Privacy Policy
Effective Date: April 13, 2026
1. Introduction
Central Asia Warehouse Private Equity Fund ("the Fund," "we," "us," or "our") is an open-ended investment company registered with the Astana International Financial Centre (AIFC). We are committed to protecting the privacy and personal data of all visitors to our website at https://caw.fund ("the Website").
This Privacy Policy explains how we collect, use, store, and protect your personal information in accordance with the AIFC Data Protection Regulations 2021 and other applicable laws.
2. Information We Collect
We may collect the following categories of personal data:
- Identity data -- full name, title, and nationality
- Contact data -- email address, phone number, and mailing address
- Technical data -- IP address, browser type, device identifiers, and cookies
- Usage data -- pages visited, time spent on the Website, and referring URLs
- Correspondence data -- messages or inquiries submitted through contact forms
- Investor data -- accreditation status and eligibility information, where applicable
3. How We Collect Your Data
We collect personal data through the following means:
- Direct interactions (contact forms, email correspondence, subscription requests)
- Automated technologies (cookies, log files, web beacons)
- Third-party sources (publicly available registries, professional networks, business partners)
4. How We Use Your Data
We process your personal data for the following purposes:
- Responding to your inquiries and communications
- Providing access to restricted investor sections of the Website
- Sending Fund updates, newsletters, and relevant communications (with your consent)
- Complying with legal and regulatory obligations under AIFC rules
- Improving Website performance, security, and user experience
- Preventing fraud and unauthorized access
5. Legal Basis for Processing
We process your personal data on the following legal grounds:
- Consent -- where you have explicitly opted in to communications
- Legitimate interests -- for website analytics and security
- Legal obligation -- to comply with AIFC and applicable regulatory requirements
- Contractual necessity -- where data processing is required to fulfill an agreement with you
6. Cookies
The Website uses cookies to enhance your browsing experience and collect analytical data. You may control cookie settings through your browser at any time. Disabling cookies may affect the functionality of certain Website features. A detailed Cookie Policy is available on the Website.
7. Data Sharing and Disclosure
We do not sell or rent your personal data to third parties. We may share your data with:
- Service providers acting on our behalf (IT, hosting, analytics, legal, compliance)
- Regulatory authorities including the AIFC Financial Services Regulation Bureau, where required by law
- Professional advisors such as lawyers, auditors, and consultants bound by confidentiality obligations
All third-party processors are contractually required to handle your data securely and in compliance with applicable data protection laws.
8. International Data Transfers
As an AIFC-registered entity, the Fund may transfer personal data across borders where necessary. Any such transfers are conducted in accordance with AIFC Data Protection Regulations and appropriate safeguards, such as standard contractual clauses.
9. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes outlined in this Policy, or as required by applicable law and AIFC regulations. Once data is no longer required, it is securely deleted or anonymized.
10. Your Rights
Under applicable AIFC data protection rules, you have the right to:
- Access the personal data we hold about you
- Correct inaccurate or incomplete data
- Request erasure of your data (subject to legal obligations)
- Restrict or object to certain processing activities
- Withdraw consent at any time, without affecting prior processing
- Lodge a complaint with the AIFC Commissioner for Data Protection
To exercise any of these rights, please contact us at the details provided in Section 13.
11. Data Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration. However, no method of transmission over the internet is entirely secure, and we cannot guarantee absolute security.
12. Children's Privacy
This Website is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us and we will promptly delete it.
13. Contact and Complaints
For questions, requests, or complaints regarding this Privacy Policy, please contact us at contact@caw.fund.
14. Updates to This Policy
We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. The revised Policy will be posted on this page with an updated effective date. We encourage you to review this page regularly.
Last updated: April 13, 2026