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ACE Society — Data Protection & Privacy Policy

Last updated: June 16, 2026

Preamble

Discretion sits at the center of what ACE Society offers. The same standard of confidentiality that governs introductions, deal flow and conversations inside the network extends, without exception, to how we handle your personal data. This policy sets out, in full, how ACE Society ("ACE Society", "ACE", "we", "us") collects, uses, protects, retains and, where relevant, transfers the personal data of applicants, members and visitors to acesociety.online.

This policy is built to meet the requirements of the United Arab Emirates Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("UAE PDPL") and its Executive Regulations, the Kingdom of Saudi Arabia's Personal Data Protection Law issued under Royal Decree No. M/19 and its Implementing Regulations ("KSA PDPL"), and — for members connecting to ACE Society from the European Economic Area or the United Kingdom — the principles of the General Data Protection Regulation ("GDPR") and the UK GDPR. Where these frameworks differ, ACE Society applies whichever standard offers the data subject the greater protection.

1. Who We Are

M Holding Investments LLC is the data controller responsible for the personal data described in this policy. Questions relating to your personal data can be directed to our Data Protection Contact at contact@acesociety.online.

2. Scope

This policy applies to:

  • Visitors browsing acesociety.online
  • Applicants completing a Member Access form (Signature or Circle) or a VIP Candidature form
  • Confirmed members of the Signature, Circle or VIP tiers
  • Subscribers to ACE Insights or the ACE newsletter
  • Anyone contacting ACE Society directly by email

3. Data We Collect

We collect only what is necessary to operate a private, curated network — never more.

3.1 Identity & Contact Data

Full name, email address, phone/WhatsApp number, city and country of residence, submitted through the Member Access and VIP Candidature forms.

3.2 Professional & Network Data

Sector, company, role, years of experience, geographic scope of activity, strongest network location, ticket size range, investment interests, past investment activity, existing Abu Dhabi/Riyadh connections, and — for VIP applicants — your principal achievement, your expectations of ACE Society, and the value you bring to the network.

3.3 Payment Data

ACE Society does not collect, view or store card numbers, expiry dates or CVC codes. All payment data is collected and processed directly by Stripe, Inc. under its own security standards (PCI-DSS Level 1). ACE Society only receives confirmation of payment, the amount, the tier purchased, and any promotional code used.

3.4 Shipping Data

Postal address, for members entitled to receive the ACE Membership Kit (metal card, signature pen, ACE notebook).

3.5 Technical Data

IP address, browser type, device type, and aggregated, anonymised usage statistics collected through functional and analytics cookies (see Section 9).

3.6 Communications

Any information you share with us directly by email or messaging, including support requests and refund or dispute communications.

We do not knowingly collect any of the special categories of sensitive personal data defined under the UAE PDPL or KSA PDPL (health data, biometric data, genetic data, religious beliefs or criminal records), and we ask applicants not to include such information in free-text fields of any form.

4. Legal Basis & Purpose of Processing

We process your personal data on one or more of the following bases, consistent with the UAE PDPL, the KSA PDPL and GDPR-equivalent principles:

  • Your consent, given when you submit a Member Access or VIP Candidature form, or subscribe to ACE Insights
  • The performance of the contract formed once your access is confirmed (see our Terms & Conditions of Sale)
  • Our legitimate interest in operating a curated, trust-based network — in particular, reviewing applications, preventing fraud, and preserving the quality and discretion that define ACE Society
  • Compliance with a legal obligation, where applicable (for example, financial record-keeping)

We use your data exclusively to:

  • Review your application and determine eligibility for Signature, Circle or VIP access
  • Activate and administer your membership, including your Member Lounge and Deal Room access
  • Organise ACE Gatherings in Abu Dhabi and Riyadh, including selection and invitation
  • Communicate with you regarding your access, ACE Announcements, and network news
  • Ship your ACE Membership Kit
  • Improve and secure acesociety.online

4.1 ACE Directory

Inclusion in the ACE Directory (Signature and Circle tiers) is based on your explicit consent and can be withdrawn at any time by contacting us. VIP profiles are never listed in the Directory, by design.

We never use your data to train third-party advertising profiles, and we never sell your data.

5. Sharing of Data

ACE Society shares personal data only with the processors strictly necessary to deliver the service, each bound by data processing terms consistent with the UAE PDPL, the KSA PDPL or GDPR, as applicable:

  • Stripe, Inc. — payment processing
  • Our website hosting and e-commerce infrastructure providers
  • Our professional email delivery service provider
  • Internal workflow and application-review tools used solely to administer membership applications and status
  • Courier and logistics partners — delivery of the ACE Membership Kit, limited strictly to name and shipping address

We do not share your data with any other third party for marketing or commercial purposes, and we never disclose your participation in ACE Society — at any tier — without your consent, except where required by law.

6. International Data Transfers

Because ACE Society operates across the UAE and Saudi Arabia while using international service providers, your data may be transferred to, and processed in, countries outside the UAE or the Kingdom of Saudi Arabia — including the United States, where Stripe and certain hosting infrastructure operate. In each case, ACE Society relies on the standard contractual and security safeguards offered by these providers, consistent with the cross-border transfer requirements of the UAE PDPL and the KSA PDPL's Regulation on Personal Data Transfer Outside the Kingdom.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this policy:

  • Confirmed member data (Signature, Circle, VIP): for the duration of your membership, and up to 5 years afterward for legal, accounting and dispute-resolution purposes
  • VIP candidacy data where the application is not accepted: 12 months from the decision, then deleted, unless you ask us to remove it sooner
  • Newsletter / ACE Insights subscriber data: until you unsubscribe
  • Payment records: retained by Stripe and ACE Society in line with applicable financial record-keeping obligations

8. Your Rights

Wherever you are connecting from, ACE Society recognises the following rights, aligned across the UAE PDPL, the KSA PDPL and the GDPR:

  • Right to be informed of how your data is processed
  • Right of access to the personal data we hold about you
  • Right to rectification of inaccurate or incomplete data
  • Right to erasure ("right to be forgotten"), subject to legal retention obligations
  • Right to restrict or object to certain processing, including direct marketing
  • Right to data portability, in a structured, machine-readable format
  • Right to withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal

To exercise any of these rights, contact us at contact@acesociety.online. We respond to all requests within 30 days.

9. Cookies & Technical Data

acesociety.online uses strictly necessary and functional cookies to operate the site, and aggregated analytics cookies to understand how visitors interact with the network's public pages. We do not use third-party advertising cookies that build a behavioural profile of you without your awareness. (If and when Meta, TikTok or Snap pixels are activated, this section must be updated to disclose them and, where required, obtain prior consent through a cookie banner.)

10. Security

We apply technical and organisational measures appropriate to the sensitivity of the data we hold, including encrypted transmission (HTTPS/TLS), restricted internal access to applicant and member data, and the use of reputable, security-audited processors — including PCI-DSS Level 1 compliant payment processing via Stripe. No system is entirely without risk; in the event of a personal data breach likely to affect your rights, we will notify the relevant authority and affected members without undue delay, in line with the breach notification requirements of the UAE PDPL and the KSA PDPL.

11. Children

ACE Society is intended exclusively for adults engaged in business and investment activity. We do not knowingly collect personal data from anyone under the age of 18, and access to any tier requires confirmation that the applicant meets this threshold.

12. Complaints

If you believe your data has not been handled in accordance with this policy, contact us directly at contact@acesociety.online to resolve the matter. You also retain the right to lodge a complaint with the UAE Data Office, the Saudi Data & Artificial Intelligence Authority (SDAIA), or your relevant national data protection authority.

13. Updates to This Policy

ACE Society may update this policy as the network evolves. The version in force is always the one published on this page, dated above. Material changes will be communicated to members through ACE Announcements.

14. Contact

For any question relating to this policy or your personal data: contact@acesociety.online