INTRODUCTION
Emirates NBD Bank PJSC, (referred to as “we”, “us”, “our” or “ENBD” in this Data Privacy Notice) primarily refers to all the Personal Data that is collected and used about ENBD Customers for the purposes of the Consumer Protection Regulations and Standards and the UAE Personal Data Protection Law. Emirates NBD Bank PJSC is part of the Emirates NBD Group.
ENBD is registered in Baniyas Road, Deira, P.O. Box: 777, Dubai, UAE
This Data Privacy Notice, herein referred to as the "Notice", describes the types of Personal Data ENBD collects, how this data is used, stored and shared, and your choices regarding this data. ENBD is the Data Controller for the Personal Data collected in connection with the use of ENBD Services.
SCOPE
This Notice applies to all Customers of ENBD Services, including Customers of ENBD’s mobile application, websites, branches, call centres, Automated Teller Machines, Cash Deposit Machines, Interactive Teller Machines, and any other banking Services (collectively, the “Services”) and through other interactions and communications you may have with us. This Notice specifically applies to:
ENBD is committed to providing you with exceptional banking Services and want you to have confidence in the way ENBD use your Personal Data. Emirates NBD is committed to protecting your privacy and your Personal Data.
Further this Notice explains the various measures ENBD have in place to protect the security of your Personal Data and minimise the potential for its unauthorised use, disclosure, and destruction.
YOUR DATA PRIVACY JOURNEY WITH US
ENBD may act as a "Data Controller" or a “Data Processor” in relation to your Personal Data.
Who is a Data Controller? ENBD will act as a Data Controller when processing your Personal Data. A Data Controller is an entity who solely, or jointly with others, determines the purposes (“why”) and means (“how”) of Personal Data Processing. In most cases, ENBD will act as the Data Controller when Processing your Personal Data – this means ENBD will decide on how to collect, process, and use Personal Data in this role.
Who is a Data Processor? In some other cases, ENBD will act as a Data Processor when Processing your Personal Data on behalf of another ENBD Group entity. In these cases, ENBD will perform the Processing of the Personal Data under the specific instructions from the ENBD Group entity acting as the Controller.
If you have any questions about how ENBD use your Personal Data, you can contact us by using the “Contact Us” information at the end of this Notice.
CONFIDENTIALITY OF PERSONAL DATA
When ENBD collects Personal Data, ENBD provides a safe, secure, and confidential environment in all our delivery channels to ensure that your Personal Data remains private and used for the purposes for which it is obtained and held.
ENBD has a legal obligation to keep your data confidential, however, ENBD may disclose your data to a third party where:
Personal Data and Processing have specific meanings under the UAE Applicable Laws. It is important that you understand these terms.
What is Personal Data?
Personal Data as per the Applicable Laws means, any data which relates to a living individual who can be identified directly or indirectly from that data. The definition includes a wide range of personal identifiers that constitute Personal Data, including but not limited to:
Demographic information (e.g., gender, marital status)
What is Processing?
Processing means any action taken on Personal Data, e.g. viewing, collecting, using, storing, sharing, manipulating, printing, copying, archiving etc.
Personal data that you provide to us
ENBD collects Personal Data directly from you as our Customer or Prospective Customer. ENBD collects information you provide directly to us through your access or use of ENBD Products and Services. For example, when you apply for a Product or Service on our website(s), by telephone or when you enter an ENBD premises and provide Personal Data with one of ENBD’s employees.
Personal data ENBD collects about you from other sources
ENBD may collect Personal Data about you from other sources such as, but not limited to the following:
Personal data ENBD may collect about other individuals
In certain circumstances, ENBD may be provided Personal Data by you about individuals who do not have a direct relationship with us. This may happen, for instance, when you provide us with Personal Data about:
Personal Data includes information that ENBD collect and process about you depending on the products or Services you obtain or receive.
The below is a non-exhaustive list which highlights some, but not all, examples of categories of Personal Data ENBD collect about you:
Category | Description | Example | Lawful Basis |
---|---|---|---|
Account Management |
Used to administer your account with ENBD.
Used to identify you when you sign-in to your account.
Used to provide you with Services, and to fulfil your requests for certain products and Services, such as issuance of Debit and Credit cards, Personal finance services (Auto finance, home finance, etc.), etc. |
To enable ENBD to process your data for the sole purpose of administering your relationship with the Bank. | Consent |
Account Opening |
Used for the setup and management of Customer accounts, including meeting the regulatory requirements such as KYC (Know Your Customer) process. |
To enable Customers to create an Account, log in to your instance on the ENBD App, or verify their credentials. | Consent |
Analytics |
Used to collect data about how Customers use the ENBD App or how it performs.
Used to understand how you use and interact with our Services and the people or things you’re connected to and interested in. |
To see how many Customers are using a particular gesture, to monitor app health, to diagnose and fix bugs or crashes, or to make future performance improvements. | Consent |
App Functionality |
Used for Features that are Available in the App.
Used to improve the design and functionality of ENBD channels for a better Customer experience. |
To enable app features, or to authenticate Customer. |
Consent
Comply with Legal Obligation |
Decline Onboarding |
If your application is declined, ENBD will store your Personal Data in accordance with the ENBD record retention procedures and to comply with ENBD legal and regulatory obligations. |
To keep track of the reasons for the declining of Onboarding to be used as reference, if and when the Customer approaches the Bank again. |
Consent
Comply with Legal Obligation |
Developer Communications |
Used to send news or notifications about the app or the developer. |
Sending a push notification to inform Customers about an important security update. | Comply with Legal Obligation |
Financial Mediations / Debt Recovery |
Used to authorise debt Service partners to carry out collection activities on ENBD behalf.
Used to recover debt and exercise other rights ENBD have under any agreement with ENBD Customers as well as to protect ENBD against harm to ENBD rights and interests in property. |
Partners of ENBD engage with Customers who have defaulted, to settle their liabilities with ENBD. | Consent |
Fraud Prevention, Security and Compliance |
Used for fraud prevention, security, or compliance with laws.
Used to prevent and detect fraud, money laundering and other crimes such as identity theft. |
Monitoring failed login attempts, geolocations, device information (e.g., model number, OS information), IP address, etc., to identify possible fraudulent activity. | Comply with Legal Obligation |
General Correspondence |
Personal Data you give to us by filling in any of ENBD forms or by communicating with us, whether face-to-face, by phone, email, online or otherwise. |
To contact you if you have asked us to do so including to resolve troubleshooting problems and helping with any issues concerning ENBD website or apps. | Consent |
Personalised Commercial and Promotional Communications (Marketing) |
To send commercial and promotional communications through telematic or conventional means, in relation to similar goods and Services than the ones previously contracted or acquired from ENBD.
This also includes for the purpose of conducting market research and accompanying statistical analysis to better understand our Customer base and the markets in which we operate. |
ENBD sends Customers a promotional email or SMS relating to a Product or Service on offer. | Consent |
Regulatory Requests |
To handle requests and instructions from regulators, law enforcement Agencies, etc. that specific information about individuals. |
To meet the legal and regulatory obligations ENBD has, as a Licenced Financial Institution, governed by the CBUAE. | Comply with Legal Obligation |
Satisfaction Surveys |
To contact you for your opinions about ENBD Services including through surveys and other market research. |
Sending Customer satisfaction surveys. |
Comply with Legal Obligation
Consent |
Service Communications |
Used to keep Customers informed of the products and Services they are availing of.
Used to tell you about important updates and changes to ENBD channels, including to ENBD Notice and other Policies and Terms.
Used to educate and advise you of security precautions that need to be taken to protect your data. |
Sending Customers reminders to update their Personal Data in the App such as their mobile number and home address. | Comply with Legal Obligation |
Video Protection (CCTV) |
Used at ENBD premises and ATMs for security purposes.
Used to monitor and investigate reported ATM issues from Consumers. |
To protect ENBD Customers, employees, visitors, and its premises. | Comply with Legal Obligation |
ENBD only discloses your Personal Data outside of ENBD in limited circumstances. If ENBD does share the Personal Data outside of ENBD, we will put in place appropriate controls and data sharing agreements that require recipients to protect your Personal Data, unless ENBD is legally required to share that Personal Data. All contractors or recipients that work for ENBD will be contractually obligated to comply with ENBD instructions. ENBD does not sell your Personal Data to third parties.
ENBD may disclose your Personal Data to ENBD third-party Service providers, agents, and subcontractors (Suppliers) for the purposes of providing Services to us or directly to you on ENBD’s behalf within and outside the UAE.
When ENBD uses Suppliers, ENBD only discloses to them the Personal Data that is necessary to provide their Services and only where ENBD has a contract in place which requires them to keep your Personal Data secure and not to use it other than in accordance with ENBD’s specific instructions.
ENBD take steps to ensure that any third-party service providers who handle your Personal Data comply with the Applicable Laws and protect your Personal Data to the same extent that ENBD does. ENBD will aim to anonymise your Personal Data or use aggregated non-specific data sets where possible.
All sharing of Personal Data with third parties shall be based on the consent from you, unless required to do so, to comply with the Applicable laws and other legal and regulatory requirements. Find below the supporting Schedule with a list of categories of third parties with whom ENBD may share your data.
Category of Third Party |
Description of Service Provided |
Lawful Basis of Processing |
Account Holders |
ENBD may share your Personal Data with any joint account holders, guarantors, trustees, or beneficiaries assigned by you at the onset or during the course of receiving ENBD products/Services. |
Consent |
Affiliates |
ENBD may share your Personal Data with companies within the Emirates NBD Group who may support us in any of the purposes set out in this Notice to (1) improve and enhance the Customer experience and (2) to administer your account with ENBD. |
Consent |
Analytics Providers |
ENBD may share your Personal Data with analytics providers that assist us in the optimisation of ENBD website and apps including by measuring the performance of ENBD online campaigns and analysing visitor activity. |
Consent |
Asset Purchasers |
ENBD may share your Personal Data with any third party that purchases, or to which ENBD transfer, all or substantially all of ENBD assets and business. Should such a sale or transfer occur, ENBD will engage best efforts to try to ensure that the entity to which ENBD transfer your Personal Data uses it in a manner that is consistent with this Notice. |
Consent |
Business Partners |
ENBD may share your Personal Data with ENBD business partners, together with whom ENBD provide Services such as hotels, restaurants, airline partners (whose logo may appear on a credit card ENBD provide) and Service providers or agents who provide Services on their behalf. Business partners may also include any entity (including its professional advisors and authorised representatives), who provide funding to ENBD or members of the ENBD Group, any entity that provides us with debt or equity finance and any potential purchasers of any part of our business. Business Partners may also include any party to a transaction acquiring an interest in, or assuming risk in, or in connection with, your banking relationship with ENBD. |
Consent |
Courts, Regulators, and Government Authorities |
ENBD may share your Personal Data with these parties where ENBD believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect ENBD rights or the rights of any third party.
To investigate or address claims or disputes relating to the use of ENBD’s Services, to satisfy requirements under applicable laws, regulations, or operating licences or agreements, or pursuant to legal process or governmental request, including from law enforcement.
To perform the role of collaborators, where Services require their involvement. |
Consent
Comply with Legal Obligation |
Credit Information Agencies |
ENBD may share your Personal Data with government-authorised Credit Information Agencies and fraud prevention agencies to comply with ENBD’s legal and regulatory obligations. |
Consent
Comply with Legal Obligation |
Debt Collection Agencies |
ENBD may share your Personal Data with any entity used for the recovery or collection of receivables to the Bank from delinquent or defaulted Customers. |
Consent |
Postal Services and Couriers |
ENBD may share your Personal Data with any entity used for the purpose of postal and courier services. |
Consent |
Fund Managers |
ENBD may share your Personal Data with fund managers who provide asset management Services to you and any brokers who introduce you to us or deal with us for you. |
Consent |
Guarantors |
ENBD may share your Personal Data with any person or entity that is to provide, or has provided, any security of guarantee (and their professional advisors) in respect of your agreement with ENBD.
This type of processing is necessary for the fulfilment of our contract with you, for example to enable us to recover any sums we have advanced under our agreement with you. |
Consent |
Insurance Providers |
ENBD may share your Personal Data with insurance providers, including underwriters, brokers, and associated parties. |
Consent |
Intermediaries/Brokers through whom you are our Customers |
ENBD may share your Personal Data with third-parties who have introduced you to us (e.g. an intermediary or broker) for them to manage their records about you, to ensure that the type of business that they refer to us is appropriate and to help ENBD to resolve any complaint made by you and/or any dispute between you and ENBD.
This type of processing allows us to ensure that the intermediary or broker is fulfilling the terms of their contract with us and for us to fulfil our legal and regulatory obligations. |
Consent |
IT Service Providers |
System based processing of personal details as part of organisational/ operational requirements. E.g. cloud hosting Services; application development and support Services; IT Infrastructure Services; email Services; communication Services providers, call recording Services. Help maintain the safety, security, and integrity of ENBD Services and Customer. Usage of AI productivity tools to enhance performance of services. |
Consent |
Law Enforcement Agencies & Authorities |
To assist law enforcement agencies for the purposes of preventing, detecting, investigating, or prosecuting criminal offences. |
Consent
Comply with Legal Obligation |
Legal/Professional Advisors |
The provision of business consulting, audit and legal Services including access to and analysis of Personal Data as part of business initiatives, statutory audits, legal claims, and ad-hoc consultancy advice. |
Consent |
Payment Processing Services |
ENBD may share your Personal Data with providers of payment-processing Services and other businesses that help us process your payments to the extent required for us to meet the contractual and legal requirements. |
Consent |
Representatives / Legal Guardians |
ENBD may share your Personal Data with anyone who provides instructions or operates any of your accounts on your behalf including advisers (such as solicitors and accountants), intermediaries and those under power of attorney or Letter of Authorisation. |
Consent |
Social Media Agencies |
ENBD may share your Personal Data with social media companies so they can display messages to you about ENBD products and Services or make sure you do not get irrelevant messages. |
Consent |
Other Third Parties |
Provide, maintain, and improve ENBD Services, including, for example, to facilitate payments, send receipts, provide products and Services you request (and send related information), develop new features, provide User support to Customer, develop safety features, authenticate Customer, and send product updates and administrative messages.
Perform internal administration and operations, including, for example, to prevent fraud and abuse of ENBD Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends.
Send you communications ENBD think will be of interest to you, including information about Products, Services, promotions, news, and events of ENBD, where permissible and according to local applicable laws.
Notify you about changes to ENBD terms, Services or policies and other communications that aren’t for the purpose of marketing the Services or products of ENBD or its partners. |
Consent
Comply with Legal Obligation |
The way ENBD analyses Personal Data relating to ENBD Services may involve profiling or other automated methods to make decisions about you that relate to the following:
You have a right to certain information about how ENBD make these decisions. You may also have a right to request human intervention in case it pertains to a fully automated process and to challenge the decision. Refer the “How to Contact Us” section for further details on reaching out to us with your request.
ENBD needs your Personal Data to provide you with the Services or products requested by you. ENBD also needs to capture expressed consent to be able to process the Personal Data for fulfilling ENBD’s contractual and legal obligations.
If you do not provide us with the requested Personal Data and the consent to process your Personal Data, ENBD may have to decline your request for our Product(s) and/or Service(s), or if ENBD is already providing you with the product(s) and Service(s), ENBD may need to suspend or stop providing you with the product(s) or Service(s), which can lead to closure of your banking relationship with us, subject to compliance with ENBD’s legal obligations to retain data.
It is optional for you to provide us your Personal Data or consent for direct sales or marketing purposes.
ENBD makes it clear on the ENBD physical application forms, during your onboarding digitally and on all communications received from the Bank as to what data is required to be provided by you by marking the mandatory fields with the asterisk symbol (*). ENBD requests your consent to process such data for direct sales and marketing purposes. It further, gives you an option to choose what are the channels through which you desire to be contacted.
You can choose to stop receiving further marketing communications at any time by:
ENBD operates channels, pages, and accounts on some social media sites to inform, assist and engage with customers.
ENBD is not responsible for any information posted on those sites other than information Emirates NBD has posted. ENBD does not endorse the social media sites themselves or any information posted on them by third parties.
ENBD collects Personal Data about your internet activity using technology known as cookies, which can often be controlled through internet browsers and by using ENBD cookie preference centre on the ENBD website and app.
ENBD utilises artificial intelligence (AI) productivity tools to enhance the efficiency and quality of our services. These tools may be used to automate routine processes and to support customer interaction, always with the goal of providing you with a personalised and secured banking experience. We are committed to protecting your privacy and ensure that the use of any AI tools is handled in accordance with applicable data protection laws and our strict internal security policies Your information is never used for purposes other than those outlined in this notice, and we continuously monitor and update our systems to maintain the highest standards of privacy, security and confidentiality.
Personal Data and Processing have specific meanings under the UAE Applicable Laws. It is important that you understand these terms.
What is Personal Data?
Personal Data as per the Applicable Laws means, any data which relates to a living individual who can be identified directly or indirectly from that data. The definition includes a wide range of personal identifiers that constitute Personal Data, including but not limited to:
Demographic information (e.g., gender, marital status)
What is Processing?
Processing means any action taken on Personal Data, e.g. viewing, collecting, using, storing, sharing, manipulating, printing, copying, archiving etc.
Personal data that you provide to us
ENBD collects Personal Data directly from you as our Customer or Prospective Customer. ENBD collects information you provide directly to us through your access or use of ENBD Products and Services. For example, when you apply for a Product or Service on our website(s), by telephone or when you enter an ENBD premises and provide Personal Data with one of ENBD’s employees.
Personal data ENBD collects about you from other sources
ENBD may collect Personal Data about you from other sources such as, but not limited to the following:
Personal data ENBD may collect about other individuals
In certain circumstances, ENBD may be provided Personal Data by you about individuals who do not have a direct relationship with us. This may happen, for instance, when you provide us with Personal Data about:
Personal Data includes information that ENBD collect and process about you depending on the products or Services you obtain or receive.
The below is a non-exhaustive list which highlights some, but not all, examples of categories of Personal Data ENBD collect about you:
Category | Description | Example | Lawful Basis |
---|---|---|---|
Account Management |
Used to administer your account with ENBD.
Used to identify you when you sign-in to your account.
Used to provide you with Services, and to fulfil your requests for certain products and Services, such as issuance of Debit and Credit cards, Personal finance services (Auto finance, home finance, etc.), etc. |
To enable ENBD to process your data for the sole purpose of administering your relationship with the Bank. | Consent |
Account Opening |
Used for the setup and management of Customer accounts, including meeting the regulatory requirements such as KYC (Know Your Customer) process. |
To enable Customers to create an Account, log in to your instance on the ENBD App, or verify their credentials. | Consent |
Analytics |
Used to collect data about how Customers use the ENBD App or how it performs.
Used to understand how you use and interact with our Services and the people or things you’re connected to and interested in. |
To see how many Customers are using a particular gesture, to monitor app health, to diagnose and fix bugs or crashes, or to make future performance improvements. | Consent |
App Functionality |
Used for Features that are Available in the App.
Used to improve the design and functionality of ENBD channels for a better Customer experience. |
To enable app features, or to authenticate Customer. |
Consent
Comply with Legal Obligation |
Decline Onboarding |
If your application is declined, ENBD will store your Personal Data in accordance with the ENBD record retention procedures and to comply with ENBD legal and regulatory obligations. |
To keep track of the reasons for the declining of Onboarding to be used as reference, if and when the Customer approaches the Bank again. |
Consent
Comply with Legal Obligation |
Developer Communications |
Used to send news or notifications about the app or the developer. |
Sending a push notification to inform Customers about an important security update. | Comply with Legal Obligation |
Financial Mediations / Debt Recovery |
Used to authorise debt Service partners to carry out collection activities on ENBD behalf.
Used to recover debt and exercise other rights ENBD have under any agreement with ENBD Customers as well as to protect ENBD against harm to ENBD rights and interests in property. |
Partners of ENBD engage with Customers who have defaulted, to settle their liabilities with ENBD. | Consent |
Fraud Prevention, Security and Compliance |
Used for fraud prevention, security, or compliance with laws.
Used to prevent and detect fraud, money laundering and other crimes such as identity theft. |
Monitoring failed login attempts, geolocations, device information (e.g., model number, OS information), IP address, etc., to identify possible fraudulent activity. | Comply with Legal Obligation |
General Correspondence |
Personal Data you give to us by filling in any of ENBD forms or by communicating with us, whether face-to-face, by phone, email, online or otherwise. |
To contact you if you have asked us to do so including to resolve troubleshooting problems and helping with any issues concerning ENBD website or apps. | Consent |
Personalised Commercial and Promotional Communications (Marketing) |
To send commercial and promotional communications through telematic or conventional means, in relation to similar goods and Services than the ones previously contracted or acquired from ENBD.
This also includes for the purpose of conducting market research and accompanying statistical analysis to better understand our Customer base and the markets in which we operate. |
ENBD sends Customers a promotional email or SMS relating to a Product or Service on offer. | Consent |
Regulatory Requests |
To handle requests and instructions from regulators, law enforcement Agencies, etc. that specific information about individuals. |
To meet the legal and regulatory obligations ENBD has, as a Licenced Financial Institution, governed by the CBUAE. | Comply with Legal Obligation |
Satisfaction Surveys |
To contact you for your opinions about ENBD Services including through surveys and other market research. |
Sending Customer satisfaction surveys. |
Comply with Legal Obligation
Consent |
Service Communications |
Used to keep Customers informed of the products and Services they are availing of.
Used to tell you about important updates and changes to ENBD channels, including to ENBD Notice and other Policies and Terms.
Used to educate and advise you of security precautions that need to be taken to protect your data. |
Sending Customers reminders to update their Personal Data in the App such as their mobile number and home address. | Comply with Legal Obligation |
Video Protection (CCTV) |
Used at ENBD premises and ATMs for security purposes.
Used to monitor and investigate reported ATM issues from Consumers. |
To protect ENBD Customers, employees, visitors, and its premises. | Comply with Legal Obligation |
ENBD only discloses your Personal Data outside of ENBD in limited circumstances. If ENBD does share the Personal Data outside of ENBD, we will put in place appropriate controls and data sharing agreements that require recipients to protect your Personal Data, unless ENBD is legally required to share that Personal Data. All contractors or recipients that work for ENBD will be contractually obligated to comply with ENBD instructions. ENBD does not sell your Personal Data to third parties.
ENBD may disclose your Personal Data to ENBD third-party Service providers, agents, and subcontractors (Suppliers) for the purposes of providing Services to us or directly to you on ENBD’s behalf within and outside the UAE.
When ENBD uses Suppliers, ENBD only discloses to them the Personal Data that is necessary to provide their Services and only where ENBD has a contract in place which requires them to keep your Personal Data secure and not to use it other than in accordance with ENBD’s specific instructions.
ENBD take steps to ensure that any third-party service providers who handle your Personal Data comply with the Applicable Laws and protect your Personal Data to the same extent that ENBD does. ENBD will aim to anonymise your Personal Data or use aggregated non-specific data sets where possible.
All sharing of Personal Data with third parties shall be based on the consent from you, unless required to do so, to comply with the Applicable laws and other legal and regulatory requirements. Find below the supporting Schedule with a list of categories of third parties with whom ENBD may share your data.
Category of Third Party |
Description of Service Provided |
Lawful Basis of Processing |
Account Holders |
ENBD may share your Personal Data with any joint account holders, guarantors, trustees, or beneficiaries assigned by you at the onset or during the course of receiving ENBD products/Services. |
Consent |
Affiliates |
ENBD may share your Personal Data with companies within the Emirates NBD Group who may support us in any of the purposes set out in this Notice to (1) improve and enhance the Customer experience and (2) to administer your account with ENBD. |
Consent |
Analytics Providers |
ENBD may share your Personal Data with analytics providers that assist us in the optimisation of ENBD website and apps including by measuring the performance of ENBD online campaigns and analysing visitor activity. |
Consent |
Asset Purchasers |
ENBD may share your Personal Data with any third party that purchases, or to which ENBD transfer, all or substantially all of ENBD assets and business. Should such a sale or transfer occur, ENBD will engage best efforts to try to ensure that the entity to which ENBD transfer your Personal Data uses it in a manner that is consistent with this Notice. |
Consent |
Business Partners |
ENBD may share your Personal Data with ENBD business partners, together with whom ENBD provide Services such as hotels, restaurants, airline partners (whose logo may appear on a credit card ENBD provide) and Service providers or agents who provide Services on their behalf. Business partners may also include any entity (including its professional advisors and authorised representatives), who provide funding to ENBD or members of the ENBD Group, any entity that provides us with debt or equity finance and any potential purchasers of any part of our business. Business Partners may also include any party to a transaction acquiring an interest in, or assuming risk in, or in connection with, your banking relationship with ENBD. |
Consent |
Courts, Regulators, and Government Authorities |
ENBD may share your Personal Data with these parties where ENBD believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect ENBD rights or the rights of any third party.
To investigate or address claims or disputes relating to the use of ENBD’s Services, to satisfy requirements under applicable laws, regulations, or operating licences or agreements, or pursuant to legal process or governmental request, including from law enforcement.
To perform the role of collaborators, where Services require their involvement. |
Consent
Comply with Legal Obligation |
Credit Information Agencies |
ENBD may share your Personal Data with government-authorised Credit Information Agencies and fraud prevention agencies to comply with ENBD’s legal and regulatory obligations. |
Consent
Comply with Legal Obligation |
Debt Collection Agencies |
ENBD may share your Personal Data with any entity used for the recovery or collection of receivables to the Bank from delinquent or defaulted Customers. |
Consent |
Postal Services and Couriers |
ENBD may share your Personal Data with any entity used for the purpose of postal and courier services. |
Consent |
Fund Managers |
ENBD may share your Personal Data with fund managers who provide asset management Services to you and any brokers who introduce you to us or deal with us for you. |
Consent |
Guarantors |
ENBD may share your Personal Data with any person or entity that is to provide, or has provided, any security of guarantee (and their professional advisors) in respect of your agreement with ENBD.
This type of processing is necessary for the fulfilment of our contract with you, for example to enable us to recover any sums we have advanced under our agreement with you. |
Consent |
Insurance Providers |
ENBD may share your Personal Data with insurance providers, including underwriters, brokers, and associated parties. |
Consent |
Intermediaries/Brokers through whom you are our Customers |
ENBD may share your Personal Data with third-parties who have introduced you to us (e.g. an intermediary or broker) for them to manage their records about you, to ensure that the type of business that they refer to us is appropriate and to help ENBD to resolve any complaint made by you and/or any dispute between you and ENBD.
This type of processing allows us to ensure that the intermediary or broker is fulfilling the terms of their contract with us and for us to fulfil our legal and regulatory obligations. |
Consent |
IT Service Providers |
System based processing of personal details as part of organisational/ operational requirements. E.g. cloud hosting Services; application development and support Services; IT Infrastructure Services; email Services; communication Services providers, call recording Services. Help maintain the safety, security, and integrity of ENBD Services and Customer. Usage of AI productivity tools to enhance performance of services. |
Consent |
Law Enforcement Agencies & Authorities |
To assist law enforcement agencies for the purposes of preventing, detecting, investigating, or prosecuting criminal offences. |
Consent
Comply with Legal Obligation |
Legal/Professional Advisors |
The provision of business consulting, audit and legal Services including access to and analysis of Personal Data as part of business initiatives, statutory audits, legal claims, and ad-hoc consultancy advice. |
Consent |
Payment Processing Services |
ENBD may share your Personal Data with providers of payment-processing Services and other businesses that help us process your payments to the extent required for us to meet the contractual and legal requirements. |
Consent |
Representatives / Legal Guardians |
ENBD may share your Personal Data with anyone who provides instructions or operates any of your accounts on your behalf including advisers (such as solicitors and accountants), intermediaries and those under power of attorney or Letter of Authorisation. |
Consent |
Social Media Agencies |
ENBD may share your Personal Data with social media companies so they can display messages to you about ENBD products and Services or make sure you do not get irrelevant messages. |
Consent |
Other Third Parties |
Provide, maintain, and improve ENBD Services, including, for example, to facilitate payments, send receipts, provide products and Services you request (and send related information), develop new features, provide User support to Customer, develop safety features, authenticate Customer, and send product updates and administrative messages.
Perform internal administration and operations, including, for example, to prevent fraud and abuse of ENBD Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyse usage and activity trends.
Send you communications ENBD think will be of interest to you, including information about Products, Services, promotions, news, and events of ENBD, where permissible and according to local applicable laws.
Notify you about changes to ENBD terms, Services or policies and other communications that aren’t for the purpose of marketing the Services or products of ENBD or its partners. |
Consent
Comply with Legal Obligation |
The way ENBD analyses Personal Data relating to ENBD Services may involve profiling or other automated methods to make decisions about you that relate to the following:
You have a right to certain information about how ENBD make these decisions. You may also have a right to request human intervention in case it pertains to a fully automated process and to challenge the decision. Refer the “How to Contact Us” section for further details on reaching out to us with your request.
ENBD needs your Personal Data to provide you with the Services or products requested by you. ENBD also needs to capture expressed consent to be able to process the Personal Data for fulfilling ENBD’s contractual and legal obligations.
If you do not provide us with the requested Personal Data and the consent to process your Personal Data, ENBD may have to decline your request for our Product(s) and/or Service(s), or if ENBD is already providing you with the product(s) and Service(s), ENBD may need to suspend or stop providing you with the product(s) or Service(s), which can lead to closure of your banking relationship with us, subject to compliance with ENBD’s legal obligations to retain data.
It is optional for you to provide us your Personal Data or consent for direct sales or marketing purposes.
ENBD makes it clear on the ENBD physical application forms, during your onboarding digitally and on all communications received from the Bank as to what data is required to be provided by you by marking the mandatory fields with the asterisk symbol (*). ENBD requests your consent to process such data for direct sales and marketing purposes. It further, gives you an option to choose what are the channels through which you desire to be contacted.
You can choose to stop receiving further marketing communications at any time by:
ENBD operates channels, pages, and accounts on some social media sites to inform, assist and engage with customers.
ENBD is not responsible for any information posted on those sites other than information Emirates NBD has posted. ENBD does not endorse the social media sites themselves or any information posted on them by third parties.
ENBD collects Personal Data about your internet activity using technology known as cookies, which can often be controlled through internet browsers and by using ENBD cookie preference centre on the ENBD website and app.
ENBD utilises artificial intelligence (AI) productivity tools to enhance the efficiency and quality of our services. These tools may be used to automate routine processes and to support customer interaction, always with the goal of providing you with a personalised and secured banking experience. We are committed to protecting your privacy and ensure that the use of any AI tools is handled in accordance with applicable data protection laws and our strict internal security policies Your information is never used for purposes other than those outlined in this notice, and we continuously monitor and update our systems to maintain the highest standards of privacy, security and confidentiality.
ENBD is a global organisation, and your Personal Data may be stored or processed in any country where ENBD has facilities or in which ENBD engages Service providers and subcontractors. ENBD has put in place appropriate safeguards in accordance with applicable legal and data protection requirements to ensure that your data is adequately protected.
You have certain rights in respect of your Personal Data, and ENBD have processes to enable you to exercise these rights. Your rights are as follows:
Central Bank of the United Arab Emirates
Telephone: 800 (CBUAE) 22823.
Website: CBUAE | Filing a Banking-Related Complaint (centralbank.ae).
Please note, all rights are subject to qualifications and limitations. In other words, there may be instances and justifiable grounds to deny any request where ENBD is required or permitted by law or technical infeasibility to do so. ENBD will always be clear and communicate this to you if these instances arise.
Also note, for the purpose of upholding the security, confidentiality, and integrity of your Personal Data, ENBD may verify your identity before allowing you to access your Personal Data.
The Security of your Personal Data is important to us. We make every effort to ensure that your Personal Data is secure on our system. ENBD maintains physical, technical, and organizational safeguards to secure your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss. Moreover, access to your personal data is limited to those employees, agents, contractors, other third parties, etc. who have a responsibility towards your personal data and only on a need-to-know basis. The aforementioned will only process your personal data on ENBD’s instructions, and they are subject to a duty of confidentiality.
Additional safeguards that Emirates NBD use to safeguard your personal data include:
ENBD evaluates these measures on a regular basis to ensure the security of the processing.
Your ENBD profile is password-protected so that only you and authorised ENBD employees have access to your account information. While we at Emirates NBD, will do our best to ensure the security and protection of your personal data, the security of your personal data will depend in part on the security of the device that you use to communicate with us, and the security measures you use to protect your personal information, user ID and passwords.
To ensure that your personal data is always kept safe, we urge you to take appropriate measures to protect your personal information, user ID and passwords, and any other information that is necessary to use our channels.
If you have any further questions on this issue, refer to the ENBD General Terms of Conditions.
Please contact the ENBD Customer Service Helpdesk on 600 540000, or reach out to us at customersupport@EmiratesNBD.com, in case you receive fraudulent emails or require any assistance with regards to our online banking Services.
Whilst ENBD takes measures to secure your Personal Data, risks to data security do exist, and there is always a possibility of unauthorised use, disclosure, modification and/or destruction of your Personal Data. In the event of a Personal Data Breach, ENBD may notify you and the Central Bank of the United Arab Emirates, without delay, about it and its likely consequences, measures taken by us to mitigate the increased risk and avenues available to you to mitigate the risk as a result of the Personal Data Breach.
For reporting Personal Data Breaches or further information on how ENBD respond to and handle Personal Data Breaches, please contact us at DPO@EmiratesNBD.com.
The ENBD website and apps may, from time to time, contain links to external sites. If you follow a link to any of these websites, please note that these websites have their own Data Privacy Notices. Please check these Notices before you submit any Personal Data to these websites. ENBD is not responsible for the Data Privacy Notices, content of such sites or any Personal Data collected by such sites.
ENBD has appointed a Data Protection Officer ("DPO") to oversee compliance with this Notice. The DPO can be contacted on DPO@EmiratesNBD.com.
ENBD will keep your Personal Data for as long as ENBD has a relationship with you and for meeting our legal, accounting, or reporting requirements. Once the ENBD relationship with you has come to an end, ENBD will retain your Personal Data for a period that enables us to:
ENBD will delete/store with limited access and appropriate safeguards your Personal Data when it is no longer required for these purposes.
In some circumstances you can ask us to delete your data. For further information, please see the "What are your Rights" section.
If you have questions or concerns regarding the way in which your Personal Data is being used, please contact the ENBD Data Privacy Office by emailing DPO@EmiratesNBD.com.
If you would like to lodge a complaint to the CBUAE, please get in touch and ENBD will provide you with instructions and contact details to the CBUAE.
ENBD is committed to working with you to obtain a fair resolution to any complaint or concern you may have. If, however, you believe that ENBD have not been able to assist with your complaint or concern you have the right to make a complaint to the competent data protection authority.
ENBD may occasionally update this notice. ENBD encourages Customers to periodically review this Notice for the latest information on the ENBD data privacy practices.
Term | Definition |
---|---|
Applicable Law(s) |
Means all Applicable Law(s) relating to the Processing of Personal Data, in each case which are in force at the date on which this policy is updated in the UAE including the CBUAE Consumer Protection Regulation and Accompanying Standards as amended. |
Authority(ies) |
Means legal, supervisory, regulatory, governmental, and quasi-governmental bodies including the Central Bank of United Arab Emirates (“CBUAE”), the Securities and Commodities Authority (“SCA”), fraud prevention agencies, etc. |
Automated Processing |
Means Processing that is conducted using an electronic application or system that operates automatically, either independently without any human intervention or under the supervision and limited intervention of a human. |
Consent |
Means the Consent by which the Consumer/Customer authorises ENBD or third parties to process their Personal Data, provided that such Consent is freely given, informed, clear, specific, and unambiguous indication of the Consumer/Customer agreement, by a statement or by a clear affirmative action, to the Processing of their Personal Data. |
Consumer Protection Regulation (‘CPR’) and Accompanying Standards (‘CPS’) |
Means the CBUAE Consumer Protection Regulation (“CPR”) (CBUAE Notice No. 444/2021), and accompanying Consumer Protection Standards (“CPS”) (CBUAE Notice No. 1158/2021) that apply to all Licensed Financial Institutions (“LFIs”) licensed by the CBUAE in relation to their activities specified in Article 65 of the Decretal Law No. 14 of 2018. |
Consumer(s)/Customer(s) |
Means a Customer for the purpose of CBUAE Consumer Protection Regulation and the accompanying Standards. A Customer is any natural person or sole proprietor who obtains or may prospectively obtain Services and/or products from ENBD, with or without charge, to satisfy their personal need or others’ needs. A Customer hence includes a Prospective Customer. |
Credit Information Agency |
Al Etihad Credit Bureau and any credit information agency established for the purpose of credit reporting requirements. |
Personal Data Breach(es) |
Means, as per the UAE Data Protection Law (Federal Decree Law No. 45 of 2021 Regarding the Protection of Personal Data), a breach of information security and Personal Data through unauthorised or unlawful access thereto, including replication, transmission, distribution, exchange, transfer, communication, or Processing in such a manner leading to the disclosure or divulgence to third parties, or otherwise the destruction or modification of such data while being stored, transferred and processed. |
Data Protection Officer (‘DPO’) |
Means any natural person appointed by ENBD who undertakes responsibilities to verify that ENBD complies with the Personal Data Protection controls, requirements, procedures, and rules provided for herein, and to verify the integrity of its systems and procedures to achieve the compliance with the CPR & CPS. |
Customer Right(s) |
Means the set of rights afforded to individuals, as per CPR & CPS, who request information about the Personal Data collected or stored by ENBD and to exert choice or control over how that data is used by ENBD. |
Data Transfer(s) |
Means any movement of data between or within jurisdictions from one party to the other. |
Destruction of Personal Data |
Means the act or action of ensuring that Personal Data no will no longer exist. |
ENBD |
Means Emirates NBD Bank PJSC and any of its branches, subsidiaries, affiliates and authorised agents. |
Encryption |
Means the process of encoding information stored on a device and can add a further layer of security. It is considered an essential security measure where Personal Data is stored on a portable device or transmitted over a public network. |
Know Your Customer or ‘KYC’ |
Means the mandatory identification and verification of the identity of customers In accordance with Cabinet Resolution no. 58 of 2020 regulating the Beneficial Owner Procedures (the UBO Resolution), Financial Institutions are obliged to identify customers, including the Beneficial Owners, beneficiaries, and controlling persons, whether permanent or walk-in, and whether a natural or legal person or Legal Arrangement, and to verify their identity using documents, data or information obtained from reliable and independent sources. |
Lawful Basis |
Means the justification to which Personal Data is being processed by ENBD. |
Notice |
Notice refers to this document, i.e., the ENBD Data Privacy Notice. |
Personal Data |
Means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as an identification number or to one or more factors specific to their biological, physical, biometric, physiological, mental, economic, cultural or social identity. |
Processing |
Means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, such as collection, recording, organisation, structuring, storage, adaptation or alteration retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. |
Profiling |
Means a form of Automated Processing consisting of the use of Personal Data to evaluate certain personal aspects relating to a Consumer/Customer. |
Services |
Means all Banking products and services such as account management including financing, card management, etc., provided through all ENBD channels such as application, websites, branches, call centers, Automated Teller Machines, Cash Deposit Machines, Interactive Teller Machines, etc. |
Central Bank of the United Arab Emirates (‘CBUAE’) |
Means the Central Bank who is responsible for overseeing compliance with personal data handling rules for licensed financial institutions (as per CPR & CPS requirements) within the UAE. Such regulators are responsible for the following:
|
UAE |
Means the United Arab Emirates. |
Update on May 12, 2025
Thank you for your feedback!
We'd love to know.