Privacy Policy

Last updated on “31 of July, 2024”

This Privacy Policy (hereinafter also referred as “Policy”) along with Terms of Use and Cookie Policy constitutes an agreement between You and Sabai Private Fund. Inc with registered address at Torre Advanced Building, first floor, Ricardo Arias Street, Panama, Republic of Panama registration number 155745623 (hereinafter also referred as “Company”).

We take your privacy seriously, and are committed to a Panamanian and all-european privacy security framework. In this Policy we desire to outline rules of processing your personal data.

If you have any questions regarding this policy, don’t hesitate to contact us at [email protected].

DISCLAIMER. By visiting, accessing or using our Website you consent to this Privacy Policy, so please read it carefully. If you consider any term or condition of this Privacy Policy to be unacceptable, please do not visit, access or use the Website of Company.

General Provisions

Company developers acts as a controller of your personal data. Personal data means any information relating to an identified or identifiable 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.

DISCLAIMER. We do not intentionally collect any information about minors. In addition, the Company does not knowingly gather information about natural persons recognized by the court as incapacitated or partially incapacitated, which means the inability of such natural persons to legally enter into relationships with Us and the inability to understand the meaning of their actions.

This Policy is drafted in accordance to the Panamanian and international standards, which is prescribed in the General Data Protection Regulation (2016/679) of the European Parliament and Council of the 27 April 2016 (hereinafter referred to as the “GDPR”) and Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018).

General Provisions

Company may process your personal data in different ways and using different methods, including but not limited to collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Company processes personal data for the following purposes:

To provide our services to you in as thorough and comprehensive a manner as possible.
To analyze how You use our Website.
To improve and enhance Your experience with our Website.
To fulfill a contract we have with you or with a third party on your behalf, without compromising your rights and interests.
To safeguard our lawful interests or those of a third party, unless your interests or fundamental rights and freedoms, which necessitate personal data protection, take precedence.
To carry out market research surveys.
To promote our products and services to you, but only with your explicit consent.
To adhere to applicable laws, regulations, and other legal responsibilities we are bound by.
To provide you with information regarding our products and services.
To identify, prevent, and respond to actual or potential instances of fraud, illegal activities, or violations of intellectual property rights.
To carry out market research surveys.

Also we may use your personal data in non-personalised form for the following purposes:

To create comprehensive marketing profiles.
To support strategic planning and development.
To assess the utilization of the website.

You typically provide us with your personal data directly by interacting with Us in the following ways:

Visiting our Website.
Applying for our services.
Requesting marketing materials to be sent to you, for example by subscribing to Company newsletters.
Providing feedback or contacting us.

Company will also use third parties and/or publicly available sources to obtain data related to you. Company may use the following sources:

Fraud and crime prevention agencies.
Publicly available information on the Internet.

Types of Data We Collect

Depending on the type of interaction with Us (visiting Website or requesting services) we may collect different types of data to offer you the best experience. We may collect the following data:

Full Name
Date of Birth
Marital Status
Postal address (including billing and shipping addresses)
Telephone number
Email address
Organization and job title or function
Passport or ID Number
Criminal Record (only when processing is authorized by the Laws of the Republic of Panama)
Source of Wealth
Bank Account Details

Your personal information is gathered when you utilize our inquiry and registration forms or when you contact us via email. Additionally, we automatically collect information about your website visit and browsing patterns. This aggregated data is solely used to enhance our website and services. Rights of the User

If you have any questions, problems, issues, or complaints, contact Company at [email protected]. Under the GDPR, Company has 1 month to respond to your request, and this period may be extended to 3 months due to the complexity and difficulty of your issue. If you are not satisfied with Company’s resolution of your concern, you can contact authorities in the field of private data protection.

Under the GDPR, You have the following rights related to your personal information:

Right to be informed: Your right to be informed is fulfilled through the provision of this Privacy Policy and similar information when Company communicates with you directly, at the point of contact.
Right of access: You have the right to obtain a copy of personal data that Company holds about you and other information specified in the GDPR, although there are exceptions to what Company is obliged to disclose.
Right to rectification: You have the right to request us to correct any inaccurate data that Company holds about you.
Right to erasure (‘right to be forgotten’): You have the right to request that Company erase personal data about you that they hold. This is not an absolute right, and depending on the legal basis that applies, Company may have overriding legitimate grounds to continue processing the data.
Right to restriction of processing: You have the right to request that Company restrict the processing of personal data about you that they hold. You can request this, for example, when you contest the accuracy of the data.
Right to object: You have the right to object to the processing of personal data about you based on grounds related to your specific situation. This right is not absolute, and Company may continue to use the data if they can demonstrate compelling legitimate grounds.
Right to data portability: This right is only available when the legal basis for processing under the GDPR is consent or for the purposes of a contract between you and Company. For this right to apply, the data must be in electronic form. You have the right to receive the data in a commonly used electronic format.
Rights in relation to automated individual decision-making, including profiling: You have the right to object to being subject to a decision based solely on automated processing, including profiling. Should Company engage in any automated decision-making, they will document it in this Privacy Policy and ensure that you have an opportunity to request that the decision involves personal consideration.
Right to complain to the Information Commissioner: You have the right to file a complaint with the Information Commissioner if you are dissatisfied with any aspect of how Company processes your personal data or believe that they are not fulfilling their responsibilities as a data controller.

Please note that the mentioned rights are not absolute and may be limited to fulfill regulatory requirements and Company’s legal interests. Keep in mind that Company may request specific details necessary to verify your identity when you seek to exercise a legal right concerning your personal data.

Disclosure of Data

Company may share Your personal data with third-party service providers, agents, subcontractors, affiliated organizations (including our group companies and affiliates) to facilitate the completion of tasks and the provision of services on Your behalf.

Your personal data may also be shared by Company with:

Companies we plan to merge with or that may acquire us (if such a merger occurs, we will notify You and require the newly formed entity to adhere to this Privacy Policy regarding Your personal data).
Law enforcement, government authorities, or other third parties in cases where we are legally obligated to do so through a subpoena, court order, or a similar legal procedure, or when we have a sincere belief that disclosing personal data is necessary to prevent physical harm or financial loss, report suspected illegal activities, or investigate policy violations.
Fraud or crime prevention agencies to combat various criminal activities, including fraud, money laundering, and terrorist financing.
Vendors and agents engaged by Company to provide You with our services.

Data Retention

Company retains your personal data for as long as it is needed for the specified purpose or as mandated by relevant laws, which may go beyond the conclusion of our association with you. Company may keep specific data to prevent fraud or future misuse, or for legitimate business reasons such as analyzing aggregated, non-personally identifiable data, account recovery, or when compelled by law.

Changes to Policy

Company reserves the right to modify or amend this Privacy Policy at its sole discretion. The most recent update date will always be prominently displayed at the top of this page. Whenever changes are made to the Privacy Policy, we will notify you in a manner consistent with the nature of those changes. If, as required by applicable data protection regulations, significant changes necessitate your approval, Company will seek your consent. If you do not agree with a revised version of the Privacy Policy, you are required to discontinue your use of the Website and services.