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Privacy Notice
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Page Content This Privacy Notice was last updated on 1 September 2020.
| The purpose of this Privacy Notice is to explain how Arab Banking Corporation (B.S.C.) (“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 Bank ABC 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 controllers are Bank ABC, ABC Tower, Diplomatic Area P.O., Box 5698, Manama, Kingdom of Bahrain and Bank ABC (DIFC Branch) Unit C1203,
Level 12 Burj Daman, Dubai International Financial Centre, P O Box 507311,
Dubai, United Arab Emirates, with which you receive financial services, 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. |
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; and
- 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;
and
- 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, nationality, gender, 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, details of ID
cards, details of passports, national social security or insurance number,
driving license number;
- Contact
details including residential address, email addresses, telephone numbers,
proof of address documents;
- 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.; and
- 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; and
- Data relating
specifically to transactions carried out on our digital platform by
users. Whilst our banking relationship is with our customer, we will be
- Data provided
by other members of the Bank ABC Group; and
- Data we
receive directly by your engagement with our social media platforms.
- Recording
of data 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 platforms
and which user initiated the transactions. Some of this may be personal data
about the user.
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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;
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. |
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. |
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; and
- 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;
- 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;
- 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 or the Bank ABC Group;
- 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 including 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 any of our obligations to you under any banking agreement; and
- 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 platforms; and
- Username (used in our digital platforms) 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; and
- 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. |
| 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. |
Please contact us in case you need a copy of this Notice in another format and we will seek to accommodate.
Kindly refer to the section below for information on how such request can be made. |
| If
you have any questions about this Privacy Notice or the way Bank ABC handles
personal data, please contact us.
- Bank ABC and Bank ABC (DIFC Branch)
- Address:
- Bank ABC,
ABC Tower, Diplomatic Area P.O., Box 5698, Manama, Kingdom of Bahrain
- E-mail :
[email protected]
- Bank ABC (DIFC Branch) Unit C1203, Level 12 Burj Daman, Dubai International
Financial Centre, P O Box 507311, Dubai, United Arab Emirates
E-mail: [email protected] |
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