Privacy Notice for Retail Customers

• Full name, email, address, telephone number(s), nationality, country and date of birth, place of residency, identification documents, details of income and source of wealth, tax status and tax identification number (including FATCA), proof of address documents, and signature.
• Data about your identity including identity documents such as, details of ID cards, details of passports, national social security or insurance number, and driving license number.
• Income and source of income, source of wealth, average account financial activity, and engagement data.
• Your identity documents, along with any associated information they contain, as well as proof of address documents.
• Your employment status, employment information, financial status, tax status, tax identification number, details of income and its source, and source of wealth.
• Other data provided by you by completing forms and via other means including e-mail, electronic messages, recorded calls, live chat, chatbots and face-to-face contact.

• Personal data relating specifically to transactions carried out on our digital platform and mobile app by you (such as type, dates, amounts, currencies, payer, payee, and beneficiary details).
• Debit card, credit card, prepaid card, security token, or electronic key that you must use to confirm your identity when accessing our digital platform.
• 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.
• Due diligence data (e.g. data required to comply with financial crime regulations).
• 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).
• 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).
• Data about your geographic location and Bank ABC branches your visit.
• Correspondence, records of interactions, and complaints.
• Information on monthly income and average account financial activity.

• Online Identifiers that may leave traces which, when combined with unique identifiers and other data received by servers, may be used to identify you. Online Identifiers may include internet protocol (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.

• Your social media profiles, messages (when interacting with us) and your biographies.
• Information that we gather from publicly available sources or other local trade register and online registers or directories.
• When we conduct general searches on you.

• Credit reports, scores, and creditworthiness.
• Financial status.
• Information obtained from third parties such as credit reference, debt recovery, fraud prevention agencies or government agencies (e.g. this information may have originated from publicly accessible sources, such as court decisions).
• 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 must share your personal data with the CRAs including details about the credit application, your financial situation and financial history.

• Internet online identifiers (i.e., cookies, IP addresses) and other technical personal data (these may leave traces which, when combined with unique identifiers and other information received by servers, may be used to identify you).
• Technical personal data may include mobile network information, unique device identified, traffic data including web logs and geolocation.
• Security codes, including all confidential codes, usernames, user identifications and passwords, PIN/Password.

• Closed-circuit television (“CCTV”) may be used in and around our branches and ATM locations for the purposes of security and preventing crime, therefore we may have images of you captured by our CCTV cameras.
• Bank ABC may record and keep track of your conversations when you call our Customer Service including phone calls, face-to face meetings, letters, emails, social media messages, live chats, video chats and any other kinds of communication between you and employee of Bank ABC.

Depending on the Bank ABC banking entity responsible for your personal data, with which you have established a banking relationship or hold an account with, we may process the below sensitive personal data:

• Biometrics to authenticate your status as an authorized user of our digital application, and to assist in fraud detection.
• Criminal and court records including Central Bank account blocks and Politically Exposed Persons.
• Religion.

• To enable you to manage your account with us and to assist you to transact with us.
• To operate and manage your account and to manage your cards (debit and / or credit) that you have with us.
• To communicate with you and to resolve your queries.
• To authenticate you as an authorized user of your account with us.

• To assess the suitably of our products and services for your needs.
• To collect due and outstanding debt which may involve passing your personal information to debt collection agencies.
• To keep records of communications to evidence what has been discussed, keep a record of your instructions, activity on the digital platform, and to prevent or detect crime.
• To record customer account activities where we have reason to believe that fraud or other crimes are being committed or where we suspect non-compliance with anti-money laundering regulations to which we are subject.
• To test the performance of our products, services, and internal processes to ensure that your personal information is only collected as needed and is held and processed securely.
• To administer our internal operational requirements (including credit, compliance, risk management, market research, system and product development, quality control, accounting and audit).
• To keep records of activities on our digital platforms, websites, and mobile applications, such as your connection’s timestamp and duration.
• To exercise or defend our legal rights or those of a member of Bank ABC Group or a third party employed by us.

• To comply with laws that require us to verify the identity of our customers and to detect and prevent financial crime.
• To comply with tax regulations that require us to report the tax status of our customers.
• When enforcing or defending our rights, or those of any Bank ABC Group entities and affiliate or a third party employed by us.
• To comply with our regulatory obligations under any applicable regimes including without limitation sanctions, due diligence checks, and tax regulations requiring us to report the tax status of our customers.
• To prevent or detect financial crime or suspected financial crime, including (but not limited to) fraud, money laundering and financing of terrorism.
• To process requests relating to the exercise of your rights under applicable data protection laws.

Where you have agreed to us collecting your personal data, for example:

• ​When you have ticked a box to indicate that you are happy for us to use your personal data in a certain way.
• To manage our website registration page for newsletter sign-up.
• When you agreed to collection of Cookies (i.e., online Identifiers that may leave traces which, when combined with unique identifiers and other data received by servers, may be used to identify you). For more details about Cookies, see our online Cookie Policy.

To assist with detecting and preventing fraud, tax evasion and financial crime, or to protect the security and integrity of our business operations or those of the Bank ABC Group:

• The courts, and as may otherwise be necessary for the administration of justice.
• 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. li>
• Agencies for the prevention of fraud and financial crime.

• ​​Parties you make payments to or receive payments from.
• Parties who give guarantees or other security for any amounts you owe us.
• Any member of Bank ABC Group to allow you to access our products and services, including our Relationship Managers and our IT support teams for digital platform services and any of their sub-contractors, agents or service providers.
• 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 any party that provides marketing services to us.
• Providers of card services, members of a credit card association or merchants, where we need to disclose information regarding the operation of cards we supplied to you.
• Any introducing broker or other intermediary to whom we provide instructions or referrals.