​​​​​​​Privacy Policy

Effective Date: August 2023

Valuable Capital Financial Company (“we”, “us” or “VCF”) respects your privacy and is

committed to protecting the privacy and security of your Personal Data. This Privacy Policy

describes how and when we collect, use, process and share your information across our websites,

mobile applications ("apps"), SMS, APIs, email notifications, buttons, and our other covered

services to which this Privacy Policy applies (collectively, the “Services”).

This Privacy Policy applies to all Personal Data we collect about you when you access or use our

Services. The contents of this Privacy Policy, as outlined below, form an integral part of

conditions for accessing or using VCF’s Services. VCF will not collect your Personal Data

unless you agree to provide us with such information. By accessing or using the Services, you

thereby confirm that you have read, understood, and agreed to our collection, storage, use, and

disclosure of your Personal Data as described in this Privacy Policy.

Our Services are not intended for any natural person under the age of 18 and we do not

knowingly collect Personal Data relating to any natural person under the age of 18.

It is important that you read this Privacy Policy carefully together with the VCF’s general terms

and conditions of use available at https://www.vcfc.sa/ so that you are fully aware of how and

why we are using your Personal Data.

 Personal Data We Collect and How We Collect it

 Why We Collect and How We Use Personal Data

 Cookies and Similar Technologies

 How We Share Personal Data

 How We Transfer Personal Data

 How We Secure Personal Data

 Retention of Personal Data

 Contacts, Notices, and Revisions

Page 1 of 71. Personal Data We Collect and How We Collect it

We may collect your Personal Data about you in the course of providing Services for you.

“Personal Data” means any data that specifically identifies an individual (such as a name,

address, photo, telephone number, mobile number, email address, birthday, office

location, professional and personal interests, company name, title, department, spoken

languages) or data about that individual that is directly linked to personally identifiable

information. It does not include data where the identity has been removed (anonymous

data).

Here are the types of Personal Data we may collect about you:

1.1 Personal Data You Provide

We collect Personal Data you provide as described below when you access or use our

Services or otherwise engage or communicate with us. For example, when you choose to

create an investment account on our apps with your email address or mobile phone

number, you will be asked to fill in Know Your Client Form under the applicable laws

and regulations and we will collect these kinds of identity data, contact data and financial

data.

Identity Data, such as your full name, date of birth, ID numbers/passport No., marital

status, educational level, citizenship, biometric identifiers, and other data on government-

issued identification documents;

Contact Data, such as your email address, mailing address, office location, residential

address and telephone number;

Financial Data, such as your bank account and payment card details, and information

about your income, account balances, financial transaction history, debit card numbers,

credit history, tax information, and credit scores;

Profile Data, such as your username, your employment information, your

knowledge/risk assessment results, your interests, preferences, feedback, and survey

responses; and

Stored Data, such as your device camera and photo album when you upload photos or

device calendar in your mobile device with your permission when you want to add alerts

or economic data to your calendars. We only collect this kind of data with your

permission; and;

Page 2 of 7Additional Data You Provide, such as via focus groups, survey responses,

contests/sweepstakes, customer support, or other means.

1.2 Personal Data We Collect Automatically

When you access or use our Services, we also collect certain Personal Data about you

automatically as described below.

Usage Data: We collect information about your activity on our Services, which includes

device identifiers (like IP address or mobile device identifiers), pages or features you use,

time and date of access, and other similar usage information.

Transactional Data: When you receive, submit, or complete a transaction via VCF’s

platforms, we collect data about the transaction, such as transaction amount, type and

nature of the transaction, and time and date of the transaction.

Data Collected Through Cookies and Similar Technologies: We also use technologies,

including cookies and similar technologies, to automatically collect certain types of usage

and device data when you access or use our Services or interact with others in connection

with the Services. The data collected through these technologies includes your IP address,

browser type, Internet service provider, platform type, device type, operating system, date

and time stamp, a unique device or account ID, usage data and other similar information.

1.3 Information We Collect from Other Sources

We also obtain Personal Data about you from other sources as described below.

Vendors and Business Partners: Subject to your prior written consent, we may collect

information about you from companies that we do business with, such as name, contact

data, inferences about your preferences and attributes, as well as inferred fraud risk, from

identity verification and fraud prevention partners.

Connected Services. Subject to your prior written consent, if you link, connect, or log in

to your VCF’s Account with a third-party service provider (e.g., Google, Apple), the

third-party service provider may send us information such as your profile information

from that service. This information varies and is controlled by that service or as

authorized by you via your privacy settings at that service.

Page 3 of 7Publicly Available Data. We collect content that you share publicly in connection with

our Services, including contact information, your interactions with our social media

platforms, and other information from publicly available sources, such as public websites.

Advertising Data. We collect information in connection with our ad campaigns that

surface on other platforms, such as the ads you clicked on and other interactions with our

ads. Please note that we also collect, use and share aggregated data for any purpose, such

as statistical or demographic data, which may be derived from your Personal Data but is

not considered as Personal Data since it does not directly or indirectly reveal your

identity under the applicable laws and regulations. In no event will we collect any

Personal Data about your race or ethnicity, religious or philosophical beliefs, sexual

orientation, political opinions, trade union membership, and genetic characteristics,

unless required by applicable laws and regulations. Nor do we collect any information

about criminal convictions and offenses.

2. Why We Collect and How We Use Personal Data

To provide our Services: We use your Personal Data to provide our Services for you,

including setting up and maintaining your account, processing transactions on your

instruction, providing customer support and completing payments.

To measure and improve our Services: By monitoring and analyzing how users interact

with our Services to help us measure, understand and forecast users’ performance and

preferences to improve and develop our products and services; by detecting security

incidents to fix problems with our Services;

To market and promote our Services. We may use your Personal Data to market and

promote our Services. We might send you marketing information about the Services and

other information which we believe may be of interest to you or be relevant to you, to

promote our products and services.

To Prevent Fraud and Abuse and Credit Risks: By detecting and protecting against

malicious, deceptive, fraudulent, or illegal activity to protect the security of our clients,

VCF and others.

To Comply with Legal Obligations: In certain cases, we have a legal obligation to

collect, use, process or retain your Personal Data. For example, we are required to collect

your identity and financial information when you access to our Services, in accordance

with the laws and regulations of Saudi Arabia.

Page 4 of 7To communicate with you: By different channels to communicate with you in relation

to our Services, such as texting you to verify your account, sharing information with you

we think will be of interest to you, emailing you to ask for your feedback or respond to

your requests. If you don’t want to hear from us, you can opt out of communications at

any time.

3. Cookies and Similar Technologies

VCF may use cookies and similar technologies to support the operation of our Services.

Cookies are small amounts of data that a website or online service exchanges with a web

browser or application on a visitor's device (for example, computer, tablet, or mobile

phone). Cookies help us to collect data about users of our Services, including date and

time of visits, pages viewed, and amount of time spent using our Services, or general

information about the device used to access our Services. For cookies in our Services,

you can manage Cookies in the content settings as your preference. At the same time, you

can enable “Do Not Track” (“DNT”) feature so that you will not be tracked by cookies.

4. How We Share Personal Data

Data about our clients is an important part of our business and we are not in the business

of selling our clients’ Personal Data to others, nor do we ever do so. We share Personal

Data only as described below:

Share with Third-Party Service Providers: We may engage third-party service

providers to perform functions and provide services. For example, we use a variety of

third-party services to help us understand and improve the use of our Services. Subject to

your prior written consent, we may share your Personal Data with such service providers

subject to obligations consistent with this Privacy Policy and any other appropriate

confidentiality and security measures, and on the condition that the third parties use your

Personal Data only on our behalf and pursuant to our instructions. These third-party

service providers have access to Personal Data needed to perform their functions, but

may not use it for other purposes. Further, they must process that data in accordance with

this Privacy Notice and as permitted by applicable data protection law.

Share with Affiliates: Subject to your prior written consent, we may share Personal Data

about you with various VCF corporate affiliates including internal service providers

which perform software development services or, data processing and analyzing services,

again subject to obligations consistent with this Privacy Policy and any other appropriate

confidentiality and security measures, and on the condition that the affiliates use your

Personal Data only on our behalf and pursuant to our instructions. Additionally, if you

interact with VCF directly as an individual investor (including joint account holders), we

Page 5 of 7may exchange certain information for their use in marketing products and services as

allowed by law.

Protection of VCF and Others: Notwithstanding anything to the contrary in this Privacy

Policy, we may preserve or disclose your Personal Data if we believe that it is reasonably

necessary to comply with a law, regulation, legal process, or governmental request; to

protect the safety of any person; to address fraud, security or technical issues; or to

protect our or our clients’ rights or property. However, nothing in this Privacy Policy is

intended to limit any legal defenses or objections that you may have to a third party’s,

including a government’s, request to disclose your information.

Share Your Public Data: We may share or disclose your public Data, such as your

public user profile information, public comments.

5. How We Transfer Personal Data

We will not transfer Personal Data outside the Kingdom or disclose it to a party outside

the Kingdom of Saudi Arabia unless permitted by the applicable laws and regulations.

Subject to the applicable laws and regulations, your Personal Data, excluding the

sensitive data, may be transferred to the country or region where you use our product and

services or where our affiliate locates with your authorization and consent, and such

Personal Data will have a fully compliant level of protection outside the Kingdom.

6. How We Secure Personal Data

We have put in place appropriate security measures to limit the possibility of your

Personal Data from being accidentally lost, used or accessed in an unauthorized way,

altered or disclosed. In addition, we limit access to your Personal Data to those

employees, agents, contractors and third-party service providers who have a business

need to know. They will only process your Personal Data on our instructions and they are

subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and

will notify you and any applicable regulator of a breach where we are legally required to

do so.

7. Retention of Personal Data

We will only retain your Personal Data for as long as necessary to fulfill the purposes we

collected it for, including for the purposes of satisfying any legal, accounting, or

reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount,

nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized

Page 6 of 7use or disclosure of your Personal Data, the purposes for which we process your Personal

Data and whether we can achieve those purposes through other means, and the applicable

legal requirements. In some circumstances, we may anonymize your Personal Data (so

that it can no longer be associated with you) for research or statistical purposes in which

case we may use this information indefinitely without further notice to you.

8. Contacts, Notices, and Revisions

If you have any questions, comments or suggestions regarding this Privacy Policy or the

collection or use of Personal Data, please contact us at legal@vcfc.sa.

We may revise this Privacy Policy from time to time. The most current version of the

policy will govern our use of your Personal Data. If we make any change to this Privacy

Policy, in our sole discretion, is material, we will update the policy on our website

without a separate notification sent to you. Please pay attention to the most updated

version of our Privacy Policy on our website, at https://www.vcfc.sa/ . By continuing to

access or use the Services after those changes become effective, you agree to be bound by

the revised Privacy Policy.