Data Protection

Privacy Policy

Last updated: April 2026

    Phoenici is a brand operated by Findisy FZCO (IFZA, Dubai, UAE). Findisy FZCO is committed to protecting your personal data in accordance with applicable UAE data protection legislation and, where applicable, the EU General Data Protection Regulation (GDPR). This policy explains how we collect, use and protect your information.
  

1. Data Controller

The data controller responsible for your personal data is:

Findisy FZCO — sole operator of the Phoenici brand
IFZA Business Park, Dubai, United Arab Emirates
Contact: info@phoenici.com

Note: Phoenici is a brand operated by Findisy FZCO. Phoenici S.A. (Luxembourg) is a separate legal entity and is not a data controller for any data collected through this website or the Kyrion platform.

2. Data We Collect

We may collect the following categories of personal data:

Contact data — name, email address, telephone number
Professional data — company name, job title, jurisdiction
Communication data — messages sent through our contact form
Technical data — IP address, browser type, pages visited (via server logs)
Compliance data — for clients using Kyrion or our advisory services, identity and KYC documents as required by applicable AML/CFT regulations

3. Purpose and Legal Basis

We process your personal data for the following purposes:

Responding to enquiries — legal basis: legitimate interest / consent
Providing compliance services — legal basis: performance of a contract
AML/KYC regulatory obligations — legal basis: legal obligation under applicable AML/CFT laws (UAE Cabinet Decision No. 10 of 2019, EU AML Directives)
Improving our website — legal basis: legitimate interest
Marketing communications — legal basis: consent (you may withdraw at any time)

4. Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected, or as required by law:

Contact enquiries: up to 3 years
Client compliance records: 5 to 10 years as required by AML/CFT regulations
Technical logs: up to 12 months

5. Data Sharing

We do not sell your personal data. We may share data with:

Service providers acting as data processors on our behalf (hosting, email, platform infrastructure)
Competent authorities where required by applicable AML/CFT law (e.g. UAE FIU, Luxembourg FIU)
Professional advisors bound by confidentiality obligations

Any international transfer of personal data outside the EU/EEA is conducted under appropriate safeguards (Standard Contractual Clauses or adequacy decisions).

6. Your Rights

Under GDPR and applicable UAE law, you have the following rights regarding your personal data:

Right of access — to obtain a copy of your data
Right of rectification — to correct inaccurate data
Right of erasure — to request deletion, subject to legal retention obligations
Right to restrict processing
Right to data portability
Right to object to processing based on legitimate interest
Right to withdraw consent at any time, without affecting prior processing

To exercise your rights, contact us at info@phoenici.com. We will respond within 30 days.

7. Cookies

This website uses only essential technical cookies necessary for its operation. We do not use tracking, advertising or analytics cookies. No cookie consent banner is required for essential cookies under GDPR.

If this policy is updated to include non-essential cookies, a consent mechanism will be implemented accordingly.

8. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction or alteration, in line with industry standards for compliance and financial services.

9. Kyrion Platform

If you use the Kyrion compliance platform, a separate data processing agreement governs the processing of personal data submitted through the platform. Please refer to the Kyrion terms and conditions available at kyrion.ae.

10. Complaints

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the relevant supervisory authority:

Luxembourg: Commission Nationale pour la Protection des Données (CNPD) — cnpd.public.lu
UAE: UAE Data Office — uaedataoffice.ae

11. Updates to this Policy

We may update this Privacy Policy from time to time. The date of the last revision is indicated at the top of this page. We encourage you to review this policy periodically.

12. Contact

For any data protection enquiry:
info@phoenici.com
Findisy FZCO — operator of the Phoenici brand
IFZA Business Park, Dubai, United Arab Emirates