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Privacy Notice
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Page Content This Privacy Notice
was last updated on 30 September 2020.
The purpose of this Privacy Notice is to explain how Bank ABC Singapore (“Bank ABC”, “we”, “us” and “our”) and the other members of the Bank ABC Group may process your personal data.
The “Bank ABC Group” includes Arab Banking Corporation (B.S.C.) and any entities wholly or partially owned by it. For more information about the Bank ABC Group, including who is a member of it, you may visit www.bank-abc.com or contact your Relationship Manager. |
A data controller determines the purposes and means of the processing of your personal data.
Your data controller is Bank ABC Singapore, 9 Raffles Place, #40-01, Republic Plaza, Singapore 048619, with which you have entered into a banking relationship, or with which you operate an account, including through the use of our digital platform.
You can find more details on how to contact us at the end of this Privacy Notice. |
For the purposes of this Privacy Notice "personal data" is information:
- that identifies or can be used to identify you;
- that relates to, describes, is reasonably capable of being associated with; or
- could reasonably be linked (directly or indirectly) with you;
- that can be used to authenticate you or provide access to an account
Where the customer of Bank ABC is a natural person, any reference to the “customer” and “you” will mean such natural person.
The term “you” also refers to any individual whose personal data is provided to us by the customer, or anyone acting on their behalf (a “connected person”).
Where the customer of Bank ABC is a business customer, (i.e. they are organised as a legal entity) any reference to “you” will mean any connected person and a reference to the “customer” will mean the business customer of Bank ABC.
Personal data we collect as a result of transactions with a business customer is usually limited to details on owners (direct, indirect and beneficial), officers, authorised persons, and personal guarantors.
If you are a senior manager, authorised signatory or beneficial owner of a business customer of Bank ABC, or if you are a personal customer of Bank ABC, you must ensure that every connected person receives a copy of this Privacy Notice before their personal data is shared with Bank ABC.
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We will use your personal data where we have your consent or
when we have another lawful reason such as: - Need to
process the data to enter into or carry out an agreement we have with you;
- Need to
pursue our own legitimate interests;
- Need to
process the data to comply with a legal obligation (e.g. compliance with our
regulatory obligations under any applicable regimes including without
limitation sanctions due diligence checks, or to comply with tax regulations
that require us to report the tax status of our customers);
- Need to
establish, exercise or defend our legal rights or those of a member of Bank ABC
Group or a third party employed by us;
- When we believe
the use of your data as described is in the public interest.
Specific reasons or purposes for which we may use
your personal data include:
- To set up,
maintain, fulfil and administer the contractual relationship that we have with you.
- To provide
you with products and services and to process the data to enter into or
carry out an agreement we have with you;
- To enable
you manage your account and transact with us;
- To make
credit assessments and checks;
- To collect
debt (which may involve passing your personal data to debt collection agencies.)
- To assess
the suitably of our products and services for your needs;
- To keep
records of your instructions, transactions and communications for any further
required evidence, and to prevent or detect financial crime or suspected financial
crime, including (but not limited to) fraud, money laundering and financing of
terrorism;
- To test
the performance of our products, services, and internal processes;
- To
administer our internal operational requirements (including credit, compliance,
and risk management, market research, system and product development, staff
training, quality control, accounting, and for audit purposes);
- To keep
records of activities effected on our digital platforms, websites or mobile
applications, such as your connection’s timestamp and duration;
- To process
requests relating to the exercise of your rights under data protection laws;
- To develop
statistics and for market research, surveys and analysis including to develop
and improve our products and services so that we can offer new and enhanced
products and services to you, which may include converting your personal data
into statistical or aggregated data which cannot be used to identify you.
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The personal data we collect includes data
provided by you when at the start of our relationship, or at any time
thereafter such as: - Personal data including full name (previous
names), nationality, gender (previous genders), date of birth, country of
birth, social status, names of relatives, employment status, photos (including
selfies), signature;
- Data about your identity including Identity
documents, biometric data, Identity Card number and details , details of
passports, national social security or insurance number, driving license number;
- Contact details including residential address,
email addresses, telephone numbers, proof of address document;
- Employer, employment status, Job title, full
name, email, address and telephone number(s) used for work purposes;
- Financial data: income and source of income,
source of wealth, average account financial activity, and engagement data;
- Data about your tax status including a tax
identification number, FATCA forms, etc;
- Other data provided by you via completing
forms and other means including e-mail, electronic messages, recorded calls, live
chat, chatbots and face-to-face contact.
- The personal data that we collect or
generate during our business activities includes:
- Details of transactions done by you or by any
of your connected persons. Details include dates, amounts, currencies, payer
and payee details;
- Data about your relationship with us, the
channels you use and your ways of interacting with us, the technology you use
for this and your language preferences;
- Data about your ability to get and manage your
credit;
- Data concerning complaints and disputes or
about the instances where you have exercised your legal rights related to the
protection of your personal data;
- Market research data, e.g. Opinions expressed
by you when participating to our market research campaigns or surveys;
- Risk rating information, e.g. credit risk
rating, transactional behaviour and underwriting information;
- Due diligence data, e.g. data required to
comply with financial crime regulations (anti-money laundering, anti-terrorism
financing etc.);
- Data used to identify you such as usernames,
PIN codes, passwords, signatures and biometric information (e.g. fingerprint,
iris scan, voice, face recognition) or a physical token (e.g. a debit, credit or
prepaid card, a Security Token or
electronic key) that are required when using our products or services.
- Email
address(es) and telephone number(s) used to receive digital alerts (meaning an
alert by SMS or email which we send to inform our customers on certain types of
transactions or to provide financial information);
- Information
about your device or the software you use, e.g. its IP address, technical
specification and uniquely identifying data;
- Data about your geographic location and ATMs
branches you use;
- Data that we need to support our regulatory
obligations, e.g. information about transaction details, detection of any
suspicious and unusual activity and data about parties connected to you for
these activities;
- We may record calls, email, text messages,
social media messages and other communications between you and employees of
Bank ABC;
- Closed-circuit television (“CCTV”) videos,
with or without audio recording, used in and around our premises and ATM
locations for the purpose of physical security and crime prevention - therefore we may have images of you captured
by our CCTV cameras;
- Online Identifiers that may leave traces
which, when combined with unique identifiers and other data received by
servers, may be used to identify the user. Online Identifiers may include
internet protocol addresses (IP addresses) and cookie identifiers (although we
do not usually use cookies to track individual users or to identify them).
For more details about cookies, see our online Cookie Policy;
Data relating specifically to
transactions carried out on our digital platform by users. Whilst our
banking relationship is with our customer, we will be collecting data specific
to transactions carried out by users. For example, we will be able to
inform our customer of details (such as dates, amounts, currencies, payer and
payee details) about transactions made on our digital platform and which user
initiated the transactions. Some of this may be personal data about the user. |
We collect your personal data from a
number of sources, including: - Data provided by you when we set up,
administer and manage our relationship with you.
- Data we otherwise receive directly from you or
from a person acting on your behalf;
- Data we obtain from third parties such as brokers,
credit reference, debt recovery, fraud prevention or government agencies;
- Data that we gather from publicly available
sources such as the Internet and companies’ registries or other local trade
registers;
- Data that we learn through your use of our
services and products such as when you use our digital platforms or mobile
applications, when you visit our websites or when you interact with us through
a recorded channel (e.g. a recorded telephone line, a chatbot etc.);
- Data that we identify through our fraud
prevention controls;
- Data provided by other members of the Bank ABC
Group;
- Data we receive directly by your engagement
with our social media platforms.
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| Bank ABC may record and keep track of
your conversations with it, including phone calls, face-to face meetings,
letters, emails, live chats, video chats and any other kinds of communication. These recordings will be used to check
your instructions to us, assess, analyse and improve the quality of our
services, train our people, manage risk or to prevent and detect fraud and
other crimes.
Bank ABC may also capture additional data
about these interactions, e.g. telephone numbers that you call us from and data
about the devices or software that are used. |
| We may perform credit and identity
checks with one or more credit reference agencies (“CRAs”) when you apply for a
loan (including overdraft facility, credit card limit, personal loan, mortgage,
car loan, etc.) or when we review such loans. To do this, we have to share your personal
data with the CRAs including details about the credit application, your
financial situation and financial history. We will also inform the CRAs about your
repayment history.
We may use data received from the CRAs
to:
- assess if we can offer you credit and whether
you can afford to take the product you applied for;
- verify the accuracy of the data you have
provided to us;
- prevent criminal activity, fraud and money
laundering;
- manage your account(s);
- trace and recover debts, and
- ensure any offers provided to you are
appropriate to your circumstances.
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| We may use your data to inform you
about products and services offered by Bank ABC or other entities of the Bank
ABC Group. You can, at any time, withdraw your
consent for this marketing purpose. For more information, see ‘Your right to
data protection’ section of this Notice.
Please note that Bank ABC will
continue to use your contact details to provide you with important information,
such as changes to our Terms & Conditions or when we have legitimate
reasons to do so, including compliance with our regulatory obligations.
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| We are unable to enter into or
administer the relationship with you without some of your personal data. In cases where providing your personal
data is optional, we will make this clear, for instance by explaining in
application forms if certain data fields can be left blank. In
particular, it is not mandatory that you sign up for or transact on digital
platforms operated by us. If we are seeking a consent to justify our
processing of your personal information, we shall make this clear to you. |
| You are responsible for ensuring that
the data that you provide is accurate. If any of the personal data you have
given to us should change, such as your contact details, please inform us
without delay.
Similarly, if we have collected personal
data about you that you consider to be inaccurate, please inform us.
Kindly refer to the section on “how to
contact us” below for information on how Bank ABC can be reached for updating
your information.
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| Bank ABC may share your personal data with
other parties where you have provided your explicit consent to do that.
For example, you may have instructed us to send your bank statements to your
accountant. Bank ABC may share your data with
others where it is lawful to do so including where we or they:
- Need the data to provide you with products or
services you have requested;
- Have a public or legal duty to do so, e.g. to
assist with detecting and preventing fraud, tax evasion and financial crime;
- Need to in connection with regulatory
reporting, litigation or asserting or defending legal rights and interests
- Have a legitimate business reason for doing so
such as to manage risk, verify your identity, enable another company to provide
you with services you have requested, or assess your suitability for products
and services;
- Have asked you for your permission to share
it, and you have agreed.
Bank ABC may share your data for the
specific purposes below with other parties including:
- Anyone who provides instructions or operates
any of your accounts on your behalf, e.g. holders of a Power of Attorney, solicitors, intermediaries,
person to whom you have granted security over your account and anybody else
that we’ve been instructed to share your data with by either you, a joint
account holder or anybody else who provides instructions or operates any of
your accounts on your behalf;
- Any joint account holders, trustees,
beneficiaries or executors, to your legal representative and their advisors and
member of your family if you die or suffer mental incapacity for the purposes
of them making a payment on your account;
- Parties who give guarantees or other security
for any amounts you owe us.
- Parties you make payments to or receive
payments from;
- Other Bank ABC Group companies (including
their employees, sub-contractors, service providers, directors and officers)
and any of their sub-contractors, agents or service providers such as for
instance backup and server hosting providers, IT software and maintenance
providers, document storage providers and suppliers of other processing and
support services;
- Our legal and professional advisers such as
auditors and external legal counsel;
- Other financial institutions, clearing houses,
custodians, counterparties, fund managers, lenders and holders of security over
any property you charge to us
- Trade associations, credit reference or rating
agencies, payment service providers and debt recovery agents;
- Our business partners who we may have arranged
to provide a service to you and anybody party that provides marketing services
to us;
- Parties involved in any disputes, law
enforcement, government, courts, dispute resolution bodies, our regulators,
auditors and any party appointed or requested by our regulators to carry out
investigations or audits of our activities;
- Agencies for the prevention of fraud and
financial crime;
- Providers of card services, members of a
credit card association or merchant where we need to disclose in regard to the
operation of cards we supplied to you;
- Any introducing broker or other intermediary
to whom we provide instructions or referrals;
- With any party to a transaction acquiring risk
in, or assuming risk in, or in connection with, the products and services of Bank
ABC;
- Any governmental, banking, taxation or other
regulatory authorities or similar bodies with jurisdiction over any part of the
Bank ABC Group, or under the rules of a relevant stock exchange, including
those which are based overseas;
- Any member of Bank ABC Group to allow you to
access our products and services. This includes our Relationship Managers (if
they are employed or engaged by a member of the Bank ABC Group) and our IT
support teams for digital platform services;
- Any potential or actual participant sub
participant, assignee, transferee or novate (and their employees and advisors)
in respect of any of our obligations to you under any banking agreement;
- The courts, and as may otherwise be necessary
for the administration of justice, to protect vital interests and to protect
the security and integrity of our business operations or those of the Bank
ABC Group.
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| We may need to share any of the above data
with parties in different countries, when that is required to carry out our
contract with you, to fulfil a legal obligation, to protect the public interest
and/or for our own legitimate interests. The parties that we may share your
personal data with may be located in countries that already have adequate
protection for personal data under their applicable laws. Where parties are
located in countries that do not have such data protection laws, Bank ABC will
apply safeguards to maintain the same level of protection as the country in
which the products and services are supplied.
These safeguards may be contractual
agreements with the overseas recipient, or it may require the recipient to
subscribe to international data protection frameworks.
In this way your personal data may be
transferred outside the country of the Bank ABC office with which you have a
relationship.
For more information about these
safeguards, and others as may be relevant from time to time, you can contact us
using the ’How to contact us’ section of this Notice. |
| We keep your personal data for as long
as necessary to fulfil the purposes for which it was collected (as described
above). Even when you close your account with us, we retain, as long as required,
a minimum set of your personal data in order to comply with legal and
regulatory requirements or in case of claims or in order to answer any of your queries
. Such personal data include:
- Activities and transactions carried out by
users on the customer’s account via our digital platform;
- Username (used in our digital platform) of a
connected person who no longer works for our customer.
Please reach out to us as per ‘How to
contact us’ section of this Notice if you want more information about the
retention of Personal Data.
We will continue to look after your personal
data securely and your rights listed in this Privacy Notice remain in place
until your personal data is safely deleted from our systems.
The criteria we use to determine data
retention periods for your personal data includes the following:
- Retention in case of queries. We will retain
some of it in case of queries from you (for instance, if you submit an
application for a product or service for the Customer and if that is
unsuccessful);
- Retention in case of claims. We will retain
some of it for the period in which the Customer might legally bring claims
against us; and
- Retention in accordance with legal and
regulatory requirements. We will retain some of it after our agreement with the
Customer has come to an end and, with respect to access to our digital
platform, following the termination of such access, based on our legal and
regulatory requirements.
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You have the following rights to data
protection:- The right to be informed about the processing
of your personal data;
- The right to have your personal data corrected
if it is inaccurate and to have incomplete personal data completed;
- The right to object to the processing of your personal
data;
- The right to restrict the processing of your personal
data;
- The right to have your personal data erased
(the right to be forgotten);
- The right to request access to your personal
data and to obtain information about how we process it;
- The right to move, copy or transfer your personal
data (data portability);
- The right not to be subject to a decision
based solely on automated Processing, including Profiling, which produces legal
effects concerning him or her or similarly significantly affects him or her;
- The right to withdraw your consent at any time
(e.g. no longer be included in our marketing campaigns).
Please note that these rights are not
absolute and do not apply in all circumstances.
It is understood that you will be entitled to any additional rights that
would be conferred by the applicable Laws and Regulations. If you wish to
exercise any of these rights, please write or mail to us. Kindly refer to the
section “How to contact us” on how to reach us. |
| In addition, you have the right to
complain to the relevant supervisory authority which has enforcement powers and
can investigate compliance with data protection laws. The relevant supervisory
authority is:
- Personal Data Protection Commission
- 10 Pasir Panjang Road, #03-01 Mapletree
Business City, Singapore 117438
- Website: https://www.pdpc.gov.sg
- Phone Number: +65-6337-3131
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| There may be other terms and conditions in our agreements with the customer that will apply to our use of your personal data. Such terms and conditions must be read in conjunction with this Privacy Notice. |
| There may be other terms and conditions in our agreements with the customer that will apply to our use of your personal data. Such terms and conditions must be read in conjunction with this Privacy Notice. |
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