Privacy Policy

Data Protection Privacy Notice

The scope and purpose of this Privacy Notice

This Privacy Notice explains how Lakemore (“Lakemore”, “we”, “us”, “our”), collects, uses, shares and otherwise processes your Personal Data in connection with your relationship with us as a Lakemore client, acting for a client or being generally interested in our services and our publications in accordance with the Data Protection Law DIFC Law No. 5 of 2020 (the “Law”) and the Data Protection Regulations (the “Regulations”).

Should you have any questions about this Privacy Notice you can contact us at

We may provide supplemental privacy notices on specific occasions, when we are collecting or  processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. Those supplemental notices should be read together with this Privacy Notice.

Personal Data

The term “Personal Data” as used in this Privacy Notice means any information relating to you such as your name, contact details, bank account details etc. Personal Data does not include data from which you can no longer be identified such as anonymised aggregate data.

What information do we collect about you, how do we collect it and what do we use it for?

The kinds of Personal Data we may collect include your contact details (such as your address, email address and telephone number) and information such as your job title which we will request from you. In addition, we collect the Personal Data you choose to provide to us, e.g. if you contact us by letter, telephone, email or any other means of electronic or personal communication. We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data only:

a) if you have consented to us doing so;
b) if we need it to perform the contract we have entered into with you;
c) if we need it to comply with a legal obligation; or
d) if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests will be the providing of services by us, administrative or operational processes within Lakemore and direct marketing.

We will use your Personal Data to deliver services to you and/or the institution you work or act for. We may also use your Personal Data to inform you about our services, new developments in the jurisdictions we operate and our marketing events.

Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

Purpose of processing  

We will always process your Personal Data for a specific and only process Personal Data which is relevant to achieve that purpose. We process Personal Data for the following purposes:  

  • Client Onboarding;
  • Client Relation management;
  • Marketing;
  • To undertake checks for the purposes of security, detecting and preventing fraud and money laundering, and to verify your identity before we provide services to you. These checks may reveal political opinions or information about criminal convictions or offences;
  • To comply with regulatory and legal obligations to which we are subject and cooperate with regulators and law enforcement bodies;
  • To prevent and detect fraud, money laundering and other crimes (such as identity theft). 

How data is processed

Personal data is processed both manually and electronically in accordance with the above-mentioned purposes and, in any case, to guarantee data security and data confidentiality in compliance with current regulations. Our Employees and Third-Party processors can access your data. Our Employees and Third-Party processors are appropriately designated and trained to process data only according to the instructions we provide them. All the data will be processed for the duration of this contract and subsequently for the fulfillment of legal obligations.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access Personal Data (or to exercise any of your other rights). This is another appropriate  security measure to ensure that Personal Data is not disclosed to any person who has no right to  receive it.

Accuracy of information

It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes during your relationship with us.

What if you do not provide the personal data we request?

It is in your sole discretion to provide Personal Data to us. In the context of our relationship, you must provide all Personal Data that is required for accepting and carrying out a business relationship and fulfilling the accompanying contractual obligations or that we are legally obliged to collect.

Anti-money laundering regulations require us to identify you on the basis of your identification documents before establishing a business relationship and to collect and put on record information which may include name, place and date of birth, nationality, address and identification details for this purpose.

In order for us to be able to comply with these statutory obligations, you must provide us with the necessary information and documents in accordance with applicable anti-money laundering regulations, and to immediately disclose any changes over the course of our relationship.

Where the Personal Data we collect from you is needed to comply with our legal or regulatory obligations or enter into an agreement with you, if we cannot collect this Personal Data there is a possibility, we may not be able to accept an engagement from you, to provide all or some of our  services, to enter into a contract with you or to send you the requested (marketing) information, we may be unable to onboard you as a client (in which case we will inform you accordingly).

Change of purpose, anonymization

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

With whom will we share your information?

When using your Personal Data for the purposes and on the legal basis described above we may share your Personal Data with our other Lakemore offices around the world as well as other services providers we work with. We may also have to share your Personal Data with regulators, public institutions, courts or other third parties.

For the purposes described above we may have to transfer your Personal Data from the Dubai International Financial Centre (“DIFC”) to a Lakemore office or a third party outside of the DIFC and in a jurisdiction not being subject to an adequacy decision of the Commissioner, the DIFC supervisory authority for data protection issues. We will always ensure that there is a legal basis and a relevant safeguard method for such data transfer so that your Personal Data is treated in a manner that is consistent with, and respects the Law and Regulations and other applicable laws and regulations on data protection. If you require further information about this you can request it from

Your rights in relation to your information

You have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. 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 erasure of your Personal Data;
  • request the restriction of processing of your Personal Data;
  • object to the processing of your Personal Data.

You also have the right to receive your Personal Data in a structured, commonly used and machine readable format and to have us transmit those Personal Data to another controller, if you have provided these Personal Data to us, if the processing is based on consent or on a contract and the  processing is carried out by us by automated means, subject, however, to legal restrictions which may apply.

If you want to exercise one of these rights, please send your request using that attached form to

Data Subject Request Form

You also have the right to make a complaint at any time to the Commissioner. 

Right to withdraw consent

In case you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. To withdraw your consent, please contact 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 there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. In case we processed your Personal Data for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Data for such marketing purposes.

How long will we retain your information?

We will only retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use 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 anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

Upon expiry of the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations.


You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Privacy Notice. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

No automated decision making

We do not apply automated decision making techniques.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our website.

Further information

If you have any concerns or require any further information, please do not hesitate to contact