Privacy Policy

1. Introduction

PEQAL ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, share, and protect personal data about visitors to our website and individuals who register their interest in the future PEQAL platform.

This Privacy Policy is prepared in accordance with Law No. 13 of 2016 on the Protection of Personal Data Privacy (the "PDPPL") issued by the State of Qatar, and related guidance issued by the Qatari authorities from time to time.

2. Who we are (data controller)

The data controller responsible for your personal data under the PDPPL is:

• Firm name: PEQAL LLC
• Trading name: PEQAL
• Registered address: QFC Tower 1, 9th Floor, Tech, Doha, State of Qatar
• Phone: +974 3334 4445
• Contact email: info@peqal.com

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us using the details in Section 14.

3. Legal basis under Qatari law

Under Article 2 of the PDPPL, personal data may only be processed within a framework of transparency, honesty, and respect for human dignity, and in accordance with the provisions of the law. We process personal data on the following legal bases:

• Consent — where you have given us clear consent to process your personal data for a specific purpose (for example, subscribing to updates or registering your interest).
• Contract — where processing is necessary for a contract we have with you or to take steps at your request before entering into a contract.
• Legal obligation — where we are required by Qatari law to process your personal data, including obligations under anti-money laundering, counter-terrorist financing, tax, commercial, and regulatory laws.
• Legitimate interest — where processing is necessary for our legitimate business interests, provided these are not overridden by your rights and freedoms.

4. Personal data we collect

We only collect personal data that is relevant, necessary, and proportionate to the purposes described in this policy. The types of personal data we may collect include:

4.1 Information you provide directly

• Identification data: full name, title
• Contact data: email address, phone number, country of residence
• Business data: company name, role/position, business sector, approximate invoice volume or investor profile (only if you register as an SME or investor on our waitlist)
• Any message or information you choose to include in a form or communication

4.2 Information collected automatically

• Technical data: IP address, browser type and version, device type, operating system
• Usage data: pages visited, time spent on pages, referring URL, general interaction patterns
• Cookie and similar tracking data (see Section 11)

4.3 What we do not collect on this website

During the pre-licensing phase, our website does not collect financial account details, government identification numbers, passport numbers, or sensitive personal data (such as health, religious, or political data) as defined in Article 16 of the PDPPL. If we ever need to collect such data in connection with the future regulated platform, we will do so under an expanded privacy notice and with the specific safeguards required by Qatari law.

5. How we use your personal data

We use personal data only for specific, legitimate, and transparent purposes, including:

• Responding to your enquiries and communications
• Managing our waitlist and contacting registered individuals when the PEQAL platform launches
• Sending you newsletters, product updates, and relevant information — only where you have subscribed or consented
• Improving the content, security, and user experience of our website
• Complying with applicable laws, including record-keeping and AML/CFT obligations under Law No. 20 of 2019 concerning the combating of money laundering and terrorism financing
• Protecting our legal rights and preventing fraud or misuse of the website

We will not use your personal data for any purpose that is incompatible with the purposes described above without first informing you and, where required, obtaining your consent.

6. When we share your personal data

We do not sell your personal data. We may share your personal data only in the following limited circumstances:

• Service providers: trusted third parties who process personal data on our behalf (such as cloud hosting, email delivery, analytics, and legal or compliance advisors), under written agreements that require them to protect your data and only use it for the purposes we specify.
• Regulators and authorities: where required by Qatari law, including the Qatar Central Bank (QCB), the Financial Information Unit, or other competent authorities, in response to lawful requests or regulatory obligations.
• Legal proceedings: where disclosure is necessary to comply with a court order, protect our legal rights, prevent fraud, or protect the safety of any person.
• Corporate transactions: in connection with a potential merger, acquisition, reorganisation, or sale of assets, subject to appropriate confidentiality and data protection safeguards.

7. International data transfers

Some of our service providers may store or process personal data outside the State of Qatar. Where this happens, we take reasonable steps to ensure that your personal data receives an adequate level of protection, consistent with the requirements of the PDPPL. This may include contractual safeguards with the relevant service provider and, where applicable, assessments of the recipient country's data protection framework.

8. How long we keep your data

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to:

• Respond to your enquiry or request
• Maintain our waitlist until PEQAL launches (or until you unsubscribe)
• Meet our legal, regulatory, accounting, or reporting obligations under Qatari law
• Defend or establish legal claims where necessary

Where personal data is no longer needed, we will delete it or anonymise it in accordance with our internal retention schedule.

9. Security of your personal data

We apply appropriate technical, organisational, and administrative measures to protect your personal data against unauthorised access, loss, alteration, disclosure, or destruction. These include:

• Encryption of data in transit (HTTPS)
• Access controls and authentication for internal systems
• Regular review of data handling practices and staff training
• Incident response procedures for any suspected data breach

In the event of a personal data breach that is likely to cause serious harm, we will notify the competent authorities and affected individuals in accordance with Article 14 of the PDPPL.

10. Your rights under Qatari law

Under the PDPPL, you have the following rights in relation to your personal data, which you may exercise by contacting us at info@peqal.com:

• Right of access: to ask for a copy of the personal data we hold about you.
• Right to rectification: to ask us to correct personal data that is inaccurate or incomplete.
• Right to erasure: to ask us to delete your personal data where there is no continued legal basis for us to retain it.
• Right to object: to object to the processing of your personal data in certain circumstances, including for direct marketing purposes.
• Right to withdraw consent: where we rely on your consent, you may withdraw it at any time; this will not affect the lawfulness of any processing carried out before your withdrawal.
• Right to lodge a complaint: if you believe we have not handled your personal data properly, you may lodge a complaint with the competent data protection authority in Qatar (the Compliance and Data Protection Department under the Ministry of Communications and Information Technology, or its successor body).

We will respond to legitimate requests within a reasonable period, and in any event within the timeframe required by Qatari law. We may need to verify your identity before acting on a request.

11. Cookies and similar technologies

Our website uses a limited number of cookies and similar technologies to operate properly and to understand how the site is used. We distinguish between:

• Strictly necessary cookies: required for the website to function securely. These do not require consent.
• Analytics cookies: help us understand aggregate usage so we can improve the website. These are only set where you consent.

You can control cookies through your browser settings. Disabling non-essential cookies will not affect your ability to use the website.

12. Children's privacy

This website is not directed at children, and we do not knowingly collect personal data from any person under the age of 18. If you believe a child has provided us with personal data, please contact us and we will take steps to delete it.

13. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other reasons. The "Last updated" date at the top of this policy indicates when it was last revised. Material changes will be communicated through the website or, where we hold your contact details, by email.

14. How to contact us

If you have any questions, requests, or complaints about this Privacy Policy or how we handle your personal data, please contact us:

• Email: info@peqal.com
• Postal address: PEQAL LLC, QFC Tower 1, 9th Floor, Tech, Doha, State of Qatar
• Phone: +974 3334 4445

This Privacy Policy is governed by the laws of the State of Qatar. Any disputes arising from or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the competent Qatari courts.