Privacy Notice
Last updated 15 September 2026
The Doha Circle deals with individuals in their professional and institutional capacities, and treats what it learns about them with discretion. This Notice explains how personal data is collected, used, disclosed, retained and protected in connection with thedohacircle.com, correspondence with the Circle, and the Circle’s institutional relationships.
1. Who we are
The Doha Circle is a private body established in Doha at the Qatar Financial Centre.
The controller of personal data is:
The Doha Circle
Lusail Twin Towers, 11th and 12th floor
Qatar Financial Centre
Doha, State of Qatar
QFC registration in progress
office@thedohacircle.com
The Circle is subject to the QFC Data Protection Regulations 2021 and the QFC Data Protection Rules 2021, administered by the Data Protection Office of the Qatar Financial Centre.
Where the law of another jurisdiction applies to a particular activity — including the EU General Data Protection Regulation and the UK General Data Protection Regulation — the Circle processes personal data in accordance with that law to the extent it applies.
Privacy matters may be raised at office@thedohacircle.com.
2. What this website collects
This website carries no contact form, no account, no registration, no newsletter sign-up and no payment function. Nothing on it asks a visitor to submit personal information.
Visiting the site therefore generates only the technical information ordinarily created when a browser requests a web page: IP address, browser and device characteristics, referring page, the pages requested, the time of the request, and an approximate location inferred from the IP address. Section 10 sets out precisely which technologies operate on the site and which third parties receive this information.
The only personal data a visitor actively provides is what they choose to put in an email to an address published on the site.
3. What we collect through our relationships
Away from the website, the Circle collects information relevant to its activities. This may include:
Identity and professional information — name, title, position, employer or organisation, professional biography, and other information concerning a person’s professional or institutional role.
Contact information — business email address, telephone number, business address and comparable details.
Correspondence and relationship information — communications with the Circle; enquiries; records of meetings, introductions and correspondence; invitations and attendance; preferences relevant to an institutional relationship; and records concerning members, prospective members, partners, counterparties and other professional contacts.
Information from third parties and public sources — professional information obtained from an individual’s organisation, an introduction or referral, an official or institutional source, professional directories, public registers, professional networks and other lawfully available sources.
Due diligence information — where a relationship or transaction makes it necessary, information obtained in the course of verification, sanctions, conflicts, anti-money-laundering, reputational or security checks, including from specialist screening providers and public records.
The Circle does not seek special categories of personal data. Where such information is exceptionally provided, or becomes necessary in a particular context, it is processed only where there is an appropriate legal basis and the safeguards required by applicable law.
4. How we use personal data
Personal data may be processed in order to:
- respond to enquiries and correspondence;
- establish, maintain and manage professional and institutional relationships;
- assess prospective relationships, partnerships, introductions and opportunities;
- administer invitations, meetings, delegations and private gatherings;
- communicate with members, prospective members, institutional partners, advisers, counterparties and other relevant contacts;
- conduct due diligence, verification, conflicts, sanctions, compliance and security checks where necessary;
- operate, protect and improve the website and the Circle’s systems;
- prevent misuse, fraud, security incidents and unlawful activity;
- maintain business and compliance records;
- establish, exercise or defend legal rights; and
- comply with applicable law, regulation, court orders and lawful requests from competent authorities.
The Circle does not sell personal data, does not trade in it, and does not use it for behavioural advertising or profiling.
5. Legal bases
Depending on the circumstances and the law that applies, the Circle processes personal data because:
- it is necessary to take steps requested by an individual, or to perform an agreement;
- it is necessary to comply with a legal or regulatory obligation;
- it is necessary for the legitimate interests of the Circle or another person, and those interests are not overridden by the individual’s rights and interests;
- the individual has given consent, where consent is required or appropriate;
- it is necessary for the establishment, exercise or defence of legal rights; or
- another lawful basis recognised by the applicable law applies.
The legitimate interests on which the Circle relies include maintaining institutional and professional relationships, responding to enquiries, assessing and conducting its business, protecting the Circle and its members, securing the integrity of its operations, and communicating with professional contacts on matters relevant to their responsibilities.
Where processing rests on consent, consent may be withdrawn at any time. Withdrawal does not affect processing already lawfully carried out.
6. Professional communications
The Circle’s communications are institutional and business-to-business.
The Circle may contact an individual in their professional capacity where there is an existing relationship, an introduction, a reasonable institutional connection, or a legitimate reason to believe the communication is relevant to their professional responsibilities. Where the applicable law requires consent before such a communication, the Circle relies on consent.
Any recipient may ask at any time not to receive further non-essential communications. The Circle will respect that request, and will retain the minimum information necessary to ensure the preference continues to be observed.
7. Who we share personal data with
Personal data may be disclosed, where reasonably necessary, to:
- professional advisers, including legal, tax, accounting and compliance advisers;
- technology, hosting, communications and administrative service providers acting on the Circle’s behalf, identified in Section 10 so far as the website is concerned;
- banks, financial institutions and professional service providers, where relevant to a particular relationship;
- appropriately authorised institutions carrying out regulated activities;
- institutional partners, counterparties and other parties, where disclosure is necessary for a legitimate matter and is lawful;
- QFC authorities, the Data Protection Office, regulators, courts, law-enforcement and governmental authorities, where disclosure is required or lawfully requested; and
- a successor organisation, in connection with a reorganisation, merger, acquisition or transfer of all or part of the Circle’s activities.
Service providers acting on the Circle’s behalf are required by contract to handle personal data only on the Circle’s instructions, for permitted purposes, and under appropriate security obligations.
Information concerning one relationship is not made available to another merely because both parties have a connection with the Circle.
8. International transfers
The Circle’s activities are international, and its website is delivered through infrastructure operated outside the State of Qatar. Personal data may therefore be accessed or processed in Qatar, the United States, the European Economic Area and other jurisdictions in which the Circle, its service providers, professional advisers or counterparties operate. Section 10 identifies the website providers and where they are established.
Where personal data is transferred out of the QFC, the Circle applies the transfer requirements of the QFC Data Protection Regulations 2021 — transfers to jurisdictions recognised as providing an adequate level of protection, or the use of appropriate contractual or other lawful safeguards.
Where the EU or UK GDPR imposes additional requirements on a transfer, the Circle relies on an adequacy decision, standard contractual clauses, or another legally recognised mechanism, together with any supplementary measures required.
9. How long we keep it
Personal data is kept only for as long as is reasonably necessary for the purpose for which it was collected, and for applicable legal, regulatory, evidentiary and legitimate business requirements. As a general approach:
| Website security and server logs | Up to 12 months |
| Aggregate website measurement statistics | Retained while the measurement service is in use; they contain no personal data and no individual can be identified from them |
| Enquiries where no relationship follows | Up to 24 months from the last contact |
| Records of an institutional, contractual or material professional relationship | For the duration of the relationship and six years afterwards |
| Due diligence, compliance and anti-money-laundering records | For the period required by the applicable regulatory regime |
| Records needed for legal, tax, dispute or evidentiary purposes | For the applicable limitation or statutory period |
| A request not to be contacted | Retained indefinitely, in minimal form, so that the request continues to be honoured |
Information may be kept for longer where litigation, an investigation, or another legal requirement makes it necessary.
10. Cookies and website technologies
The Circle measures how its website is used, but does so without cookies and without collecting personal data. There is no Google Analytics, no advertising pixel, no social-media tag, no heat-mapping and no session recording. The Circle does not profile visitors, does not identify them individually, and does not build advertising audiences from them.
The technologies that operate on the site are the following.
Audience measurement — Plausible. The Circle uses Plausible Analytics, operated by Plausible Insights OÜ and hosted on servers within the European Union. Plausible records aggregate information about visits: the pages viewed, the country of the visitor, the site or campaign that referred them, the device and browser type, the approximate time spent on a page, and how far down it they scrolled.
Plausible sets no cookies and stores nothing on the visitor’s device. It does not assign persistent identifiers, does not follow visitors between websites, and does not retain IP addresses — the IP address is used transiently to derive a country and a daily, irreversible hash, and is then discarded. The Circle cannot identify an individual visitor through it, and neither can Plausible. Because no personal data is stored and nothing is placed on the visitor’s device, no consent is required and no consent banner is presented.
Site hosting and delivery — Webflow. The website is built and hosted on the Webflow platform, operated by Webflow, Inc. (United States), with static files delivered from content delivery networks operated by Amazon Web Services. Webflow processes server-log information, including IP addresses, in order to deliver the site and keep it secure.
Network security — Cloudflare. Requests to the site pass through Cloudflare, Inc. (United States), which provides network security and abuse prevention. Cloudflare sets a cookie named _cfuvid for the purpose of distinguishing legitimate traffic from automated abuse and applying rate limits. It is used for security only. It is not used for advertising, analytics or profiling.
Typefaces — self-hosted. The typefaces used on the site are served from the Circle's own content delivery network, alongside the rest of the site's files. No request is made to any third-party font service, and no visitor information is transmitted to one. Until 15 September 2026 the typefaces were loaded from Google Fonts, which transmitted each visitor's IP address to Google LLC in the United States; they were moved in order to end that transfer.
Device storage — one functional entry. The site stores a single entry in the browser’s session storage to record that the opening title sequence has already been shown, so that it is not repeated as the visitor moves between pages. It contains no identifier, is not readable by any third party, and is discarded when the browser tab is closed.
No other cookie, tag, beacon or similar technology is used. No consent banner is presented because nothing on the site requires consent: the measurement described above is cookieless and stores nothing on the visitor’s device, and the remaining technologies are limited to what is necessary to deliver and secure the site.
A visitor may restrict or delete cookies and similar technologies through their browser settings. Doing so does not prevent access to the site.
If the technologies used on the site change materially, this Notice and any required consent controls will be updated accordingly.
11. Security
The Circle applies technical and organisational measures appropriate to the sensitivity of its work, designed to protect personal data against unauthorised access, disclosure, alteration, loss and destruction. Access is limited according to need.
No method of electronic transmission or storage is completely secure, and absolute security cannot be guaranteed. Where a personal data breach occurs and the applicable law requires it, the Circle will notify the Data Protection Office of the Qatar Financial Centre, any other competent supervisory authority, and affected individuals, within the periods that law prescribes.
12. Your rights
Subject to applicable law and any lawful exceptions, an individual may have the right to:
- be informed how their personal data is used;
- obtain confirmation that it is being processed;
- access it and obtain a copy;
- have inaccurate or incomplete information corrected;
- request its deletion;
- object to particular processing, including direct communications;
- request that processing be restricted;
- receive certain information in a portable format;
- withdraw consent, where processing rests on consent; and
- appropriate protection in relation to decisions taken solely by automated means.
The Circle does not take decisions producing legal or similarly significant effects on individuals solely by automated means.
As a matter of policy, the Circle will consider a legitimate privacy request from any individual regardless of jurisdiction, although the precise legal entitlement will depend on the law that applies.
Requests should be sent to office@thedohacircle.com. The Circle may take reasonable steps to verify identity before acting on a request, and will respond within the period required by the applicable law.
13. Complaints
The Circle asks to be contacted first about any concern regarding the handling of personal information.
An individual whose data falls within the QFC regime may also raise a complaint with the Data Protection Office of the Qatar Financial Centre. Where the EU or UK GDPR applies, an individual may lodge a complaint with the competent supervisory authority in their country of residence or work. Where another national data protection law applies, the rights and remedies provided by the relevant authority are also available.
Nothing in this Notice limits a right that cannot lawfully be limited.
14. Children
The website and the Circle’s activities are directed to professional and institutional audiences and are not intended for children. The Circle does not knowingly collect personal data from children through this website.
15. External websites
The website may link to websites operated by other organisations. The Circle does not control them and is not responsible for their privacy practices. Their own notices apply.
16. Changes
This Notice may be updated to reflect changes in the Circle’s activities, in the technology used, or in the law. The current version is published on this website and identified by the date of its last update.
17. Contact
The Doha Circle
Lusail Twin Towers, 11th and 12th floor
Qatar Financial Centre
Doha, State of Qatar
office@thedohacircle.com