant effects on those individuals.

    If Alpheya introduces such Processing in the future, we will provide the information and safeguards required by Applicable Data Protection Law.

  • 15.
    Your Rights

    Where the ADGM DPR applies, and subject to the conditions, restrictions and exemptions contained in those Regulations, you may have the following rights in relation to your Personal Data.

    15.1

    Right to Be Informed

    You have the right to receive clear and transparent information about how your Personal Data is Processed.

    15.2

    Right of Access

    You may request confirmation as to whether Alpheya Processes Personal Data relating to you and, where applicable, request access to that Personal Data and related information.

    15.3

    Right to Rectification

    You may request correction of inaccurate Personal Data or completion of incomplete Personal Data.

    15.4

    Right to Erasure

    In circumstances provided by Applicable Data Protection Law, you may request deletion of your Personal Data.

    This right is not absolute and may not apply where Alpheya is required or permitted to continue retaining or Processing the Personal Data.

    15.5

    Right to Restriction

    In circumstances provided by Applicable Data Protection Law, you may request that Alpheya restrict Processing of your Personal Data.

    15.6

    Right to Data Portability

    Where applicable, you may have the right to receive certain Personal Data in a structured, commonly used and machine-readable format and to request its transfer to another Controller.

    15.7

    Right to Object

    You may have the right to object to certain Processing of your Personal Data, including Processing based on legitimate interests.

    You also have the right to object to Processing for direct marketing purposes.

    15.8

    Right to Withdraw Consent

    Where Processing is based on consent, you may withdraw that consent at any time.

    Withdrawal of consent will not affect the lawfulness of Processing carried out before such consent was withdrawn.

    15.9

    Rights Relating to Automated Decision-Making

    Where Applicable Data Protection Law applies, you may have rights relating to decisions based solely on automated Processing, including Profiling, that produce legal or similarly significant effects.

  • 16.
    Exercising Your Rights

    Requests to exercise your privacy rights may be submitted to:

    privacy@alpheya.com

    We may ask you to provide additional information where reasonably necessary to confirm your identity or clarify your request.

    Under the ADGM DPR, Alpheya will respond to valid requests without undue delay and normally within two months of receipt.

    Where permitted under the ADGM DPR, this period may be extended by a further month where necessary due to the complexity or number of requests. If an extension is required, we will inform you within the initial two-month period and explain the reasons for the extension.

    Requests are generally handled free of charge.

    Where permitted by Applicable Data Protection Law, Alpheya may charge a reasonable administrative fee or refuse to act on a request that is unreasonable or excessive, in particular because it is repetitive.

    Where Alpheya refuses to act on a request, we will provide the information required by Applicable Data Protection Law regarding that decision.

  • 17.
    Complaints and Questions

    If you have any questions, concerns or complaints about this Privacy Notice or about how Alpheya Processes your Personal Data, please contact us in the first instance at:

    privacy@alpheya.com

    We will review privacy-related inquiries and complaints and seek to resolve them in accordance with Applicable Data Protection Law.

    Where the ADGM DPR applies and you are not satisfied with our response, you may lodge a complaint with the ADGM Commissioner of Data Protection.

    The Commissioner of Data Protection may be contacted using the contact information published by the ADGM Office of Data Protection.

    Where another Applicable Data Protection Law applies, you may also have the right to lodge a complaint with the competent supervisory or data protection authority under that law.

  • 18.
    Cookies

    Our website uses cookies and similar technologies.

    Cookies may be used to collect information about website usage and to help understand how visitors interact with the website.

    Further details about the types of cookies used, their purposes and available choices are provided in Alpheya’s Cookies Policy.

  • 19.
    Third-Party Websites

    Alpheya’s website or communications may contain links to websites or services operated by third parties.

    Alpheya is not responsible for the privacy practices, security or content of websites or services that are not controlled by Alpheya.

    You should review the applicable privacy notice of any third-party website or service before providing Personal Data to it.

  • 20.
    Changes to This Privacy Notice

    We may update this Privacy Notice from time to time to reflect changes to:

    1. our Processing activities;
    2. our products, services or business practices;
    3. applicable legal or regulatory requirements; or
    4. relevant guidance or regulatory expectations.

    The current version of this Privacy Notice will be published on Alpheya’s website and will state when it was last updated.

    Where required by Applicable Data Protection Law, we will provide additional notice of material changes.

  • 21.
    Contact Details
    Quantum Wealth Tech Limited (Alpheya)Registered in the Abu Dhabi Global MarketUnit 5, 8, Al Sarab TowerADGM Square, Al Maryah IslandAbu Dhabi, United Arab EmiratesPrivacy inquiries: privacy@alpheya.comWebsite: www.alpheya.com
  • 22.
    Definitions

    For purposes of this Privacy Notice:

    • Applicable Data Protection Law means the data protection and privacy laws applicable to the relevant Processing activity, including the ADGM Data Protection Regulations 2021 and, where their respective scope requirements are satisfied, other applicable data protection and privacy laws.
    • Controller means the person or entity that, alone or jointly with others, determines the purposes and means of Processing Personal Data.
    • Personal Data means information relating to an identified or identifiable natural person.
    • Information that has been anonymized so that an individual is no longer identifiable is not Personal Data.
    • Processing means any operation or set of operations performed on Personal Data, whether or not by automated means, including collection, recording, organization, storage, alteration, retrieval, consultation, use, disclosure, transfer, restriction, deletion or destruction.
    • Processor means a person or entity that Processes Personal Data on behalf of a Controller.
    • Profiling means automated Processing of Personal Data involving the use of Personal Data to evaluate certain personal aspects relating to an individual.
    • Special Categories of Personal Data means categories of Personal Data that receive additional protection under Applicable Data Protection Law, including categories specified as such under the ADGM DPR.