1. Introduction
Ambersoft FZE LLC (“we,” “us,” or “our”), operating the 17VLT Fund platform (“Platform”) at 17vlt.com, is committed to protecting the personal data of founders, applicants, and users (“you”) who interact with our services. This Privacy Policy explains how we collect, use, store, and share your personal information in accordance with UAE Federal Decree-Law No. 45/2021 on the Protection of Personal Data (PDPL) and, where applicable, the EU General Data Protection Regulation (GDPR).
By accessing or using our Platform, you consent to the data practices described in this Policy. If you do not agree, please discontinue use of our services.
2. Information We Collect
2.1 Information You Provide Directly
We collect information you voluntarily submit when you:
- Apply to the Platform (name, email, nationality, country of residence, business description, app or product details)
- Create an account or complete onboarding forms
- Submit KYC documentation (passport, proof of address, source of funds — at applicable tiers)
- Execute agreements with us (Master Cooperation Agreement, IP Assignment Deed)
- Communicate with our team via email, messaging tools, or video calls
2.2 Information Collected Automatically
When you visit our Platform, we may automatically collect:
- IP address, browser type, and device identifiers
- Pages visited, time spent, and navigation paths
- Cookies and similar tracking technologies (see Section 8)
- Referral URLs and geographic location (country/city level)
2.3 Information from Third Parties
We may receive information about you from:
- App stores (Apple App Store, Google Play) in connection with publisher account transfers
- Payment processors (Stripe) in connection with revenue distributions
- KYC and identity verification providers
- Sanctions and PEP screening providers
3. How We Use Your Information
We process your personal data for the following purposes:
- Evaluating and processing your application to the Platform
- Administering your participation and Tier progression
- Processing revenue distributions and payments under the Master Cooperation Agreement
- Facilitating publisher account transfers and IP assignment registration
- Conducting KYC, AML, and sanctions compliance checks
- Communicating platform updates, milestone reviews, and opportunities
- Improving our Platform and services
- Sending marketing communications (only with your consent)
- Complying with legal obligations under UAE and applicable international law
4. Legal Basis for Processing
We process your data on the following legal bases:
- Contractual necessity — to fulfil obligations under the Master Cooperation Agreement and related agreements
- Legal obligation — KYC/AML compliance under UAE Federal Decree-Law No. 20/2018
- Legitimate interests — platform operations, fraud prevention, and network development
- Consent — for marketing communications and non-essential cookies
5. AI-Assisted Processing
Our Platform uses artificial intelligence tools (including large language model APIs) to assist with founder application assessment, document analysis, and workflow automation. AI-assisted assessments are reviewed by human personnel before any final decision is made that materially affects a Founder.
You have the right to request human review of any AI-assisted decision affecting you. To exercise this right, contact us at privacy@17vlt.com. We will respond within thirty (30) days. For further information on our AI compliance approach, see our AI Act Conformity Statement at 17vlt.com/ai-policy.
6. Data Sharing and Disclosure
6.1 Service Providers
We engage third-party vendors who process data on our behalf under Data Processing Agreements. These include: cloud hosting providers, payment processors (Stripe), scheduling tools (Calendly), analytics providers (Google Analytics), KYC/identity verification providers, sanctions screening providers, and AI API providers (Anthropic, OpenAI). Each vendor processes data only as necessary to deliver the relevant service.
6.2 Regulatory Disclosure
We may disclose your data when required by UAE law, court order, or regulatory authority (including UAE FIU for AML purposes), or when necessary to protect our legal rights or prevent fraud.
6.3 App Store Platforms
In connection with publisher account transfers, certain business information (app name, category, and associated identifiers) is shared with Apple and Google in accordance with their developer programme terms.
6.4 No Sale of Data
We do not sell, rent, or trade your personal data to third parties for marketing purposes.
7. International Data Transfers
Your data may be transferred to and processed in countries outside the UAE in connection with the services of our third-party processors (including Anthropic, OpenAI, Stripe, and Google). When we transfer data internationally, we ensure appropriate safeguards are in place, including:
- Data Processing Agreements with each processor incorporating standard contractual clauses (SCCs) where required under GDPR
- Adequacy decisions or equivalent protections under UAE PDPL
- Contractual obligations on processors to maintain confidentiality and implement appropriate technical and organisational security measures
You may request details of the specific safeguards applicable to any transfer by contacting privacy@17vlt.com.
8. Data Retention
We retain your personal data as follows:
- Application data (Tier 1–2): 3 years from last activity
- Active founder data (Tier 3+): Duration of relationship plus 5 years
- KYC and AML records: 7 years per UAE Federal Decree-Law No. 20/2018
- Financial and legal records (MCA, IP assignments): 7 years
- Marketing data: Until you withdraw consent
You may request deletion of your data at any time, subject to our legal retention obligations.
9. Cookies and Tracking
Our Platform uses cookies and similar technologies. We use:
- Essential cookies — required for basic Platform functionality; no consent required
- Analytics cookies (Google Analytics) — require prior consent for EU users and are not activated until consent is given
- Payment processing cookies (Stripe) — required where payment services are used
- Scheduling cookies (Calendly) — require prior consent for EU users
You can manage cookie preferences via our cookie consent tool or at 17vlt.com/cookies. Withdrawing consent for non-essential cookies does not affect your ability to use the Platform.
10. Your Rights
Under UAE PDPL and applicable GDPR provisions (where applicable), you have the right to:
- Access your personal data
- Correct inaccurate data
- Request erasure (subject to legal retention obligations)
- Restrict processing
- Receive your data in portable format
- Object to processing based on legitimate interests
- Withdraw consent at any time (without affecting the lawfulness of prior processing)
- Request human review of any AI-assisted decision affecting you
To exercise any of these rights, contact us at privacy@17vlt.com. We will respond within thirty (30) days.
11. Data Security
We implement appropriate technical and organisational measures including: encryption of data in transit and at rest; access controls and role-based permissions; regular security assessments; and secure vendor agreements. In the event of a personal data breach, we will notify you and relevant authorities as required by UAE PDPL and, where applicable, GDPR Article 33.
12. Children’s Privacy
Our Platform is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have collected personal data from a minor, we will delete it promptly.
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by email or by posting a notice on our Platform at least fourteen (14) days before the changes take effect. Your continued use of the Platform after such notification constitutes acceptance of the updated Policy.
14. Contact
17VLT Fund — Ambersoft FZE LLC
BLA-SP1-39, AMC Boulevard-A Building, Ajman Media City, UAE
General enquiries: legal@17vlt.com
Data protection: privacy@17vlt.com
Website: 17vlt.com
17VLT Fund — Ambersoft FZE LLC · Privacy Policy · June 3, 2026 · 17vlt.com