Privacy Policy.

Pinetree Capital respects the privacy of every visitor to our website and is committed to protecting the personal data we collect or process about you.

01Introduction

Pinetree Capital ("Pinetree Capital", "we", "us", or "our") is a proprietary investment firm based in the United Arab Emirates. We respect the privacy of every visitor to our website at https://www.pinetreecapital.ae (the "Website") and are committed to protecting personal data we collect or process about you.

This Privacy Policy explains what personal data we collect when you interact with the Website, how we use it, the legal bases on which we rely, with whom we share it, how long we retain it, and the rights available to you. It applies to all users of the Website regardless of location.

Pinetree Capital is a proprietary investment firm that deploys its own capital. We do not solicit, accept or manage funds from members of the public, and we do not hold ourselves out through this Website as a regulated financial services provider in any jurisdiction. The Website is purely informational and is limited to general information about Pinetree Capital, a contact facility, and an optional subscription to market commentary.

02Who we are (data controller)

For the purposes of the United Arab Emirates Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("UAE PDPL") and, where applicable, the EU General Data Protection Regulation 2016/679 ("GDPR") and the UK GDPR, the data controller for personal data collected through the Website is:

If you have questions about this Privacy Policy or wish to exercise any of your rights, please contact us at the email address above.

03Scope of this policy

This Privacy Policy applies to personal data we collect:

• when you visit, browse or interact with the Website;
• when you complete a contact form, subscribe to our newsletter or market commentary, or otherwise communicate with us by email;
• when you engage with any content we publish on third-party platforms (such as LinkedIn or X) and follow links to the Website; and
• through cookies, analytics and similar tracking technologies as described below.

It does not apply to third-party websites linked from our Website, which are governed by their own privacy policies.

04Personal data we collect

We collect only the personal data that is necessary for the purposes described in this Policy. Depending on how you interact with us, the categories of personal data we may process include:

4.1 Information you provide to us

• Identity and contact data — your name, email address, telephone number, employer or organisation, job title, country of residence, and any other information you choose to include in correspondence with us.
• Communication content — the content of messages you send us through the contact form or by email, including any attachments and the subject matter of your enquiry.
• Subscription data — if you subscribe to receive market commentary, research notes or other communications from us, your subscription preferences and engagement history.

4.2 Information we collect automatically

• Technical data — your Internet Protocol (IP) address, browser type and version, operating system, device identifiers, time-zone setting, and language preferences.
• Usage data — information about how you access and use the Website, including pages viewed, time spent, referring URL, click-through patterns, and the date and time of your visit.
• Cookie and similar tracking data — information collected via cookies, web beacons, pixels and similar technologies, as further described in Section 9 below.

4.3 Information from third-party sources

• Analytics providers — we may receive aggregated information about Website performance and visitor behaviour from analytics services.
• Social media platforms — if you interact with our profiles or posts on platforms such as LinkedIn or X and follow a link to the Website, we may receive limited information from those platforms in accordance with your privacy settings on them.

We do not knowingly collect or process special categories of personal data (such as data revealing racial or ethnic origin, religious beliefs, health data, or biometric data) through the Website. Please do not submit such information to us.

05Children's privacy

The Website is not directed at children under the age of 18 and we do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child without verified parental consent, we will take steps to delete it promptly.

06How we use your personal data

We process personal data only for specified, explicit and legitimate purposes, including the following:

• To respond to enquiries you submit through the Website or by email, and to manage our correspondence with you.
• To deliver market commentary, research notes, newsletters or other communications you have requested or are entitled to receive.
• To operate, maintain, secure and improve the Website, including diagnosing technical problems and analysing usage patterns.
• To protect the security and integrity of the Website, prevent fraud, unauthorised access, and other unlawful activity.
• To comply with applicable laws, regulations and lawful requests from competent authorities, including obligations under UAE financial-services and anti-money-laundering legislation as relevant.
• To establish, exercise or defend legal claims and to protect our rights, property and interests.
• Where we have your consent, for any other purpose disclosed at the time of collection.

We will not use your personal data for purposes that are incompatible with those listed above without first informing you and, where required, obtaining your consent.

07Legal bases for processing

Where the GDPR or UK GDPR applies to our processing of your personal data, we rely on the following legal bases:

• Consent — where you have given clear consent to us processing your personal data for a specific purpose (for example, subscribing to our newsletter). You may withdraw consent at any time.
• Contract — where processing is necessary to take steps at your request prior to entering a contract or to perform a contract with you.
• Legal obligation — where processing is necessary for us to comply with a legal or regulatory obligation.
• Legitimate interests — where processing is necessary for our legitimate interests (such as operating and securing the Website, responding to business enquiries, and developing our business), provided those interests are not overridden by your rights and freedoms.

Where the UAE PDPL applies, we process personal data on the lawful bases set out in Article 4 of that law, including your consent, the necessity of processing for the performance of a contract, compliance with a legal obligation, or our legitimate interests, in each case as permitted by law.

08Disclosure and sharing of personal data

We treat personal data as confidential and only disclose it in the limited circumstances set out below.

• Service providers and processors — we may share personal data with carefully selected third parties who provide services on our behalf, such as website hosting, email and contact-form delivery, analytics, cybersecurity, and IT support. These providers are contractually obliged to process personal data only on our instructions and to maintain appropriate security measures.
• Professional advisers — our legal counsel, auditors, accountants, tax advisers and insurers, where strictly necessary.
• Regulators and authorities — where we are required to do so by applicable law, regulation, court order, or a lawful request from a competent governmental, regulatory or law-enforcement authority.
• Corporate transactions — in the event of a reorganisation, merger, sale, joint venture, assignment, or transfer of all or part of our business or assets, in which case personal data may be transferred subject to appropriate confidentiality protections.
• With your consent — to any other party where you have specifically consented to the disclosure.

We do not sell, rent or trade personal data to third parties for their own marketing purposes.

09Cookies and similar technologies

The Website uses cookies and similar technologies to function correctly, to remember your preferences, and to help us understand how visitors interact with the Website. The categories we use are:

• Strictly necessary cookies — required for the operation of the Website (for example, security and load balancing). You cannot opt out of these.
• Performance and analytics cookies — collect aggregated information about how visitors use the Website so we can improve it. We may use providers such as Google Analytics for this purpose.
• Functionality cookies — remember choices you make (such as language) to provide a more personalised experience.

You can control cookies through your browser settings and most browsers allow you to refuse or delete cookies. Disabling certain cookies may affect the functionality of the Website. Where required by law, we will request your consent before placing non-essential cookies on your device.

10International data transfers

Pinetree Capital is established in the United Arab Emirates. Personal data we collect may be processed in, or transferred to, jurisdictions outside the country in which you reside, including the UAE and other countries where our service providers operate.

Where personal data is transferred from the European Economic Area, the United Kingdom or another jurisdiction with cross-border transfer restrictions to a country that has not been recognised as providing an adequate level of data protection, we will implement appropriate safeguards, such as standard contractual clauses or other lawful transfer mechanisms, to protect your personal data.

Transfers from the UAE will be carried out in accordance with the UAE PDPL and any implementing regulations issued by the UAE Data Office.

11Data security

We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures include, where appropriate, access controls, encryption in transit, secure hosting environments, and confidentiality obligations on personnel and service providers.

However, no method of transmission over the Internet or electronic storage is completely secure. While we endeavour to protect your personal data, we cannot guarantee absolute security and you transmit information to us at your own risk.

12Data retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements, and to establish, exercise or defend legal claims. In particular:

• Enquiry and correspondence data is generally retained for up to 24 months following our last substantive contact with you, unless a longer period is required by law or to manage an ongoing matter.
• Newsletter and subscription data is retained until you unsubscribe and for a short period thereafter to evidence your unsubscribe request.
• Website analytics data is retained for the period configured with the analytics provider, typically not exceeding 26 months.

When personal data is no longer required, we will securely delete or anonymise it.

13Your rights

Subject to the limitations set out in applicable data-protection law, you have the following rights in relation to personal data we hold about you:

• Right of access — to obtain confirmation of whether we process your personal data and a copy of that data.
• Right to rectification — to have inaccurate or incomplete personal data corrected.
• Right to erasure — to request deletion of your personal data in certain circumstances.
• Right to restriction of processing — to ask us to restrict the processing of your personal data in certain circumstances.
• Right to object — to object to processing based on our legitimate interests, and to object at any time to direct marketing.
• Right to data portability — to receive your personal data in a structured, commonly used and machine-readable format, where applicable.
• Right to withdraw consent — where we rely on your consent, to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to lodge a complaint — with the UAE Data Office or, if applicable to you, your local supervisory authority in the EEA or the United Kingdom.

To exercise any of these rights, please contact us at contact@pinetreecapital.ae. We may need to verify your identity before responding and will reply within the timeframes required by applicable law.

14Marketing communications

Where you have subscribed to receive market commentary, newsletters or other communications from us, you may opt out at any time by following the unsubscribe link contained in each communication or by emailing us at contact@pinetreecapital.ae. We will continue to send you service-related messages where necessary (for example, to respond to a specific enquiry).

15Third-party websites and platforms

The Website may contain links to third-party websites, plug-ins and applications, including social media platforms such as LinkedIn and X. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. We encourage you to read the privacy policy of every website you visit.

16Changes 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. The updated version will be posted on this page with a revised "Last Updated" date. Where the changes are material, we will provide additional notice as required by law. Your continued use of the Website after any changes take effect constitutes your acknowledgement of the revised Policy.

17Governing law

This Privacy Policy is governed by and construed in accordance with the laws of the United Arab Emirates, without regard to its conflict-of-laws principles. Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the competent courts of the United Arab Emirates, without prejudice to any mandatory rights you may have under the data-protection laws of your country of residence.

18Contact us

If you have any questions, comments or concerns about this Privacy Policy or our processing of your personal data, please contact us at: