Investors Club

Privacy Policy

This policy explains how V-Community, the official operator of Investors Club, collects, uses, stores, and protects your personal data, who it's shared with, how long it's retained, and what rights you have over it and how to exercise them, in accordance with the Personal Data Protection Law of the Kingdom of Saudi Arabia and its regulations.

Last updated: September 2026 18 clauses 15-minute read Under the Personal Data Protection Law
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1

Who We Are & This Policy's Scope

V-Community is the official operator of Investors Club and one of the companies within the Vibes Holding ecosystem. It is the controller of the personal data collected through the Club's website and the services covered by this policy, and determines the purpose and manner of its processing.

Investors Club V-Community Commercial Registration 2050179051

This policy applies to the vcmem.com website, Investors Club membership, verification via Absher, the Club's official WhatsApp numbers, in-person and virtual gatherings and events, the Club's headquarters and its facilities, the "Profile & Journey" initiative, the Vibes Holding ecosystem's unified account and its AI assistant whose data is managed through the Club's website, and any related correspondence. The other ecosystem companies' websites, on the other hand, are governed by their own privacy policies.

Address: Al-Jawhara Commercial Tower, Prince Mohammed bin Abdulaziz Road (Tahlia), Al Olaya District, Riyadh 12331 To contact us about your data: info@vcmem.com

The collection and processing of your data is governed by the Personal Data Protection Law issued by Royal Decree No. (M/19) dated 9/2/1443H, as amended by Royal Decree No. (M/148) dated 5/9/1444H, its implementing regulation, and the Regulation on Transferring Personal Data Outside the Kingdom. This policy should be read alongside the Terms and Conditions for Club membership.

2

Personal Data We Collect

We collect the minimum data necessary to achieve specific, clear purposes, and the data varies depending on the service you use:

Identity and contact data: first and last name, mobile number and WhatsApp number, email address, and country and city.
Absher verification data: the mobile number registered with Absher, the national ID or residency number used solely to complete the phone-number match, and the verification result.
Account and profile data: your password and verification codes, the category you choose (neutral, entrepreneur, or investor), your bio and description of your activity, anything you optionally add such as your LinkedIn profile link, your website or company website, a job title, or a profile photo, and a referral or promo code if any.
Membership and payment data: your membership type, status, and term, the payment link or approved representative you subscribed through, transaction amounts, dates, and references, and payment gateway notifications — we never see or store your full card details.
Investment-interest data: whatever you choose to disclose about your financial standing or capacity and your investment direction, and the ventures you present to members.
The content of your communications with us: your conversations with the AI assistant and with the Club's official WhatsApp numbers, voice messages and their transcripts, photos, screenshots and payment receipts, and messages from contact forms and consultation or meeting requests and their subjects.
Data about your experience with the AI assistant: summaries of your conversation context, your direction and interests as they appear in your communications, and the pages and services you interact with across the ecosystem's sites, all of which we store to improve your experience as explained in clause (7).
Gatherings and HQ data: registration for gatherings and events, bookings to visit the HQ, the Stage, and the meeting room, entry QR codes and attendance records, and photos and video/audio recordings of gatherings.
Technical data: your Internet Protocol (IP) address, device and browser type, the pages you visit and the site you came from, and cookie identifiers.
We don't ask for sensitive data or copies of ID documentsWe don't ask you for sensitive data, such as health, genetic, security, or criminal data, or anything related to belief or ethnic origin, and we ask that you not share such data in conversations or your bio. We also don't ask for photos or copies of official ID documents unless required by law or requested by a competent public authority.

The mandatory fields are marked on every form, and not providing them prevents account creation, verification, membership activation, or delivery of the requested service. Leaving optional fields blank, on the other hand, does not affect your ability to receive the service.

3

How We Collect Data

We obtain your data only through the following methods:

Directly from you: when you register or subscribe, fill out verification, gathering, or "Profile & Journey" forms and consultation, meeting, or contact requests, talk to the AI assistant or message us on WhatsApp, or attend gatherings.
Automatically: through cookies and server logs as you browse the site, and through what the AI assistant extracts from your conversations to save their context.
From the Absher system: the result of verifying your mobile number when you request it.
From the payment gateway: notifications of successful subscription transactions and their references, to activate your membership.
From companies in the Vibes Holding ecosystem: when you use their services linked to your unified account, or when your request is referred to us.
From our advertising campaigns: when you fill out an interest form in our ads on social media platforms.

In cases other than when you provide your data yourself, we limit ourselves to what is necessary for the specific purpose, and inform you as this policy provides.

4

Processing Purposes & Their Legal Bases

We process your data for the following purposes, each with a specific legal basis, and we will not later process it in a way that conflicts with the purpose for which it was collected:

Creating and managing your account, and verifying your email address with a code.Legal basis: performance of the agreement concluded with you
Verifying your mobile number via Absher before activating your membership or entering into any dealing.Legal basis: your consent, and the legitimate interest in preventing unidentified numbers and fake accounts
Activating membership and processing payments, linking the subscription to the referral link used, and sending its notifications.Legal basis: performance of the agreement concluded with you, and under zakat and tax regulations
Organizing gatherings and HQ and facility bookings, and issuing entry QR codes.Legal basis: performance of the agreement concluded with you
Broadcasting gatherings online and publishing their photos and clips on the Club's platforms.Legal basis: your consent
Selecting the profiles for the "Profile & Journey" initiative and publishing them.Legal basis: your consent when registering for the initiative
Publishing members' ventures across the Club's channels and facilitating introductions between members.Legal basis: performance of the agreement concluded with you, and your consent to what you publish
Responding to your inquiries and consultation and meeting requests through the AI assistant and the administration team.Legal basis: your consent, and performance of the agreement concluded with members
Storing the context of your communications and your preferences so the AI assistant recognizes you across every ecosystem site, suggests what suits your direction, and so we can improve the accuracy of its replies and develop it.Legal basis: performance of the agreement concluded with you, and the legitimate interest in improving your experience and service quality
Sending offers and marketing or awareness messages.Legal basis: your consent
Protecting the website and the Club's platforms, information security, detecting fraud, and preventing misuse.Legal basis: legitimate interest
Improving services, measuring their usage, and prioritizing follow-up.Legal basis: legitimate interest
Complying with regulations, responding to requests from competent authorities, and preserving legal rights.Legal basis: under applicable regulations, and legitimate interest

Wherever your consent is the legal basis, you may withdraw it at any time through the contact channels listed in clause (15). This does not affect the lawfulness of processing carried out before your withdrawal, nor processing based on another legal basis.

5

Verification via Absher

V-Community relies on the Absher system to verify the mobile numbers of Club members and those who deal with it, and also handles verification as the company accredited by Vibes Holding to verify its partners, in order to keep the community free of unidentified numbers and fake profiles.

What we ask for: the mobile number registered with Absher, and the national ID or residency number solely to complete the number match.
How it works: a verification code is sent to your phone to confirm the process.
Limits of use: we do not use the ID or residency number for any purpose other than verification and confirming its result.
The number alone is enough to verifyVerification is limited to entering the ID or residency number, without photographing or copying the document, and is carried out at your request when you submit the verification form; the number is never shown to Club members or anyone else.
6

The Member Community & What They See

Investors Club is a closed, governed community, made up of subscribed members after their numbers have been verified.

Your profile data and the ventures you add may appear to registered Club members within the member-only areas of the site, and the profiles selected for the "Profile & Journey" initiative are published along with the contact method their owners approve.

Member data is not for commercial useNo member may collect other members' numbers or data from the site or the Club's platforms to send marketing messages, or add them to lists or groups without their consent; processing personal data for professional or commercial purposes is not considered personal use, and is subject to the Personal Data Protection Law. The Club has the right to take whatever action is necessary against any violation.

What you publish to members, such as your ventures and bio, remains visible to them for as long as it stays published, and we have no control over what members may retain of what they have viewed. We therefore recommend not publishing any data you don't want others to see.

7

The AI Assistant & Saving Your Experience Data

The AI assistant on the Club's website and the ecosystem's sites — and possibly the Club's official WhatsApp numbers — relies on AI models provided by external vendors, used to understand your messages and reply to them, transcribe voice messages to text, and read the photos and screenshots you send. A member of the administration team may also respond to you directly.

We deliberately store your data with the AI assistant, so it recognizes you on every visit, picks up where you left off, and gives you a smarter, more accurate experience the more you interact with it.

What the Assistant Keeps About You.. and WhyEvery stored data point is tied to a clear purpose that serves your experience
A log of your conversations, their attachments, and a summary of their contextSo you can pick up where you left off on any ecosystem site without repeating your request
Your unified account data, category, bio, and membership statusSo it recognizes you the moment you sign in, and addresses you in a way that suits your category and membership
Your direction and interests as they appear in your communicationsSo it can suggest the ventures, gatherings, and services closest to your direction
The pages and services you interact with across the ecosystem's sitesSo it can answer about the page you're on, and point you to the right link
An automated estimate of your level of interest in our servicesSolely to prioritize the administration team's follow-up
Patterns in recurring questions and requestsTo continuously improve the accuracy of the assistant's replies and develop it for every user

This data is stored linked to your account, mobile number, or browser identifier, and is accessed by authorized administration staff to the extent necessary to serve you. We send AI providers only what is needed to generate the reply.

No fully automated decisions affecting your rightsWe do not make decisions affecting your rights or interests based solely on automated processing; the decision on follow-up always remains with the administration team. We do not use your voice or image to identify you by biometric traits. The assistant's replies may contain errors, and are not financial or legal advice or an investment recommendation.

You may at any time request to see, correct, or delete what the assistant stores about you through the contact channels listed in clause (15), and you can update your profile data directly from the "My Account" page. Deletion means the assistant starts fresh with you, with no knowledge of your previous communications.

8

Sharing & Disclosing Data

We do not disclose your data except in cases permitted by law and to the minimum extent necessary, and we do not share it with any party for its own marketing purposes without your consent. We may disclose it to:

Vibes Holding and its ecosystem companies: to the extent necessary to operate the unified account, deliver ecosystem services and member discounts, the Projects Bank and the Success Partners program, and verify Vibes Holding's partners.
Service providers acting as processors: such as hosting, email, the payment gateway, AI models, WhatsApp and messaging services, meeting and video-broadcast platforms, and process automation, under contractual terms that bind them to protect the data.
The Absher system: your mobile number and ID or residency number to complete verification, when you request it.
Club members and the public: as explained in clause (6), and when gathering clips or "Profile & Journey" profiles are published on the Club's social media accounts with your consent.
The Club's approved representatives: if you subscribed through one of their links, to the extent necessary to record the referral and follow up on your subscription.
Public and judicial authorities: whenever a competent public authority requests this for reasons of public interest, security purposes, to implement another law, or to satisfy judicial requirements.

We are committed to choosing processors that provide the necessary safeguards to protect data, and we verify their compliance; this remains without prejudice to our responsibility toward you.

9

Transferring & Processing Data Outside the Kingdom

Some of your data may be stored or processed outside the Kingdom with service providers we use, such as AI, hosting, email, messaging, and video-meeting services.

Transfers are governed by the LawNo transfer takes place except in accordance with Article (29) of the Law and the Regulation on Transferring Personal Data Outside the Kingdom, and in a manner that does not prejudice national security or the Kingdom's vital interests, limited to the minimum data necessary, and through one of the bases or safeguards the Regulation recognizes — such as transferring to a country with an adequate level of data protection, under standard contractual clauses, or when the transfer is necessary to conclude or perform an agreement to which you are a party.
10

Cookies & Third-Party Content

We use cookies and similar technologies to operate and improve the Club's website. They fall into:

Necessary: for signing in, the "Remember me" option, maintaining the session, and account security — the site does not function properly without them.
Functional: to save your browsing language, recognize your unified account, and hold the AI assistant identifier it uses to recognize you and preserve your conversation context as you move between ecosystem sites.
Performance measurement: to understand overall site usage and improve it, whenever such tools are used.
Third-party content: such as embedded YouTube videos, Google Maps, and web fonts from Google — these parties may collect technical data such as your IP address under their own policies.

You can control or delete cookies from your browser settings, keeping in mind that disabling the necessary ones may prevent signing in or the AI assistant from working, and deleting the functional ones may mean the assistant won't recognize you before you sign in.

The site includes links to the Club's social media accounts, to WhatsApp, to the payment gateway's pages, and to the ecosystem companies' websites. This policy does not apply to their practices, so please review their own privacy policies.

11

Marketing & Awareness Messages

We do not use your mobile number, email address, or any other personal contact method to send promotional, marketing, or awareness material except with your consent, and these messages abide by the following:

Sent only after your consent Clearly show the sender's name Can be stopped at any time We stop as soon as you ask Stopping costs nothing

To stop marketing messages, email us or message the administration's WhatsApp listed in clause (15), or ask the AI assistant or the WhatsApp chat to do it. Operational messages related to your account, however — such as verification codes, payment notifications, membership activation, gathering reminders, and security alerts — are not marketing messages, and continue for as long as your account or service is active.

12

Storing & Protecting Data

Your data is stored electronically within secure databases and servers held by the company or by the hosting providers we contract with, and we take the organizational, administrative, and technical measures necessary to protect it, including:

Encrypting the connection between your browser and the site via the HTTPS protocol.
Limiting access rights to authorized personnel, and only to the extent necessary to perform their duties.
Verifying mobile numbers via Absher with a code sent to your phone, and verifying email addresses with a code when creating the unified account.
Processing payments through an electronic payment gateway, without storing card details on our end.
Requiring everyone who processes data to maintain its confidentiality, even after their relationship with us ends.
Applying the National Cybersecurity Authority's controls whenever they apply to us, or recognized best practices.
Notification in the event of a breachIf a personal data breach occurs that could harm you, your rights, or your interests, we notify the competent authority within no more than (72) hours of becoming aware of it, and notify you without unjustified delay, in clear language, stating the potential risks, the measures taken, and recommendations to help you limit their effects.

No method of transmission or storage is completely secure, so please keep your password confidential and never share verification codes with anyone, including anyone claiming to represent the Club.

13

Data Retention Period & Destruction

We retain your data to the extent and for the period necessary to achieve the purpose for which it was collected, then destroy it or convert it to a form that no longer identifies you, unless the law requires a longer retention period:

Account and profile data: for as long as your account is active, and destroyed upon your request to delete the account, unless there is a legal basis to retain it.
Membership and payment data: for the membership term, then for the period required by zakat, tax, and commercial regulations for record-keeping.
The Absher verification result: for as long as your account is active, to prove your number has been verified.
Conversations, their summaries and attachments, and the personalization data the AI assistant stores: for as long as your account is active or as long as they remain necessary to serve you and improve your experience; you may request their deletion at any time.
Gathering photos and recordings: for as long as they remain published on the Club's platforms, and you may request removal of anything specific to you under clause (14).
Technical data and security logs: for the period necessary to protect the site and detect misuse.

Data may be retained beyond the end of its purpose when necessary for a case pending before a judicial authority, to establish a legal right, or when a law requires it. Destruction does not extend to what members may retain of what they viewed while it was published.

14

Your Rights Over Your Personal Data

The Personal Data Protection Law guarantees you the following rights:

The right to be informed: of the legal basis and purpose for collecting and processing your data, which this policy explains.
The right to access: your data held by us, including what the AI assistant stores about you, and to receive a copy of it in a clear format.
The right to request correction: of your inaccurate or incomplete data, or to have it updated.
The right to request destruction: of your data that is no longer needed, without prejudice to what the law requires us to retain.
The right to withdraw consent: at any time, whenever consent is the legal basis for processing.
The effect of exercising certain rightsRequesting the destruction of certain data, or withdrawing consent, may make it impossible to provide certain services, such as activating membership or having the AI assistant remember the context of your communications. We will explain this to you before carrying out the request.
15

Exercising Your Rights & Filing Complaints

To exercise any of your rights, withdraw your consent, or ask about how your data is processed, contact us through one of the two channels below. We may ask you for what's needed to verify your identity before carrying out the request, to protect your data:

Email: info@vcmem.com Administration WhatsApp: 0558318777
30 days is the maximum period to respond to your request from the date it's received, extendable by an equal period if the nature of the request requires it, with notice of the extension and its reasons.At no financial cost, unless the request is repeated unreasonably

If you believe the processing of your data violates the Law, you may file a complaint with the Saudi Data & AI Authority (SDAIA) within (90) days of the incident or your becoming aware of it. We welcome you to contact us first so we can address your concern directly.

16

Data of Minors & the Legally Incapacitated

Investors Club's services and membership are directed at those with full legal capacity. We do not knowingly collect data from anyone under eighteen, or from those with limited or no legal capacity, except with their legal guardian's consent and in a manner that serves their interest.

If we learn that a minor's data was collected without their guardian's consent, we destroy it without delay, and their guardian may contact us through the channels listed in clause (15).

17

Updating This Policy

We may update this policy from time to time to reflect changes in our services or related laws, and we display the date of the last update at the top of the page. If an update is material and affects how your data is processed, we notify you through the website or the contact methods we have on file before it takes effect, and we ask for your consent again whenever consent is the legal basis.

Last updated: September 2026
Clause 18 — Contact About Your Privacy

Your Data Is a Trust.. and We Keep It to Serve You Better

We store your data with the AI assistant so your experience with us is faster, more accurate, and closer to what you need — and the final word on it always stays with you: view it, correct it, or ask us to delete it whenever you want.

For any inquiry or request about your data, email us at info@vcmem.com or contact the administration's WhatsApp at 0558318777.

Email Us About Your Data Administration WhatsApp

V-Community — Commercial Registration 2050179051 — Al-Jawhara Commercial Tower, Prince Mohammed bin Abdulaziz Road (Tahlia), Al Olaya District, Riyadh 12331