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PRIVACY POLICY

BINGHATTI CAPITAL LIMITED

Effective Date: 9 June 2026

1. Important information and who we are

2. The types of personal data we collect about you

3. How is your personal data collected?

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Contact details

11. Complaints

12. Changes to the privacy policy and your duty to inform us of changes

13. Third-party links

Introduction

This privacy policy sets out how Binghatti Capital Limited uses and protects your personal data.

1. Important information and who we are

This privacy policy gives you information about how Binghatti Capital Limited collects and uses your personal data through your use of the website accessible at www.binghatticapital.com (the "Website"), including the investor portal accessible to registered users of the Website (the "Investor Portal"), and any data you may provide when you register with us, apply for our products or services, or otherwise interact with us.

This Website is directed to, and intended for use by, Professional Clients as defined under the Rulebook of the Dubai Financial Services Authority ("DFSA"). General informational content on the Website may be accessed by other persons, but no person who is not a Professional Client should rely on, or act upon, any content on this Website that relates to financial services, investment products, fund performance, or any other regulated activity. Binghatti Capital does not deal with retail clients.

This Website is not intended for children and we do not knowingly collect data relating to children.

Controller

Binghatti Capital Limited is the controller and responsible for your personal data (referred to as "Binghatti Capital", "we", "us" or "our" in this privacy policy).

Binghatti Capital Limited is a company incorporated in the Dubai International Financial Centre ("DIFC") and is authorised and regulated by the DFSA under Reference Number F010521. Binghatti Capital is permitted to carry on the following regulated financial services in accordance with its DFSA licence:

(a)Managing a Collective Investment Fund;
(b)Advising on Financial Products;
(c)Arranging Deals in Investments; and
(d)Managing Assets,

with endorsement to Hold or Control Client Assets and to Operate an Islamic Window.

We have appointed a Data Protection Officer ("DPO") who is responsible for overseeing questions in relation to this privacy policy in accordance with Articles 16, 17 and 18 of DIFC Data Protection Law No. 5 of 2020 (as amended) (the "Data Protection Law"). If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact the DPO using the information set out in the contact details section (paragraph 10).

2. The types of personal data we collect about you

Personal data means any information referring to an identified or identifiable natural person, as defined in the Data Protection Law.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth, gender, nationality, place of birth, passport details and photographs.

• Contact Data includes residential and correspondence address, email address and telephone numbers.

• Financial Data includes bank account details and payment card details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, including capital calls, distributions, subscription amounts and redemption proceeds.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device identifiers and other technology on the devices you use to access the Website.

• Profile Data includes your username and login credentials which we protect using appropriate technical and organisational security measures, investments or subscriptions made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you interact with and use the Website (including the Investor Portal), our products and services.

• Marketing and Communications Data includes your preferences in receiving communications from us and your communication preferences.

• KYC and Regulatory Data includes information collected as part of our know-your-customer, anti-money laundering and counter-terrorist financing checks, including source-of-funds and source-of-wealth documentation, politically exposed person screening results, and sanctions screening results.

Certain categories of personal data are classified as "Special Categories of Personal Data" under the Data Protection Law and attract additional protections. In the course of our KYC, AML and CTF onboarding procedures, we may process the following Special Categories of Personal Data:

• Biometric data, where our identity verification service providers use such data for the purpose of uniquely identifying you (for example, through facial recognition or fingerprint matching). We only process biometric data in this way where our onboarding procedures require it.

• Certain documents provided during onboarding (such as identity documents or source-of-funds documentation) may incidentally contain information that reveals or concerns racial or ethnic origin or religious beliefs. We do not request such information unless required by applicable law.

We process Special Categories of Personal Data only where one or more of the following conditions under Article 11 of the Data Protection Law applies:

(a)the processing is necessary to comply with applicable anti-money laundering or counter-terrorist financing obligations (Article 11(h));
(b)the processing is necessary for compliance with a specific requirement of applicable law to which we are subject, including regulatory obligations imposed by the DFSA Rulebook (Article 11(g));
(c)you have given explicit consent to the processing of those Special Categories of Personal Data for one or more specified purposes (Article 11(a)); or
(d)the processing relates to personal data that has been made public by you (Article 11(e)).

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) identify you. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific Website feature in order to analyse general trends in how users are interacting with the Website to help improve the Website and our service offering.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms, submitting applications, entering into subscription agreements or other fund documentation, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;

• register for access to the Investor Portal;

• subscribe to or invest in a fund managed by Binghatti Capital;

• submit know-your-customer or onboarding documentation;

• request information to be sent to you;

• enter into any agreement with us;

• give us feedback or contact us; or

• submit a complaint.

Automated technologies or interactions. As you interact with the Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy [COOKIE POLICY URL] for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

• Technical Data from analytics providers.

• Identity, Contact and KYC and Regulatory Data from identity verification, credit reference and screening providers.

• Identity and Contact Data from publicly available sources, including corporate registries and regulatory databases.

• Financial and Transaction Data from fund administrators, custodians, transfer agents and payment service providers.

• Identity, Contact and Financial Data from your professional advisers (such as lawyers and accountants) where they act on your behalf in connection with your investment.

4. How we use your personal data

Legal basis

The Data Protection Law requires us to have a lawful basis for processing your personal data. In accordance with Article 10 of the Data Protection Law, we rely on one or more of the following lawful bases:

• Performance of a contract with you: Where processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into such contract (Article 10(b)).

• Legitimate interests: Where processing is necessary for the purpose of legitimate interests pursued by us or a third party to whom the personal data has been made available, subject to Article 13, except where such interests are overridden by your interests or rights (Article 10(f)). We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.

• Legal or regulatory obligation: Where processing is necessary for compliance with applicable law to which we are subject, including obligations under the DFSA Rulebook, DIFC anti-money laundering legislation and the Data Protection Law itself (Article 10(c)).

• Consent: Where you have given consent, which complies with Article 12, to the processing of your personal data for specific purposes (Article 10(a)). You have the right to withdraw consent at any time in accordance with Article 32 (see paragraph 9).

• Vital interests: In limited circumstances, where processing is necessary in order to protect your vital interests or those of another natural person (Article 10(d)).

Purposes for which we will use your personal data

We have set out below a description of the ways we use the various categories of your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose / Use	Type of data	Lawful basis
To register you as a client and conduct onboarding (including KYC, AML and CTF checks)	(a) Identity (b) Contact (c) Financial (d) KYC and Regulatory	(a) Performance of a contract with you (Article 10(b)) (b) Compliance with applicable law (Article 10(c)), including the DFSA Rulebook and DIFC AML legislation
To process and manage your investment, including managing subscriptions, redemptions, capital calls, distributions, payments, fees and charges	(a) Identity (b) Contact (c) Financial (d) Transaction	(a) Performance of a contract with you (Article 10(b)) (b) Legitimate interests (Article 10(f)): to recover debts due to us
To provide you with access to the Investor Portal and display information relating to your investments	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical (f) Profile	(a) Performance of a contract with you (Article 10(b)) (b) Legitimate interests (Article 10(f)): to provide investors with convenient access to investment information
To manage our relationship with you, including notifying you about changes to our terms, privacy policy or fund documentation, and dealing with your requests, complaints and queries	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (Article 10(b)) (b) Compliance with applicable law (Article 10(c)) (c) Legitimate interests (Article 10(f)): to keep our records updated and manage our relationship with you
To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Legitimate interests (Article 10(f)): for running our business, provision of administration and IT services, network security, to prevent fraud (b) Compliance with applicable law (Article 10(c))
To comply with legal and regulatory obligations, including reporting to the DFSA, responding to regulatory enquiries, and maintaining records	(a) Identity (b) Contact (c) Financial (d) Transaction (e) KYC and Regulatory	Compliance with applicable law (Article 10(c))
To use data analytics to improve the Website, our products, services, client relationships and experiences	(a) Technical (b) Usage	Legitimate interests (Article 10(f)): to keep the Website updated and relevant, to develop our business and to inform our strategy
To detect, prevent and investigate fraud, money laundering, terrorist financing and other financial crime	(a) Identity (b) Contact (c) Financial (d) Transaction (e) KYC and Regulatory (f) Technical	(a) Compliance with applicable law (Article 10(c)) (b) Legitimate interests (Article 10(f)): to protect our business and clients from financial crime (see also Article 13(3))

Retention periods

We set out our data retention periods in paragraph 8 below.

Marketing communications

Binghatti Capital does not currently conduct direct marketing. Should this position change in the future, we will update this privacy policy accordingly and, where required, obtain your consent before sending you any direct marketing communications.

You will continue to receive service-related communications that are essential for administrative, regulatory or client-service purposes (for example, capital call notices, distribution notices, regulatory notifications and changes to our terms). These are not marketing communications.

We use a small number of cookies on our Website, including the Investor Portal. This section explains what cookies we use, why we use them, and how you can manage your preferences.

What are cookies?

Cookies are small text files placed on your device when you visit a website. They are retrieved on subsequent visits and allow the website to recognise your device and remember certain information about your session or preferences.

Cookies we use

The table below sets out the cookies currently in use on the Website. We will update this section whenever our use of cookies changes.

Cookie name: _ga, _ga_[ID]

Provider: Google LLC

Category: Analytics

Purpose: Measures and reports on how visitors interact with the Website in aggregate, enabling us to improve its content and performance.

Lawful basis: Legitimate interests (Article 10(f)) — to keep the Website relevant and to develop our business.

Retention: Up to 2 years.

Cookie name: _gcl_au

Provider: Google LLC (via Google Tag Manager)

Category: Analytics

Purpose: Supports conversion tracking and facilitates the loading of analytics tags across the Website.

Lawful basis: Legitimate interests (Article 10(f)).

Retention: 90 days.

Cookie name: Session cookie (e.g. session_token or equivalent)

Provider: Binghatti Capital Limited

Category: Strictly necessary

Purpose: Maintains your authenticated session when you log in to the Investor Portal. Without this cookie the portal cannot function.

Lawful basis: Performance of a contract with you (Article 10(b)). This cookie does not require your consent.

Retention: Session only — deleted automatically when you log out or close your browser.

Please note: although session cookies are deleted when you close your browser or log out, server-side access logs recording your Investor Portal activity are retained separately in accordance with our data retention policy at paragraph 8.

Third-party cookie providers

Where we use third-party services, those providers may process cookie-collected data in accordance with their own privacy policies. Google's privacy policy is available at https://policies.google.com/privacy.

Managing your cookie preferences

Most browsers accept cookies by default. You can control or delete cookies through your browser's 'Help' or 'Settings' menu. You may also visit www.aboutcookies.org for independent guidance on managing and deleting cookies across different browsers and devices. For mobile devices, please refer to your handset manual or network operator.

Please be aware that disabling certain cookies may limit your ability to access parts of the Website, including the Investor Portal.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table in paragraph 4 above:

(a)Internal third parties: Other entities within the Binghatti group of companies, where applicable, who may provide IT, system administration, compliance and reporting services and who are subject to appropriate data protection obligations. A controller that is part of a group may have a legitimate interest in transferring personal data within its group for internal administrative purposes (Article 13(2)).
(b)External third parties, including:

• Fund administrators, custodians, transfer agents, auditors and other service providers appointed in connection with the funds managed by Binghatti Capital.

• Professional advisers, including lawyers, accountants, bankers and insurers, who provide consultancy, legal, banking, insurance and accounting services.

• Identity verification, credit reference and screening providers for the purposes of KYC, AML and CTF compliance.

• IT service providers, cloud hosting providers and data analytics providers.

• The DFSA and other regulatory authorities, government entities and law enforcement agencies, where required by applicable law, regulation or legal process, subject to the data sharing requirements of Article 28.

• The Sharia Supervisory Board appointed in respect of any fund operated through Binghatti Capital's Islamic Window, to the extent necessary for Sharia governance and review.

(c)Corporate transactions: Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Where processing is carried out on our behalf by a processor, the processing is governed by a legally binding written agreement in accordance with Article 24 of the Data Protection Law.

6. International transfers

The DIFC is a separate legal jurisdiction within the United Arab Emirates. Under the Data Protection Law, a transfer of personal data from the DIFC to any jurisdiction outside the DIFC — including to the UAE mainland — constitutes a transfer to a "Third Country" as defined in Schedule 1 of the Data Protection Law.

Transfers to the UAE mainland. In the course of our business operations, we transfer personal data from the DIFC to recipients located in the UAE mainland. This is our primary cross-jurisdictional transfer. As the UAE mainland has not, at the date of this policy, been the subject of a formal adequacy determination by the Commissioner of Data Protection under Article 26(2) of the Data Protection Law, we ensure that such transfers are protected by appropriate safeguards in accordance with Article 27 of the Data Protection Law, including:

• standard data protection clauses adopted or approved by the Commissioner of Data Protection in accordance with Article 27(2)(c); and

• where applicable, reliance on the specific derogations set out in Article 27(3), including where the transfer is necessary for the performance of a contract between us and you (Article 27(3)(b)), for the establishment, exercise or defence of a legal claim (Article 27(3)(f)), or for compliance with applicable anti-money laundering or counter-terrorist financing obligations (Article 27(3)(k)).

Other transfers. Where we transfer your personal data outside the DIFC to any other Third Country, we ensure that a similar degree of protection is afforded to it by implementing one or more of the following safeguards:

• We will only transfer your personal data to a Third Country that has been determined by the Commissioner of Data Protection to provide an adequate level of protection for personal data under Article 26(2) or Article 26(3).

• We may use standard data protection clauses adopted or approved by the Commissioner of Data Protection under Article 27(2)(c).

• We may rely on binding corporate rules approved in accordance with Article 27(2)(b) and Article 27(7), where applicable.

• We may rely on any other appropriate safeguard or derogation permitted under Articles 26 or 27 of the Data Protection Law.

Where required, we assess the circumstances of a transfer and implement appropriate safeguards to ensure that enforceable data subject rights and effective legal remedies are available, in accordance with Articles 26 and 27 of the Data Protection Law.

To obtain further details of the safeguards we have in place in respect of international transfers of your personal data, please contact us using the details set out in paragraph 10.

7. Data security

We have put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, in accordance with Article 14(2) of the Data Protection Law. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality in accordance with Article 25 of the Data Protection Law.

When accessing Binghatti Capital's services, you may be required to go through a verification and authorisation process to confirm your identity through our know-your-customer procedures.

We have put in place procedures to deal with any suspected personal data breach and will notify the Commissioner of Data Protection and, where applicable, affected data subjects of a breach where we are legally required to do so in accordance with Articles 41 and 42 of the Data Protection Law.

8. Data retention

How long will we use your personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, in accordance with Article 9(1)(i) of the Data Protection Law. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we 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, regulatory, tax, accounting or other requirements.

Our standard retention periods are as follows:

Category of data	Retention period
Corporate, financial and transaction records (including Contact, Identity, Financial and Transaction Data)	A minimum of six (6) years from the end of the client relationship, in accordance with record-keeping obligations under the DFSA Rulebook
KYC, AML and CTF onboarding records (including KYC and Regulatory Data, and associated Identity and Contact Data)	A minimum of five (5) years from the date of termination of the business relationship, in accordance with DIFC anti-money laundering legislation
Technical and Usage Data	Retained for the duration of your use of the Website and for a period of two (2) years thereafter, unless a longer period is required for the purposes of any investigation or legal proceedings
Investor Portal access logs	A minimum of six (6) years from the date of the relevant access event

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information. Where we are required to cease processing and no lawful basis for retention applies, we will comply with Article 22 of the Data Protection Law.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under Part 6 of the Data Protection Law, you have a number of rights in relation to your personal data. You have the right to:

(a)Request access to your personal data. Upon request, you have the right to obtain from us, without charge and within one (1) month, confirmation as to whether or not personal data relating to you is being processed, information as to the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data are disclosed, and a copy of the personal data undergoing processing (Article 33(1)).
(b)Request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us (Article 33(1)(c)).
(c)Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where, for example, the processing is no longer necessary in relation to the purposes for which it was collected, you have withdrawn consent and there is no other lawful basis for processing, or the processing is unlawful. Note, however, that we may not always be able to comply with your request for erasure where we are required to retain the personal data in compliance with applicable law or for the establishment or defence of legal claims (Article 33(2) and Article 33(3)).
(d)Object to processing of your personal data where we are relying on legitimate interests (Article 10(f)) as the lawful basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to continue processing your information which override your right to object. Where an objection is justified, we shall cease processing and comply with Article 22 of the Data Protection Law (Article 34).
(e)Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios, for example if you want us to establish the data's accuracy, where our use of the data is unlawful but you do not want us to erase it, where you need us to hold the data for the establishment, exercise or defence of legal claims, or where you have objected to our use of your data pending verification of whether our legitimate grounds override yours (Article 35).
(f)Request the portability of your personal data. You have the right to receive personal data that you have provided to us in a structured, commonly used and machine-readable format where the processing is based on your consent or the performance of a contract and is carried out by automated means. Where technically feasible, you have the right to have the personal data transmitted directly to another controller (Article 37).
(g)Withdraw consent at any time where we are relying on consent (Article 10(a)) to process your personal data. Withdrawal of consent does not affect the lawfulness of any processing carried out before the date of withdrawal. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Upon withdrawal of consent, we will cease processing your personal data as soon as reasonably practicable and comply with Article 22 of the Data Protection Law (Article 32).
(h)Rights in relation to automated decision-making. We do not currently make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects on you. Should that position change, we will update this policy and implement the safeguards required by Article 38 of the Data Protection Law, including your right to object to such decisions and to require that they be reviewed manually.
(i)Non-discrimination. We will not discriminate against you for exercising any of your rights under Part 6 of the Data Protection Law (Article 39).

How to exercise your rights

In accordance with Article 40 of the Data Protection Law, we make available at least two methods by which you can contact us to exercise your rights. If you wish to exercise any of the rights set out above, please contact us using the details set out in paragraph 10.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, where requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking into account the administrative costs, or refuse to act on the request, in accordance with Article 33(8).

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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it (Article 33(12)). We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We endeavour to respond to all legitimate requests within one (1) month. If your request is particularly complex, we may extend the period for compliance by a further two (2) months, and we will notify you of the reasons for the delay within the initial one-month period (Article 33(7)).

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data, or you wish to exercise your privacy rights, please contact our Data Protection Officer in the following ways:

Email address: info@binghatticapital.com

Postal address: Binghatti Capital Limited, Unit L19-04A, ICD Brookfield Place, DIFC, PO Box 482010, Dubai, United Arab Emirates

In accordance with Article 16(8) of the Data Protection Law, the contact details of our DPO are published above so that they are readily accessible to third parties.

11. Complaints

You have the right to lodge a complaint with the Commissioner of Data Protection at the DIFC (the supervisory authority for data protection matters in the DIFC) in accordance with Article 60 of the Data Protection Law. You may also have rights to seek remedies before the DIFC Courts in accordance with the Data Protection Law, including under Article 64A. Contact details and further information about the complaints process are available at https://www.difc.ae/business/operating/data-protection/.

However, we would appreciate the opportunity to address your concerns before you approach the Commissioner of Data Protection, so please contact us in the first instance using the details set out in paragraph 10.

If your complaint relates to the conduct of Binghatti Capital as a DFSA-authorised firm, you may also refer your complaint to the DFSA. Further information about the DFSA's complaints process is available at www.dfsa.ae. You may contact Binghatti Capital's complaints team at complaints@binghatticapital.com.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 9 June 2026.

We will notify registered Investor Portal users of material changes to this privacy policy by posting a notice on the Website or by sending an email to the address associated with your account.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. Third-party links

The Website may include links to third-party websites, plug-ins and applications. 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 statements. When you leave the Website, we encourage you to read the privacy policy of every website you visit.

This privacy policy is governed by the laws of the Dubai International Financial Centre, including DIFC Data Protection Law No. 5 of 2020 (as amended).

PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE USING THIS WEBSITE

These terms and conditions govern the use of the Binghatti Capital website accessible at www.binghatticapital.com (the "Website"), including the investor portal accessible to registered users of the Website (the "Investor Portal").

Who we are and how to contact us

The Website is operated by Binghatti Capital Limited ("We" / "us" / "our" / "Binghatti Capital"), a company incorporated in the Dubai International Financial Centre ("DIFC").

Binghatti Capital is authorised and regulated by the Dubai Financial Services Authority ("DFSA") under Reference Number F010521.

Binghatti Capital is permitted to carry on the following regulated financial services in accordance with its DFSA Licence:

(a)Managing a Collective Investment Fund;
(b)Advising on Financial Products;
(c)Arranging Deals in Investments; and
(d)Managing Assets,

with endorsement to Hold or Control Client Assets and to Operate an Islamic Window.

To contact us, please email info@binghatticapital.com.

Important regulatory notices

This Website and the information contained herein are intended solely for Professional Clients, as defined under the DFSA Rulebook. Binghatti Capital does not deal with retail clients.

Nothing on this Website constitutes an offer or invitation to subscribe for or purchase units in any collective investment fund. Any such offer will be made solely pursuant to the relevant fund's offering documents, which should be read carefully before making any investment decision. In the event of any inconsistency between this Website and the relevant offering documents, the offering documents will prevail.

No content on this Website constitutes a financial promotion, offer, recommendation or invitation to engage in any investment activity except where made lawfully through the relevant offering documents and directed to eligible recipients in accordance with the DFSA Rulebook.

By using the Website you accept these terms

By accessing or using the Website (including the Investor Portal), you confirm that you accept these terms of use and that you agree to comply with them.

If you do not agree to these terms, you must not use the Website.

We recommend that you retain a copy of these terms for future reference.

There are other terms that may apply to you

These terms of use refer to the following additional terms, which also apply to your use of the Website:

(a)Our Privacy Policy available at [PRIVACY POLICY URL], which explains how we collect, use and store your personal data in accordance with DIFC Data Protection Law No. 5 of 2020 (as amended) and, to the extent applicable, UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and its implementing regulations.

We may make changes to these terms

We may amend these terms from time to time. Every time you wish to use the Website, please check these terms to ensure you understand the terms that apply at that time.

These terms were most recently updated on 9th June 2026.

We will notify registered Investor Portal users of material changes to these terms by posting a notice on the Website or by sending an email to the address associated with your account. Your continued use of the Website after such notification constitutes your acceptance of the amended terms.

We may make changes to the Website

We may update and change the Website from time to time to reflect changes to our services, regulatory obligations, user requirements and business priorities. We will endeavour to give registered users reasonable notice of any major changes that materially affect the Website's functionality.

We may suspend or withdraw the Website

Access to the Website is provided free of charge.

We do not guarantee that the Website, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of the Website (including the Investor Portal) for business, operational or regulatory reasons. We will endeavour to give you reasonable notice of any suspension or withdrawal.

We may transfer this agreement to someone else

We may transfer our rights and obligations under these terms to another organisation. We will notify you in writing if this happens and we will ensure that the transfer will not materially affect your rights under these terms.

Eligibility and intended audience

The Website is directed to, and intended for use by, Professional Clients (as defined under the DFSA Rulebook). General informational content on the Website (such as corporate information about Binghatti Capital) may be accessed by other persons, but no person who is not a Professional Client should rely on, or act upon, any content on this Website that relates to financial services, investment products, fund performance, or any other regulated activity.

The Investor Portal is directed to, and intended for use by, investors who have an existing investment relationship with Binghatti Capital and who have been granted access credentials by us.

We reserve the right to refuse registration or restrict access to any person who does not satisfy the eligibility criteria set out in these terms.

We reserve the right to remove, restrict or withdraw any content from the Website or the Investor Portal, or to limit access to any part of the Website, by reference to jurisdiction, investor classification, product status, regulatory requirement or any other factor we consider relevant.

You must keep your account details safe

If you are provided with a user identification code, password or any other piece of information as part of our security procedures for the Investor Portal, you must treat such information as confidential. You must not disclose it to any third party.

You are responsible for all activity that occurs under your account, whether or not authorised by you.

We have the right to disable any user identification code or password at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these terms of use.

If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify us at info@binghatticapital.com

You acknowledge and agree that we will not be liable for any loss, damage or unauthorised disclosure arising from or in connection with the compromise of your account credentials, except to the extent directly caused by our fraud or wilful misconduct. You are solely responsible for maintaining the security of your login credentials and for any activity conducted through your account.

The Investor Portal

The Investor Portal provides registered investors with read-only access to information relating to their investments with Binghatti Capital. The Investor Portal is an informational tool only; it does not permit investors to execute transactions, place orders, submit instructions or take any other action in respect of their investments.

The information displayed on the Investor Portal is provided for your convenience and general information only. It is not intended to constitute investment advice, a recommendation, an offer or an invitation to engage in any investment activity.

The Investor Portal is not the authoritative legal or financial record of your holdings, valuations, Net Asset Value, capital commitments, capital calls, distributions, entitlements or any other aspect of your investment relationship with Binghatti Capital or any fund managed by Binghatti Capital. Information displayed on the Investor Portal is indicative only and may be incomplete, delayed, subject to correction or not current. You must not treat any information on the Investor Portal as a definitive statement of your investment position.

In the event of any discrepancy between the information displayed on the Investor Portal and (i) the relevant fund's offering documents, constitutional documents, subscription agreements or side letters, (ii) any formally issued capital call notice, distribution notice, investor statement or other official communication from Binghatti Capital or the relevant fund, or (iii) our internal records, the relevant fund documentation, formal notice or internal record (as applicable) will prevail.

We reserve the right to modify, suspend or discontinue any feature or category of the Investor Portal at any time, with or without notice.

Precedence of fund documentation

The content of this Website and the Investor Portal is supplementary to, and does not replace, amend or override, any fund documentation. For the purposes of these terms, "fund documentation" means the relevant fund's offering documents (including any prospectus, offering memorandum or private placement memorandum), constitutional documents, subscription agreements, side letters, capital call notices, distribution notices, investor statements and any other formal communication issued by or on behalf of Binghatti Capital or the relevant fund.

In the event of any inconsistency between the content of this Website or the Investor Portal and any fund documentation, the fund documentation will prevail in all respects.

Any decision to invest in, or to continue to hold an investment in, any fund managed by Binghatti Capital should be made solely on the basis of the relevant fund documentation and, where appropriate, independent professional advice. You should not make any investment decision in reliance on the content of this Website or the Investor Portal.

Investment risk warnings

Investment involves risk. The value of investments and any income derived from them may rise or fall, and investors may not recover the full amount invested.

Past performance is not a reliable indicator of future results. No guarantee is given as to the performance of any investment strategy, fund or product.

Any decision to engage Binghatti Capital's services or to invest in any fund managed by Binghatti Capital should be made only after reviewing all relevant fund documentation and, where appropriate, obtaining independent professional advice.

Islamic Window

Binghatti Capital operates an Islamic Window in accordance with the DFSA Islamic Finance Rules.

Any reference on this Website to Sharia-compliant products or services is product-specific and is based on the firm's internal Sharia governance arrangements, including independent Sharia review and supervision where applicable. Such references are subject to, and qualified by, the relevant fund documentation and the determinations of the applicable Sharia supervisory board. The DFSA does not assess or endorse the Sharia compliance of any product or service.

Disclaimer

While we take reasonable care in preparing the content of this Website, the information contained herein is provided for general information purposes only and does not constitute investment advice, a recommendation, an offer or an invitation to engage in any investment activity.

Content on this Website may be incomplete, delayed, subject to correction or not current. Although we make reasonable efforts to update the information on the Website, we do not warrant or guarantee that the content is accurate, complete or up to date at all times.

The content on this Website is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on this Website.

Nothing in this "Disclaimer" section seeks to exclude or limit any duty or liability that we owe to you under legislation administered by the DFSA, including the duty to communicate information in a way that is clear, fair and not misleading.

How you may use material on the Website

We are the owner or the licensee of all intellectual property rights in the Website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You may print off one copy, and may download extracts, of any page(s) from the Website for your personal, non-commercial use, provided that you do not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you do not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of content on the Website must always be acknowledged.

You must not use any part of the content on the Website for commercial purposes without obtaining a licence to do so from us or our licensors.

If you copy, download, share or repost any part of the Website in breach of these terms of use, your right to use the Website will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

Prohibited conduct

You shall not conduct, facilitate, authorise or permit any text or data mining or web scraping in relation to the Website or any services provided via, or in relation to, the Website, for any purpose, including the development, training, fine-tuning or validation of AI systems or models. This includes using (or permitting, authorising or attempting the use of):

(a)Any "robot", "bot", "spider", "scraper" or other automated device, program, tool, algorithm, code, process or methodology to access, obtain, copy, monitor or republish any portion of the Website or any data, content, information or services accessed via the same.
(b)Any automated analytical technique aimed at analysing text and data in digital form to generate information, which includes but is not limited to patterns, trends and correlations.

This provision does not apply insofar as (but only to the extent that) we are unable to exclude or limit text or data mining or web scraping activity by contract under the laws which are applicable to us.

Rules about linking to the Website

You may link to the home page of the Website, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.

You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.

You must not establish a link to the Website in any website that is not owned by you.

The Website must not be framed on any other site, nor may you create a link to any part of the Website other than the home page.

We reserve the right to withdraw linking permission without notice.

If you wish to link to or make any use of content on the Website other than that set out above, please contact info@binghatticapital.com

Our trade marks

"Binghatti Capital" and the Binghatti Capital logo are trade marks of Binghatti Capital and/or its affiliates. You are not permitted to use our trade marks, logos or branding without our prior written consent, except as expressly permitted under these terms.

We are not responsible for websites we link to

Where the Website contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them.

We have no control over the contents of those sites or resources.

We are not responsible for viruses

We do not guarantee that the Website will be secure or free from bugs or viruses.

You are responsible for configuring your information technology, computer programmes and platform to access the Website. You should use your own virus protection software.

You must not introduce viruses

You must not misuse the Website by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful, or otherwise harmfully interacting with the Website or any part of it. You must not attempt to gain unauthorised access to the Website, the server on which the Website is stored or any server, computer or database connected to the Website or any other equipment or network connected with the Website. You must not interfere with, damage or disrupt any software used in the provision of the Website or any equipment or network or software owned or used by any third party on which the Website relies in any way. You must not attack the Website via a denial-of-service attack or a distributed denial-of-service attack.

By breaching this provision, you may commit a criminal offence. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use the Website will cease immediately.

Confidentiality

You acknowledge that in the course of using the Website (and in particular the Investor Portal) you may have access to information that is confidential to Binghatti Capital, including fund details, pricing, net asset values, portfolio data, investor statements and other commercially sensitive information ("Confidential Information").

You must keep all Confidential Information strictly confidential and must not disclose it to any third party without our prior written consent, except to the extent required by law or regulation or to your professional advisers (including lawyers, accountants and auditors) who have a need to know and who are subject to professional or statutory obligations of confidentiality.

Without limiting the generality of the foregoing, you must not download, forward, copy, screenshot, extract, reproduce or redistribute any investor-specific content from the Investor Portal (including, without limitation, portfolio data, investor statements, capital call or distribution information, Net Asset Value reports and fund fact sheets) to any third party or for any purpose other than your own personal review of your investment position, without our prior written consent.

This obligation of confidentiality survives the termination or expiry of your access to the Website and the Investor Portal.

Limitation of liability

Nothing in these terms seeks to exclude or limit any duty or liability that Binghatti Capital owes to any person under legislation administered by the DFSA, including the obligation to communicate information in a way that is clear, fair and not misleading pursuant to GEN Rule 4.2.6 (Principle 6 for Authorised Firms) and the prohibition in COB Rule 3.2.2 on attempting to limit or avoid any such duty or liability. To the extent that any provision of these terms is inconsistent with any such duty or liability, that provision will be read down or disapplied to the extent necessary to give effect to the applicable regulatory requirement.

Subject to the foregoing we exclude all implied conditions, warranties, representations or other terms that may apply to the Website or any content on it, to the fullest extent permitted by law.

We are not liable to you for any loss or damage, whether in contract, tort (including negligence) or otherwise, even if foreseeable, arising under or in connection with:

(a)your use of, or inability to use, the Website (including the Investor Portal);
(b)your use of or reliance on any content displayed on the Website or the Investor Portal;
(c)any act or omission of any third party in connection with the Website;
(d)any delay, interruption, suspension or unavailability of the Website or the Investor Portal (whether scheduled or unscheduled), including any delay in the publication, updating or correction of any content;
(e)any error, inaccuracy, omission or incompleteness in any data, report, valuation, statement or other content displayed on the Investor Portal, including any display, calculation, formatting or data-transmission error;
(f)any failure, interruption, error or delay in any third-party system, data feed, pricing source, custodian, administrator or other service provider on which the Website or the Investor Portal relies;
(g)any corruption, loss or unauthorised disclosure of data arising from or in connection with the transmission of information to or from the Website or the Investor Portal; or
(h)any unauthorised access to, or use of, the Investor Portal resulting from the compromise of your account credentials, except to the extent directly caused by our fraud or wilful misconduct.

In particular, we are not liable for:

(a)loss of profits, sales, business or revenue;
(b)business interruption;
(c)loss of anticipated savings;
(d)loss of business opportunity, goodwill or reputation;
(e)loss of or corruption of data; or
(f)any indirect, special or consequential loss or damage.

Suspension and termination of access

We may suspend or terminate your access to the Investor Portal at any time and without prior notice if:

(a)you breach any provision of these terms;
(b)your investment relationship with Binghatti Capital is terminated or expires;
(c)we are required to do so by law, regulation or by order of a competent authority (including the DFSA); or
(d)we reasonably believe that your account has been compromised or is being used fraudulently or by an unauthorised person.

Without limiting the foregoing, we may also suspend, restrict or withdraw your access to the Website or the Investor Portal (in whole or in part) immediately and without prior notice for any administrative, security, regulatory, investor-classification, eligibility or confidentiality reason, or where we consider it necessary or prudent to do so in order to comply with our obligations under the DFSA Rulebook or any other applicable law or regulation.

Upon termination of your access:

(a)all rights granted to you under these terms will immediately cease;
(b)you must immediately cease using the Investor Portal; and
(c)we may retain your data as required by law or regulation or as reasonably necessary for the resolution of any outstanding matters.

Termination of your access to the Investor Portal does not affect any rights, obligations or liabilities that have accrued prior to termination.

Complaints handling

Binghatti Capital has established procedures for the fair, transparent and prompt handling of complaints in accordance with the DFSA Rulebook.

Clients wishing to make a complaint may do so by contacting us at complaints@binghatticapital.com. We will acknowledge receipt of your complaint promptly and will endeavour to resolve it within the timeframe required by the DFSA Rulebook. We will keep you informed of the progress of your complaint and will provide you with a written response setting out our findings and any remedial action we propose to take.

If you are not satisfied with our response, or if your complaint has not been resolved within the period prescribed by the DFSA Rulebook, you may refer your complaint to the Dubai Financial Services Authority. Further information about the DFSA's complaints process is available at www.dfsa.ae.

Further information regarding our complaints handling procedures is available upon request.

How we may use your personal information

We will only use your personal information as set out in our Privacy Policy [PRIVACY POLICY URL]. Our processing of your personal data is conducted in accordance with DIFC Data Protection Law No. 5 of 2020 (as amended).

Governing law and dispute resolution

These terms of use, their subject matter and their formation (and any non-contractual disputes or claims arising out of or in connection with them) are governed by and construed in accordance with the laws of the Dubai International Financial Centre.

Any dispute arising out of or in connection with these terms, including any question regarding their existence, validity or termination, shall be referred to and finally resolved by the DIFC Courts, which shall have exclusive jurisdiction.

General

These terms, together with the documents referred to in them, constitute the entire agreement between you and us in relation to your use of the Website and supersede all previous agreements, understandings and arrangements between us in respect of the same, whether written or oral.

For the avoidance of doubt, nothing in these terms supersedes, varies or replaces any fund documentation (as defined in the "Precedence of fund documentation" section above) or any separate agreement between you and Binghatti Capital or any fund managed by Binghatti Capital.

If any provision of these terms is found by any court or competent authority to be invalid, unlawful or unenforceable, that provision will be deemed modified to the minimum extent necessary to make it valid, lawful and enforceable. If such modification is not possible, the relevant provision will be deemed deleted. Any modification or deletion of a provision under this paragraph will not affect the validity and enforceability of the remaining provisions.

No failure or delay by us in exercising any right or remedy under these terms will constitute a waiver of that right or remedy, nor will it prevent or restrict the further exercise of that or any other right or remedy.

These terms do not confer any rights on any person or party other than you and us.

These terms are drafted in the English language. If these terms are translated into any other language, the English language version will prevail.

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Privacy Center

PRIVACY POLICY

BINGHATTI CAPITAL LIMITED

CONTENTS

1. Important information and who we are

2. The types of personal data we collect about you

3. How is your personal data collected?

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Contact details

11. Complaints

12. Changes to the privacy policy and your duty to inform us of changes

13. Third-party links

1. Important information and who we are

2. The types of personal data we collect about you

3. How is your personal data collected?

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Contact details

11. Complaints

12. Changes to the privacy policy and your duty to inform us of changes

13. Third-party links

PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE USING THIS WEBSITE