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Privacy Notice
Page Content This Privacy Notice was last updated on 1 September 2020.
The purpose of this Privacy Notice is to
explain how Bank ABC Islamic (“Bank ABC Islamic”, ”ABC Islamic Bank
(E.C.)”, “we”, “us” and “our”) and the other members
of the Bank ABC Group may process your personal data. The “Bank ABC Group” includes ABC
Islamic Bank (E.C.) and its parent 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 Coverage Relationship Manager. |
A data controller determines
the purposes and means of the processing of your personal data.
Your data controller is Bank ABC Islamic,
Bank ABC Tower, Diplomatic Area, P.O. Box 2808, Manama, Kingdom of Bahrain,
with which you have entered into a banking relationship, or with which you
operate an account, including through the use of our digital platforms.
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 you;
- could reasonably be linked (directly or
indirectly) with you; or
- that can be used to authenticate you or provide
access to an account.
Where the customer of Bank ABC Islamic 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 Islamic is a
business customer, (i.e. they are organized 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 Islamic.
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, authorized persons, and personal
guarantors.
If you are a senior manager, authorized
signatory or beneficial owner of a business customer of Bank ABC Islamic, or if
you are a personal customer of Bank ABC Islamic, you must ensure that every
connected person receives a copy of this Privacy Notice before their personal
data is shared with Bank ABC Islamic. |
We will use your personal data where we have
your consent or when we have another lawful reason such as:
- The need to process the data to enter into or
carry out an agreement we have with you;
- The need to pursue our own legitimate interests;
- The 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);
- The 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, ATMs you use
and branches you visit;
- 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
Islamic;
- 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 include internet
protocol addresses (IP addresses) and cookie identifiers. 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 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;
- Data provided by other members of the Bank ABC
Group; and
- Data we receive
directly by your engagement with our social media platforms.
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Bank ABC Islamic 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 Islamic 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 Islamic or other entities of the Bank
ABC Group.
You can, at any time, withdraw your consent
for this marketing purpose. For more information, refer to ‘Your right to
data protection’ section of this Notice.
Please note that Bank ABC Islamic 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 Islamic can be reached
for updating your information. |
Bank ABC Islamic 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
Islamic may also 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; and
- 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.
Bank ABC Islamic 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, persons to whom you have granted security over your account and
anybody else that we have 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 merchants 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 Islamic;
- 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 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 Islamic will apply safeguards to maintain a similar
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 Islamic 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 as explained in 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;
- Username (used in our digital platforms) of a
connected person who no longer works for our customer.
Please reach out to us as explained in the “How
to contact us” section if you wish 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 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;
- The right not to be subject to a decision based
solely on automated processing, including profiling; 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”. |
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 Personal Data Protection
Authority in the Kingdom of Bahrain is the Ministry of Justice, Islamic Affairs
and Waqf. |
There may be other terms and conditions in
our agreements with our customers 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 (Braille print, audio). 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 Islamic handles personal data, please contact us by e-mail to privacy.bahrain@bank-abc.com for the attention of the Data Protection Coordinator.
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