Privacy Policy
1. Introduction:
This Privacy Policy describes how we, Ahoy DMCC, its affiliates, and subsidiaries (“Ahoy” or the “We”), collect, use, disclose, share, and protect your personal information. Your registration or sometimes usage of our website and using any of our services in any way mean your unconditional approval of this Privacy Policy.
By you, We mean any Company, individual, customers, Merchant, Bounty, User, or any person interacting with Ahoy platform (“You”).
Please note, We may update this Privacy Policy from time to time. Your continuing of use of our services after changes are posted constitutes your implicit approval of such updates.Data breaches or misuse of proprietary information
Privacy of your personal information is important to us, and if You do not agree to the terms of this Privacy Policy, please stop using the platform.
We care about your privacy, and as such, We will always try and mask your information when it needs to be handled by contractors using APIs for call forwarding and masking, SMS, and email forwards; thus, reducing the amount of details and number of times your information is passed on or exposed.
2. Changes to our privacy policy:
Our Privacy Policy reflects our current practices, and is subject to change and update from time to time. If We change our Privacy Policy, We will inform You through a notice advising of such change your consent will not be required to continue using Ahoy services.
3. Scope:
We do not collect information about You unless we need it.
We do not share your personal information with anyone unless We are required to do so in accordance with the applicable laws and regulations including the laws of the United Arab Emirates.
We will not store your personal information on our servers unless it is required for a current profile/account, the betterment of the service, preference accommodation when You choose to save that and continuous operation of one of our services.Dedicated Whistleblower Hotline: Confidential telephone line managed by an external provider.
4. We collect the following types of information:
First: The Information You Provide Us Directly
We collect information that You provide when accessing or participating in any of our services, such as when creating any type of membership, or using our services, or introducing friends and family or clients, brochures, and literature, or leaving a comment, or completing a survey, or accessing any of our other services either as an initiator, recipient or to those you wish us to contact on your behalf concerning one or more of our services.
The information You provide may specifically identify You, your dependents, friends, family or your customers including name, email address, postal address, business address, telephone numbers, payment information (including payment card numbers), use of services, and all other corporate information, brochures, and studies for investors.
The amount and type of information You provide depends on the nature of the interaction. If You refuse to provide personally identifiable information, the system may prevent You from using our corresponding services. In addition to the information mentioned above, You can provide information about You, but this does not identify your identity, such as age, gender, zip code, interests, and preferences regarding our services.
In the case You provide us with information concerning a friend, customer, family member, or anyone You wish us to interact with; We assume that You have acquired and You must have the authority or permission to do so on their behalf.
Second: The information is automatically collected when You use or access our services
Cookies. Like most online services, We may use cookies, tokens, OTP (one time password) and other technologies and methodologies, such as BLE beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device.
A browser cookie or an access token is a small portion of data stored on your device to help websites remember things about You. Other technologies, including Web storage and identifiers associated with your device, may be used for similar purposes. This type of technology will be referred to as cookies ("Cookies") in this Privacy Policy.
We may also use these Cookies to collect information when You interact with our Service. Most web browsers are set to accept Cookies by default. If You prefer otherwise, You can remove or reject browser cookies through settings on your browser or device. However, You should bear in mind that removing or rejecting Cookies can affect the availability and functionality of our services.
We may use cookies for a number of reasons, first of which is to protect your personal data and account, helping us know which features are most popular, counting visitors to a page, improving our users’ experience, keeping our services secure, and generally to providing You with a better, more intuitive, and satisfying experience and on your mobile device they are used to verify you at singing in and to keep you singed in.
Cookies we generally use fall into one of the following categories: (1) preferences: We use these Cookies to remember your settings and preferences. (e.g.: languages…etc); (2) security: We use these Cookies to help identify you and give you access and prevent security risks; (3) performance: We use these cookies to collect information about how You interact with our services and to help us improve them. (e.g.: to determine if you have interacted with a certain page).
When You or someone on your behalf asks us to contact You and You decide to change your preferences concerning how We contact You or communicate with You to deliver a service without having an account with Ahoy, only in this event We will create a profile for your preferences that is correlated to your address, contact details and/or name and email ID. You will always get notified before we create a profile where We will ask you to accept our Privacy Policy.
Additionally, for the purpose of providing You with our high quality services We might ask for your permission to (1) access your device camera for the purpose of QR code scanning for basic app functionality and the optional use of a profile picture, (2) Your live location for basic functionality to retrieve your location relevant to the services related to You, We will not save your location unless You choose to do so by adding it to your locations list, address book, favorites and such or through your order history. (3) Bluetooth/Wi-Fi, since AHOY use IoT devices that is part of the service delivery, as well as location accuracy. (4) Notifications, for status updates and alerts for actions required by you.
Third: How We Use the Information
In addition to some of the specific uses of information this Privacy Policy covers, we may use information that we receive in order to: (1) manage, develop, operate, improve, deliver, maintain, and protect our services; (2) communicate with You by all means of communications, including by email. For example, We may use email to respond to support inquiries or to exchange information about our services, and promotional offers that we think may interest you; (3) monitor and analyze trends and usage; (4) enhance the safety and security of our services; (5) verify your identity and prevent fraud or other unauthorized or illegal activity; (6) use information We’ve collected from Cookies and other technology to enhance our services and your experience; (7) enforce our Terms and Conditions and other usage policies; (7) Accounts and records and information verification; (8) Relevant government agencies; (9) Publishing on the Platform and/or social media accounts of Ahoy; (10) Managing the data and data bank; (11) Press and media; and (12) Imposing other terms and conditions and usage policies.
We will use the information to communicate with you directly, such as direct marketing via e-mail messages or service-related messages (for example, account verification, change, or updates to the technical and security service notification features).
Fourth: Share your information
Ahoy discloses your information to its employees, contractors, and affiliated organizations that (1) need that information in connection with the services and (2) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using Ahoy services, You consent to the transfer of such information to them to the extent permissible under applicable law.
We may share your information with our corporate entities including any holding company, affiliates and subsidiaries. If Ahoy gets involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of its business to another company, We may share your information with that company before and after the transaction closes.
We may also share your information with partners and service providers to provide or support our services, process payments, financing services, or credit reviews, or that assist Ahoy in marketing to customers or improving the user experience for our clients and end users. For example, We may share your information with companies that provide services such as data processing, extending credit, fulfilling customer orders, delivering products to You, managing and enhancing customer data, providing customer service, and conducting customer satisfaction surveys. These companies are obligated to protect your information and may be located anywhere the company operates. If the service is approved to be provided, your account will be subject to the company, distributor or carrier's privacy policies. Personal information will not be shared other than to provide or improve our products, services, ads and communications with companies; it will not be shared with third parties for their own marketing purposes.
The information We receive about You may be accessed, processed, and kept for a long period of time when this is a systemic requirement, governmental obligation, investigation, or investigation regarding possible violations of our terms or policies, or to prevent any imminent harm.
Fifth: Information protection
Ahoy understands that the information collected and shared with us contains sensitive data. Therefore, you should be assured that we take our role to protect your information very seriously. We also provide high-quality security programs on our Platform based on high industry standards and provide best practices. In addition, we take a strong defensive approach to countering cyber-attacks and securing information from unauthorized access or misuse.
Passwords. You should never share your password with anyone. Your password is unknown to any employee within Ahoy or any third party, and we will never ask for your password via phone or email. If you receive any communication claiming to be from Ahoy asking for your password, you must report it immediately.
We also periodically review and adjust security measures to ensure the highest quality. Ultimately, there is no non-hackable security system, thus, We cannot guarantee the security of our systems 100%. In the event that any information subject to our control is attacked by a cyber-attack as a result of a security breach, our policy is to take reasonable steps to investigate the situation, and we have the discretion to communicate with and compensate the affected individuals.
Sixth: Data Storage and Transmission
The information collected through our website may be stored and processed in the United Arab Emirates or any other country where We or our subsidiaries or service providers own servers. If You are located in the European Union or in other regions with laws governing data collection and use that may differ from the United Arab Emirates laws, please note that We may transfer your information, including personal information, to a country that does not have the same data protection laws as your country, and You authorize us and agree that We transfer such information to the United Arab Emirates or any other country in which We or our subsidiaries or service providers own servers and storage locations, as described in this Privacy Policy.
5. Third Party:
Certain third party’s links may appear on the Ahoy platforms. Please note that Ahoy is not responsible of any third-party materials that appears on its platforms. Your access to these third party sites and adds is on your own discretion and responsibility.
6. Governing Law:
This Privacy Policy is governed by and construed in accordance with Federal Decree-Law No. 45/2021 on the Protection of Personal Data (UAE PDPL) and all applicable UAE federal and emirate-level laws and regulations.
This policy shall be subject to the non-exclusive jurisdiction of the courts of Dubai, United Arab Emirates, or such other competent UAE courts as may have jurisdiction over any disputes arising from or in connection with this policy, including but not limited to:
Dubai Courts (for mainland matters)
Dubai International Financial Centre (DIFC) Courts
Abu Dhabi Global Market (ADGM) Courts
Data subjects (UAE residents) retain all rights to lodge complaints with the UAE Data Office under the UAE Data Law, regardless of governing law provisions.
7. Disclaimer:
PLEASE NOTE THAT YOUR CONSENT FORM A LEGAL GROUND FOR AHOY TO USING, COLLECTING, AND PROCESSING YOUR PERSONAL INFORMATION FAIRLY AND LAWFULLY SUBJECT TO THIS PRIVACY POLICY AND APPLICABLE LAW. YOUR AGREEMENT TO THIS PRIVACY POLICY CONSTITUTE AN INFORMED CONSENT TO YOUR PERSONAL INFORMATION.
If you do not agree to this Privacy Policy, you will not be able to access and benefit from the Service.
1. Introduction:
This Privacy Policy describes how we, Ahoy DMCC, its affiliates, and subsidiaries (“Ahoy” or the “We”), collect, use, disclose, share, and protect your personal information. Your registration or sometimes usage of our website and using any of our services in any way mean your unconditional approval of this Privacy Policy.
By you, We mean any Company, individual, customers, Merchant, Bounty, User, or any person interacting with Ahoy platform (“You”).
Please note, We may update this Privacy Policy from time to time. Your continuing of use of our services after changes are posted constitutes your implicit approval of such updates.Data breaches or misuse of proprietary information
Privacy of your personal information is important to us, and if You do not agree to the terms of this Privacy Policy, please stop using the platform.
We care about your privacy, and as such, We will always try and mask your information when it needs to be handled by contractors using APIs for call forwarding and masking, SMS, and email forwards; thus, reducing the amount of details and number of times your information is passed on or exposed.
2. Changes to our privacy policy:
Our Privacy Policy reflects our current practices, and is subject to change and update from time to time. If We change our Privacy Policy, We will inform You through a notice advising of such change your consent will not be required to continue using Ahoy services.
3. Scope:
We do not collect information about You unless we need it.
We do not share your personal information with anyone unless We are required to do so in accordance with the applicable laws and regulations including the laws of the United Arab Emirates.
We will not store your personal information on our servers unless it is required for a current profile/account, the betterment of the service, preference accommodation when You choose to save that and continuous operation of one of our services.Dedicated Whistleblower Hotline: Confidential telephone line managed by an external provider.
4. We collect the following types of information:
First: The Information You Provide Us Directly
We collect information that You provide when accessing or participating in any of our services, such as when creating any type of membership, or using our services, or introducing friends and family or clients, brochures, and literature, or leaving a comment, or completing a survey, or accessing any of our other services either as an initiator, recipient or to those you wish us to contact on your behalf concerning one or more of our services.
The information You provide may specifically identify You, your dependents, friends, family or your customers including name, email address, postal address, business address, telephone numbers, payment information (including payment card numbers), use of services, and all other corporate information, brochures, and studies for investors.
The amount and type of information You provide depends on the nature of the interaction. If You refuse to provide personally identifiable information, the system may prevent You from using our corresponding services. In addition to the information mentioned above, You can provide information about You, but this does not identify your identity, such as age, gender, zip code, interests, and preferences regarding our services.
In the case You provide us with information concerning a friend, customer, family member, or anyone You wish us to interact with; We assume that You have acquired and You must have the authority or permission to do so on their behalf.
Second: The information is automatically collected when You use or access our services
Cookies. Like most online services, We may use cookies, tokens, OTP (one time password) and other technologies and methodologies, such as BLE beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device.
A browser cookie or an access token is a small portion of data stored on your device to help websites remember things about You. Other technologies, including Web storage and identifiers associated with your device, may be used for similar purposes. This type of technology will be referred to as cookies ("Cookies") in this Privacy Policy.
We may also use these Cookies to collect information when You interact with our Service. Most web browsers are set to accept Cookies by default. If You prefer otherwise, You can remove or reject browser cookies through settings on your browser or device. However, You should bear in mind that removing or rejecting Cookies can affect the availability and functionality of our services.
We may use cookies for a number of reasons, first of which is to protect your personal data and account, helping us know which features are most popular, counting visitors to a page, improving our users’ experience, keeping our services secure, and generally to providing You with a better, more intuitive, and satisfying experience and on your mobile device they are used to verify you at singing in and to keep you singed in.
Cookies we generally use fall into one of the following categories: (1) preferences: We use these Cookies to remember your settings and preferences. (e.g.: languages…etc); (2) security: We use these Cookies to help identify you and give you access and prevent security risks; (3) performance: We use these cookies to collect information about how You interact with our services and to help us improve them. (e.g.: to determine if you have interacted with a certain page).
When You or someone on your behalf asks us to contact You and You decide to change your preferences concerning how We contact You or communicate with You to deliver a service without having an account with Ahoy, only in this event We will create a profile for your preferences that is correlated to your address, contact details and/or name and email ID. You will always get notified before we create a profile where We will ask you to accept our Privacy Policy.
Additionally, for the purpose of providing You with our high quality services We might ask for your permission to (1) access your device camera for the purpose of QR code scanning for basic app functionality and the optional use of a profile picture, (2) Your live location for basic functionality to retrieve your location relevant to the services related to You, We will not save your location unless You choose to do so by adding it to your locations list, address book, favorites and such or through your order history. (3) Bluetooth/Wi-Fi, since AHOY use IoT devices that is part of the service delivery, as well as location accuracy. (4) Notifications, for status updates and alerts for actions required by you.
Third: How We Use the Information
In addition to some of the specific uses of information this Privacy Policy covers, we may use information that we receive in order to: (1) manage, develop, operate, improve, deliver, maintain, and protect our services; (2) communicate with You by all means of communications, including by email. For example, We may use email to respond to support inquiries or to exchange information about our services, and promotional offers that we think may interest you; (3) monitor and analyze trends and usage; (4) enhance the safety and security of our services; (5) verify your identity and prevent fraud or other unauthorized or illegal activity; (6) use information We’ve collected from Cookies and other technology to enhance our services and your experience; (7) enforce our Terms and Conditions and other usage policies; (7) Accounts and records and information verification; (8) Relevant government agencies; (9) Publishing on the Platform and/or social media accounts of Ahoy; (10) Managing the data and data bank; (11) Press and media; and (12) Imposing other terms and conditions and usage policies.
We will use the information to communicate with you directly, such as direct marketing via e-mail messages or service-related messages (for example, account verification, change, or updates to the technical and security service notification features). For more information about your communication preferences, you may reach us out at (care(at)ahoy(dot)ae).
Fourth: Share your information
Ahoy discloses your information to its employees, contractors, and affiliated organizations that (1) need that information in connection with the services and (2) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using Ahoy services, You consent to the transfer of such information to them to the extent permissible under applicable law.
We may share your information with our corporate entities including any holding company, affiliates and subsidiaries. If Ahoy gets involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of its business to another company, We may share your information with that company before and after the transaction closes.
We may also share your information with partners and service providers to provide or support our services, process payments, financing services, or credit reviews, or that assist Ahoy in marketing to customers or improving the user experience for our clients and end users. For example, We may share your information with companies that provide services such as data processing, extending credit, fulfilling customer orders, delivering products to You, managing and enhancing customer data, providing customer service, and conducting customer satisfaction surveys. These companies are obligated to protect your information and may be located anywhere the company operates. If the service is approved to be provided, your account will be subject to the company, distributor or carrier's privacy policies. Personal information will not be shared other than to provide or improve our products, services, ads and communications with companies; it will not be shared with third parties for their own marketing purposes.
The information We receive about You may be accessed, processed, and kept for a long period of time when this is a systemic requirement, governmental obligation, investigation, or investigation regarding possible violations of our terms or policies, or to prevent any imminent harm.
Fifth: Information protection
Ahoy understands that the information collected and shared with us contains sensitive data. Therefore, you should be assured that we take our role to protect your information very seriously. We also provide high-quality security programs on our Platform based on high industry standards and provide best practices. In addition, we take a strong defensive approach to countering cyber-attacks and securing information from unauthorized access or misuse.
Passwords. You should never share your password with anyone. Your password is unknown to any employee within Ahoy or any third party, and we will never ask for your password via phone or email. If you receive any communication claiming to be from Ahoy asking for your password, you must report it immediately by contacting us at (care(at)ahoy(dot)ae).
We also periodically review and adjust security measures to ensure the highest quality. Ultimately, there is no non-hackable security system, thus, We cannot guarantee the security of our systems 100%. In the event that any information subject to our control is attacked by a cyber-attack as a result of a security breach, our policy is to take reasonable steps to investigate the situation, and we have the discretion to communicate with and compensate the affected individuals.
Sixth: Data Storage and Transmission
The information collected through our website may be stored and processed in the United Arab Emirates or any other country where We or our subsidiaries or service providers own servers. If You are located in the European Union or in other regions with laws governing data collection and use that may differ from the United Arab Emirates laws, please note that We may transfer your information, including personal information, to a country that does not have the same data protection laws as your country, and You authorize us and agree that We transfer such information to the United Arab Emirates or any other country in which We or our subsidiaries or service providers own servers and storage locations, as described in this Privacy Policy.
5. Third Party:
Certain third party’s links may appear on the Ahoy platforms. Please note that Ahoy is not responsible of any third-party materials that appears on its platforms. Your access to these third party sites and adds is on your own discretion and responsibility.
6. Governing Law:
This Privacy Policy is governed by and construed in accordance with Federal Decree-Law No. 45/2021 on the Protection of Personal Data (UAE PDPL) and all applicable UAE federal and emirate-level laws and regulations.
This policy shall be subject to the non-exclusive jurisdiction of the courts of Dubai, United Arab Emirates, or such other competent UAE courts as may have jurisdiction over any disputes arising from or in connection with this policy, including but not limited to:
Dubai Courts (for mainland matters)
Dubai International Financial Centre (DIFC) Courts
Abu Dhabi Global Market (ADGM) Courts
Data subjects (UAE residents) retain all rights to lodge complaints with the UAE Data Office under the UAE Data Law, regardless of governing law provisions.
6. Disclaimer:
PLEASE NOTE THAT YOUR CONSENT FORM A LEGAL GROUND FOR AHOY TO USING, COLLECTING, AND PROCESSING YOUR PERSONAL INFORMATION FAIRLY AND LAWFULLY SUBJECT TO THIS PRIVACY POLICY AND APPLICABLE LAW. YOUR AGREEMENT TO THIS PRIVACY POLICY CONSTITUTE AN INFORMED CONSENT TO YOUR PERSONAL INFORMATION.
If you do not agree to this Privacy Policy, you will not be able to access and benefit from the Service.
Anti-Bribery and Corruption Policy
1. Policy Statement:
At AHOY, we uphold our core values of integrity, transparency, and accountability in all our business dealings. We are committed to conducting our operations ethically and legally, strictly prohibiting bribery, corruption, and any other unethical conduct that could damage our reputation, undermine our integrity, or violate applicable laws, including those of the United Arab Emirates (UAE). This policy affirms our zero-tolerance stance towards any form of bribery and corruption and sets out the principles and standards required of all employees, directors, contractors, agents, consultants, and third-party representatives.
2. Purpose and Objectives:
To reinforce the importance of ethical conduct and compliance under UAE anti-bribery laws.
To provide clear guidance on acceptable and unacceptable behaviors related to bribery and corruption.
To prevent, detect, and address bribery and corruption within our business operations.
To establish a strong culture of integrity that supports sustainable growth and stakeholder confidence.
3. Scope and Applicability:
This policy applies to all AHOY personnel, including full-time employees, temporary staff, contractors, consultants, agents, board members, and third-party partners acting on behalf of AHOY, both within the UAE and in internationally operating contexts. All individuals involved in AHOY’s business activities must familiarize themselves with and adhere to this policy.
4. Legal Framework and Principles:
This policy is aligned with and designed to comply with UAE Federal Law No. 3 of 1987 (UAE Penal Code) concerning anti-bribery and corruption, as well as other relevant UAE laws and regulations, including:
UAE Federal Anti-Commercial Fraud Law
UAE Law Concerning Criminal and Civil Penalties for Bribery and Corruption
UAE’s commitment to international anti-bribery conventions, including those by the United Nations and the Organisation for Economic Co-operation and Development (OECD).
Our principles are based on:
Zero tolerance for bribery and corruption.
Commitment to lawful conduct and ethical integrity.
Maintaining transparency in all dealings.
Ensuring fair treatment of all stakeholders.
Providing training and resources to prevent misconduct.
Encouraging a speak-up culture for compliance concerns.
5. Definitions and Clarifications:
Bribery: Offering, promising, giving, accepting, or soliciting anything of value (e.g., money, gifts, favors, hospitality, or other benefits) to influence the actions or decisions of a person in a position of authority or to gain an improper advantage.
Corruption: Abuse of entrusted power or position for personal gain or to benefit a third party dishonestly, including bribery, kickbacks, embezzlement, or facilitation payments.
Facilitation Payments: Small, unofficial payments made to secure or expedite routine government actions or services, which are strictly prohibited under this policy and UAE law.
Third Parties: Any external entity or individual acting on behalf of AHOY, including vendors, contractors, agents, partners, or representatives.
6. Prohibited Conduct and Conduct Expectations:
Offering Bribes: Employees are strictly forbidden from offering, promising, or giving any bribe or illicit benefit directly or through intermediaries, regardless of whether such conduct is legal in the jurisdiction.
Receiving Bribes: Employees must refuse any inducement to influence or compromise their impartiality.
Gifts and Hospitality: All gifts, entertainment, or hospitality provided or accepted must be reasonable, proportionate, transparent, and permissible under local laws and AHOY policies. Gifts of substantial value or that might influence business decisions are prohibited unless explicitly approved by senior management and properly documented.
Third-Party Engagements: Before engaging third parties, conduct due diligence to assess risks and include contractual provisions requiring strict compliance with anti-bribery laws.
Facilitation Payments: Absolutely prohibit any facilitation payments, regardless of size or perceived urgency.
Use of Intermediaries: Ensure transparency in dealings with intermediaries; avoid schemes that conceal corrupt intent.
7. Due Diligence and Risk Management:
Conduct comprehensive risk assessments and due diligence when selecting new business partners, agents, or contractors, focusing on their compliance with anti-bribery laws.
Regularly review and monitor third-party compliance through audits, performance assessments, and contractual obligations.
Maintain a register of high-risk transactions and third-party relationships for ongoing oversight.
8. Gifts, Hospitality, and Donations:
Gifts, hospitality, or donations should always be modest, transparent, and within reasonable standards customary in business practice.
All gifts and hospitality exceeding predefined monetary limits or considered potentially influential require prior approval from senior management and must be properly documented.
Donations to charities or political entities must be transparent, compliant
Anti-Money Laundering Policy
1. Policy Statement
At AHOY, we are committed to preventing money laundering, terrorist financing, and related financial crimes. We uphold the highest standards of integrity, compliance, and transparency in all our business operations. This Anti-Money Laundering (AML) Policy reflects our dedication to compliance with applicable laws and regulations in the United Arab Emirates (UAE), including Federal Law No. 20 of 2018 Concerning Anti-Money Laundering and Combating the Financing of Terrorism, and associated regulations.
2. Purpose and Objectives
To establish a robust framework for detecting, preventing, and reporting potential money laundering and terrorist financing activities.
To ensure compliance with UAE AML regulations and international best practices.
To educate and empower employees to identify and mitigate AML risks.
To safeguard AHOY’s reputation and integrity by fostering a culture of compliance and transparency.
3. Scope and Applicability
This policy applies to all employees, officers, directors, contractors, agents, consultants, and any third parties acting on behalf of AHOY across all geographic jurisdictions, particularly within the UAE. It covers all aspects of AHOY’s operations, including but not limited to financial transactions, client onboarding, and third-party engagements.
4. Definitions
Money Laundering: The process of concealing the origins of illegally obtained money, typically by complex transactions, to make it appear as legitimate funds.
Terrorist Financing: Providing financial support for terrorist activities, regardless of the source.
Suspicious Activity: Any transaction or activity that raises concerns about potential money laundering or terrorist financing.
Customer Due Diligence (CDD): Procedures to verify the identity of clients and assess AML risks before establishing a business relationship.
Enhanced Due Diligence (EDD): Additional verification measures for higher-risk clients or transactions.
5. Legal and Regulatory Framework
AHOY commits to full compliance with applicable AML laws, including:
UAE Federal Law No. 20 of 2018 on AML and Terrorism Financing.
UAE Executive Regulations and related guidelines issued by the UAE Central Bank and the Financial Intelligence Unit (FIU).
International AML standards from FATF (Financial Action Task Force) and other relevant bodies.
6. Customer Due Diligence (CDD) and KYC Procedures
All clients and third parties must undergo appropriate CDD and KYC checks prior to establishing or continuing business relationships.
Customer identification must include verification of identity documents, source of funds, and assessment of AML risks.
High-risk clients and transactions will undergo EDD with stricter scrutiny and ongoing monitoring.
Ongoing monitoring of all transactions is required to identify suspicious activity.
7. Detection and Reporting of Suspicious Activities
Employees are trained to recognize red flags such as inconsistent transaction patterns, unusual client behavior, or suspicious documentation.
Any staff suspecting money laundering or terrorist financing must report promptly to the designated AML compliance officer or department.
All reports will be handled with confidentiality and in accordance with UAE legal obligations.
Suspicious activity reports (SARs) must be submitted to the UAE FIU without delay, following established reporting procedures.
8. Record Keeping
Maintain detailed records of all AML-related activities, including customer information, transaction records, risk assessments, and SARs.
Records must be retained for a minimum of five years from the end of the business relationship or transaction, in accordance with UAE law.
Recordkeeping must ensure data confidentiality and security.
9. Training and Awareness
All relevant personnel will receive ongoing AML training to stay informed of legal requirements, red flags, and reporting obligations.
Training will be conducted periodically and tailored to employees' roles and exposure to AML risks.
10. Internal Controls and Compliance
Establish and maintain effective internal controls, policies, and procedures to prevent AML violations.
Designate an AML Compliance Officer responsible for oversight, monitoring, and enforcement of this policy.
Conduct periodic AML risk assessments and audits to identify vulnerabilities and improvement areas.
Implement independent reviews and audits on AML compliance.
11. Due Diligence in Third-Party Relationships
Conduct thorough AML risk assessments for third-party relationships, including due diligence on clients, vendors, partners, and agents.
Incorporate contractual provisions requiring compliance with AML laws and this policy.
12. Policy Review and Continuous Improvement
This AML Policy will be reviewed annually or upon regulatory updates to remain current and effective.
Updates and improvements will be incorporated based on new risks, regulatory changes, or audit findings.
13. Disciplinary Actions
Non-compliance with this AML policy may result in disciplinary action, up to and including termination of employment or engagement, and legal prosecution under UAE law.
Employees are encouraged to report any concerns
1. Policy Statement
At AHOY, we are committed to preventing money laundering, terrorist financing, and related financial crimes. We uphold the highest standards of integrity, compliance, and transparency in all our business operations. This Anti-Money Laundering (AML) Policy reflects our dedication to compliance with applicable laws and regulations in the United Arab Emirates (UAE), including Federal Law No. 20 of 2018 Concerning Anti-Money Laundering and Combating the Financing of Terrorism, and associated regulations.
2. Purpose and Objectives
To establish a robust framework for detecting, preventing, and reporting potential money laundering and terrorist financing activities.
To ensure compliance with UAE AML regulations and international best practices.
To educate and empower employees to identify and mitigate AML risks.
To safeguard AHOY’s reputation and integrity by fostering a culture of compliance and transparency.
3. Scope and Applicability
This policy applies to all employees, officers, directors, contractors, agents, consultants, and any third parties acting on behalf of AHOY across all geographic jurisdictions, particularly within the UAE. It covers all aspects of AHOY’s operations, including but not limited to financial transactions, client onboarding, and third-party engagements.
4. Definitions
Money Laundering: The process of concealing the origins of illegally obtained money, typically by complex transactions, to make it appear as legitimate funds.
Terrorist Financing: Providing financial support for terrorist activities, regardless of the source.
Suspicious Activity: Any transaction or activity that raises concerns about potential money laundering or terrorist financing.
Customer Due Diligence (CDD): Procedures to verify the identity of clients and assess AML risks before establishing a business relationship.
Enhanced Due Diligence (EDD): Additional verification measures for higher-risk clients or transactions.
5. Legal and Regulatory Framework
AHOY commits to full compliance with applicable AML laws, including:
UAE Federal Law No. 20 of 2018 on AML and Terrorism Financing.
UAE Executive Regulations and related guidelines issued by the UAE Central Bank and the Financial Intelligence Unit (FIU).
International AML standards from FATF (Financial Action Task Force) and other relevant bodies.
6. Customer Due Diligence (CDD) and KYC Procedures
All clients and third parties must undergo appropriate CDD and KYC checks prior to establishing or continuing business relationships.
Customer identification must include verification of identity documents, source of funds, and assessment of AML risks.
High-risk clients and transactions will undergo EDD with stricter scrutiny and ongoing monitoring.
Ongoing monitoring of all transactions is required to identify suspicious activity.
7. Detection and Reporting of Suspicious Activities
Employees are trained to recognize red flags such as inconsistent transaction patterns, unusual client behavior, or suspicious documentation.
Any staff suspecting money laundering or terrorist financing must report promptly to the designated AML compliance officer or department.
All reports will be handled with confidentiality and in accordance with UAE legal obligations.
Suspicious activity reports (SARs) must be submitted to the UAE FIU without delay, following established reporting procedures.
8. Record Keeping
Maintain detailed records of all AML-related activities, including customer information, transaction records, risk assessments, and SARs.
Records must be retained for a minimum of five years from the end of the business relationship or transaction, in accordance with UAE law.
Recordkeeping must ensure data confidentiality and security.
9. Training and Awareness
All relevant personnel will receive ongoing AML training to stay informed of legal requirements, red flags, and reporting obligations.
Training will be conducted periodically and tailored to employees' roles and exposure to AML risks.
10. Internal Controls and Compliance
Establish and maintain effective internal controls, policies, and procedures to prevent AML violations.
Designate an AML Compliance Officer responsible for oversight, monitoring, and enforcement of this policy.
Conduct periodic AML risk assessments and audits to identify vulnerabilities and improvement areas.
Implement independent reviews and audits on AML compliance.
11. Due Diligence in Third-Party Relationships
Conduct thorough AML risk assessments for third-party relationships, including due diligence on clients, vendors, partners, and agents.
Incorporate contractual provisions requiring compliance with AML laws and this policy.
12. Policy Review and Continuous Improvement
This AML Policy will be reviewed annually or upon regulatory updates to remain current and effective.
Updates and improvements will be incorporated based on new risks, regulatory changes, or audit findings.
13. Disciplinary Actions
Non-compliance with this AML policy may result in disciplinary action, up to and including termination of employment or engagement, and legal prosecution under UAE law.
Employees are encouraged to report any concerns
Whistleblower Policy
1. Policy Statement:
At AHOY, we are committed to maintaining the highest standards of integrity, transparency, and ethical conduct across all aspects of our operations. We recognize that issues such as misconduct, dishonesty, or legal violations can occur despite our best efforts. To uphold our commitment, we encourage all employees, contractors, and stakeholders to report any concerns about unethical, illegal, or suspicious activities without fear of retaliation. This Whistleblower Policy provides a clear framework to protect individuals who report in good faith and ensures that reports are handled fairly, confidentially, and effectively, in compliance with UAE laws.
2. Purpose and Objectives:
To provide a secure and feasible mechanism for reporting concerns regarding misconduct or violations of laws, regulations, or company policies.
To protect whistleblowers from retaliation, discrimination, or unfair treatment.
To promote a transparent culture rooted in accountability and integrity.
To uphold compliance with UAE Federal Law No. 7 of 2016 on Combating Commercial Frauds and Money Laundering and other relevant legal frameworks.
3. Scope and Applicability:
This policy applies to all employees, directors, contractors, vendors, business partners, and any other stakeholders associated with AHOY. It covers a broad spectrum of concerns, including but not limited to:
Fraud, corruption, or bribery
Financial irregularities or misreporting
Violations of laws, regulations, or company policies
Harassment, discrimination, or unethical conduct
Data breaches or misuse of proprietary information
Environment, health, and safety violations
4. Reporting Channels
To facilitate safe and accessible reporting, AHOY provides multiple channels:
Dedicated Whistleblower Hotline: Confidential telephone line managed by an external provider.
Email Reporting: Secure email address monitored by the designated compliance or HR team.
Anonymous Reporting Portal: Secure online portal enabling anonymous submissions.
In-Person Reporting: Direct communication with designated compliance officers or senior management, if preferred.
All reports will be treated with the utmost confidentiality, respecting the whistleblower’s identity and privacy.
5. Confidentiality and Anonymity
AHOY commits to protecting the identity of whistleblowers to the greatest extent possible, subject to legal and investigative requirements. Whistleblowers are encouraged to disclose their identity to enable proper investigation; however, anonymous reports are also accepted and will be seriously considered and investigated.
6. Protection Against Retaliation
No Retaliation Policy: AHOY prohibits retaliation, discrimination, harassment, or any adverse action against anyone making a good-faith report. Retaliation offenders will face disciplinary measures, including termination of employment or contractual relationship, and legal action if applicable.
Good-Faith Reporting: Whistleblowers are expected to provide honest and factual information. Malicious or unfounded reports made with malicious intent may be subject to disciplinary action.
Protection Measures: Whistleblowers will be protected from dismissal, demotion, harassment, or any adverse treatment related to their reporting.
7. Investigation Process
All reports will be recorded, reviewed, and investigated promptly and thoroughly by a designated Compliance Officer or a special investigations team.
Investigations will be conducted confidentially, maintaining fairness and due process.
The whistleblower may be interviewed as part of the investigation process, and their input will be considered.
Findings and recommendations will be documented, and appropriate corrective actions will be implemented.
8. Handling of Reports
Initial Acknowledgment: Whistleblowers will receive confirmation of receipt within a specified timeframe.
Follow-Up: Regular updates regarding the investigation status will be provided, respecting confidentiality.
Outcome: Upon conclusion, the whistleblower will be informed of any corrective measures taken, consistent with confidentiality and legal requirements.
9. Record Keeping
Initial Acknowledgment: Whistleblowers will receive confirmation of receipt within a specified timeframe.
Follow-Up: Regular updates regarding the investigation status will be provided, respecting confidentiality.
Outcome: Upon conclusion, the whistleblower will be informed of any corrective measures taken, consistent with confidentiality and legal requirements.
10. Training and Awareness
All reports, investigation records, and follow-up actions will be securely stored, access limited to authorized personnel.
Data will be retained in accordance with applicable laws and internal policies.
11. Review and Continuous Improvement
This policy will be reviewed annually to ensure effectiveness, relevance, and compliance with UAE legal requirements.
Feedback from employees and stakeholders will be incorporated to improve the reporting and protection mechanisms.
12. Legal and Regulatory Compliance
AHOY’s whistleblowing procedures are designed to align with relevant UAE laws, including Federal Law No. 7 of 2016 concerning anti-money laundering and anti-fraud measures, as well as other applicable regulations.
Disclosures made in good faith and in compliance with
1. Policy Statement:
At AHOY, we are committed to maintaining the highest standards of integrity, transparency, and ethical conduct across all aspects of our operations. We recognize that issues such as misconduct, dishonesty, or legal violations can occur despite our best efforts. To uphold our commitment, we encourage all employees, contractors, and stakeholders to report any concerns about unethical, illegal, or suspicious activities without fear of retaliation. This Whistleblower Policy provides a clear framework to protect individuals who report in good faith and ensures that reports are handled fairly, confidentially, and effectively, in compliance with UAE laws.
2. Purpose and Objectives:
To provide a secure and feasible mechanism for reporting concerns regarding misconduct or violations of laws, regulations, or company policies.
To protect whistleblowers from retaliation, discrimination, or unfair treatment.
To promote a transparent culture rooted in accountability and integrity.
To uphold compliance with UAE Federal Law No. 7 of 2016 on Combating Commercial Frauds and Money Laundering and other relevant legal frameworks.
3. Scope and Applicability:
This policy applies to all employees, directors, contractors, vendors, business partners, and any other stakeholders associated with AHOY. It covers a broad spectrum of concerns, including but not limited to:
Fraud, corruption, or bribery
Financial irregularities or misreporting
Violations of laws, regulations, or company policies
Harassment, discrimination, or unethical conduct
Data breaches or misuse of proprietary information
Environment, health, and safety violations
4. Reporting Channels
To facilitate safe and accessible reporting, AHOY provides multiple channels:
Dedicated Whistleblower Hotline: Confidential telephone line managed by an external provider.
Email Reporting: Secure email address monitored by the designated compliance or HR team.
Anonymous Reporting Portal: Secure online portal enabling anonymous submissions.
In-Person Reporting: Direct communication with designated compliance officers or senior management, if preferred.
All reports will be treated with the utmost confidentiality, respecting the whistleblower’s identity and privacy.
5. Confidentiality and Anonymity
AHOY commits to protecting the identity of whistleblowers to the greatest extent possible, subject to legal and investigative requirements. Whistleblowers are encouraged to disclose their identity to enable proper investigation; however, anonymous reports are also accepted and will be seriously considered and investigated.
6. Protection Against Retaliation
No Retaliation Policy: AHOY prohibits retaliation, discrimination, harassment, or any adverse action against anyone making a good-faith report. Retaliation offenders will face disciplinary measures, including termination of employment or contractual relationship, and legal action if applicable.
Good-Faith Reporting: Whistleblowers are expected to provide honest and factual information. Malicious or unfounded reports made with malicious intent may be subject to disciplinary action.
Protection Measures: Whistleblowers will be protected from dismissal, demotion, harassment, or any adverse treatment related to their reporting.
7. Investigation Process
All reports will be recorded, reviewed, and investigated promptly and thoroughly by a designated Compliance Officer or a special investigations team.
Investigations will be conducted confidentially, maintaining fairness and due process.
The whistleblower may be interviewed as part of the investigation process, and their input will be considered.
Findings and recommendations will be documented, and appropriate corrective actions will be implemented.
8. Handling of Reports
Initial Acknowledgment: Whistleblowers will receive confirmation of receipt within a specified timeframe.
Follow-Up: Regular updates regarding the investigation status will be provided, respecting confidentiality.
Outcome: Upon conclusion, the whistleblower will be informed of any corrective measures taken, consistent with confidentiality and legal requirements.
9. Record Keeping
Initial Acknowledgment: Whistleblowers will receive confirmation of receipt within a specified timeframe.
Follow-Up: Regular updates regarding the investigation status will be provided, respecting confidentiality.
Outcome: Upon conclusion, the whistleblower will be informed of any corrective measures taken, consistent with confidentiality and legal requirements.
10. Training and Awareness
All reports, investigation records, and follow-up actions will be securely stored, access limited to authorized personnel.
Data will be retained in accordance with applicable laws and internal policies.
11. Review and Continuous Improvement
This policy will be reviewed annually to ensure effectiveness, relevance, and compliance with UAE legal requirements.
Feedback from employees and stakeholders will be incorporated to improve the reporting and protection mechanisms.
12. Legal and Regulatory Compliance
AHOY’s whistleblowing procedures are designed to align with relevant UAE laws, including Federal Law No. 7 of 2016 concerning anti-money laundering and anti-fraud measures, as well as other applicable regulations.
Disclosures made in good faith and in compliance with
AI and Advanced Algorithms for Complex Problems.
Research-driven systems powering orchestration, logistics, and critical infrastructure.
© 2025 AHOY Technologies. All rights reserved.
AI and Advanced Algorithms for Complex Problems.
Research-driven systems powering orchestration, logistics, and critical infrastructure.
© 2025 AHOY Technologies. All rights reserved.
AI and Advanced Algorithms for Complex Problems.
Research-driven systems powering orchestration, logistics, and critical infrastructure.
© 2025 AHOY Technologies. All rights reserved.