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Privacy Policy

Last updated: [DATE — Lewis to confirm]

1. Data Controller

The data controller for personal data collected through this website is [ENTITY NAME — Lewis to confirm: EP Services FZco or other entity].
Registered Office: [ADDRESS]
Registration Number: [NUMBER]
Contact: info@emergence.partners

2. Personal Data We Collect

We may collect the following personal data through this website:

• Email address (via the newsletter subscription form)
• IP address and browser information (via server logs)
• Cookie data (see our Cookie Policy)

3. Purpose and Legal Basis for Processing

We process personal data for the following purposes:

• Newsletter delivery: To send investment insights and updates. Legal basis: your explicit consent (GDPR Article 6(1)(a)).
• Website operation: To maintain the security and functionality of the website. Legal basis: legitimate interest (GDPR Article 6(1)(f)).
• Analytics: To understand website usage and improve our content, subject to your cookie consent. Legal basis: your consent (GDPR Article 6(1)(a)).

4. Data Retention

Newsletter subscriber data is retained until you withdraw your consent. Server logs are retained for [PERIOD — Lewis to confirm, e.g. 12 months]. Cookie data retention periods are set out in our Cookie Policy.

5. Your Rights

Under GDPR, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request erasure of your data
• Withdraw consent at any time (without affecting the lawfulness of prior processing)
• Object to processing based on legitimate interest
• Request data portability
• Lodge a complaint with a supervisory authority

To exercise any of these rights, contact us at info@emergence.partners.

6. Supervisory Authority

[Lewis to confirm: If the data controller is an Irish entity or individual, the relevant supervisory authority is the Data Protection Commission (DPC), 21 Fitzwilliam Square South, Dublin 2, Ireland, www.dataprotection.ie. If another jurisdiction, update accordingly.]

7. Data Sharing and Sub-Processors

We may share personal data with the following categories of service providers, all of whom are bound by data processing agreements (GDPR Article 28):

• Website hosting provider: [Lewis/Paul to confirm — e.g. GitHub Pages]
• Email service provider: [Lewis/Paul to confirm — e.g. Mailchimp, ConvertKit]
• Analytics provider: [Lewis/Paul to confirm — e.g. Google Analytics, or none]

We do not sell personal data to third parties.

8. International Transfers

Your data may be transferred to and processed in countries outside the European Economic Area. Where such transfers occur, we ensure appropriate safeguards are in place in accordance with GDPR Chapter V.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Any material changes will be posted on this page with an updated effective date.