Data Privacy Notice

INFORMATION THAT YOU PROVIDE TO US

We collect data directly from you as our customer or prospective customer. We collect 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 engage with one of our employees.

INFORMATION WE COLLECT ABOUT YOU FROM OTHER SOURCES

The Bank may collect information about you from other sources such as but not limited to:

• Representative(s) of a corporate client;
• Legal representatives (power of attorney) of a client;
• People appointed to act on your behalf;
• Other Emirates NBD Groups;
• Your employer;
• Credit Bureaus or credit reporting agencies;
• Digital identity solutions;
• Government databases;
• Law enforcement officials;
• Co-borrowers / guarantors;
• Criminal records checks from organisations authorised to provide this data;
• Beneficiaries of your payment transactions;
• Nominated contact person by an existing account holder;
• Third party providers and partners to help us improve the personal data we hold and to provide more relevant and interesting products and services to you; and Reference contacts provided in the application form by you.

INFORMATION WE MAY COLLECT ABOUT OTHER INDIVIDUALS

In certain circumstances, we may be provided information from you about individuals who do not have a direct relationship with us. This may happen, for instance, when you provide us with information about:

• Representative(s) of a corporate client;
• Shareholder(s)/Director(s) of a corporate client;
• Legal representatives (power of attorney) of a client;
• Ultimate beneficial owners;
• Successors and right holders;
• Co-borrowers / guarantors;
• Employers of our customers;
• Beneficiaries of your payment transactions;
• Landlords; and
• Reference contacts provided in the application form by our (prospective) customer.

We refrain from collecting other types of data than the categories mentioned in this policy, furthermore, personal data collected by our organisation are used only for the stated and explicitly listed purposes within this data privacy notice.

Personal data includes information that we 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 information we collect about you:

Information from online activities:

We collect information about your internet activity using technology known as cookies, which can often be controlled through internet browsers and by using our cookie preference centre on our website.

For detailed information on the cookies we use and the purposes for which we use them, see our Cookies Policy, which is available on our website.

You must keep your personal data up-to-date – please tell us promptly about any changes, for example, if you have a new address.

We automatically collect the following when you use our website or apps:

• Technical information, such as your IP address and device ID.
• Information about your visit, such as your URL and website interaction.
• Location data, with your approval, used to show you the location of the nearest branch or ATM based on your IP address, coordinates or a unique device code.
• Networks and connections, when you interact with us and the people and groups that you are connected to (for example, through social media).

Find out more

The Bank is committed to collect used data through lawful and transparent means, furthermore, where required, we will ask for the express consent of the data subject. We may use the categories of personal data explained in the previous section as follows:

IS IT OBLIGATORY OR VOLUNTARY FOR ME TO PROVIDE MY PERSONAL DATA?

We need your personal data to provide you with the services or products requested by you. We also need to capture expressed consent to be able to process the personal data for fulfilling our contractual and legal obligations.

If you do not provide us with the requested personal data and consent to our methods of processing, we may have to decline your request for our services, or if we are already providing you with the product(s) and service(s) or, we may need to suspend or stop providing you with the product(s) or service(s) which can lead to account(s) closure subject to compliance with our legal obligations to retain data.

It is voluntary for you to provide us your data or consent for sales or marketing purposes.

We make it clear on our application forms what data is required to be provided by you by marking the mandatory fields with the asterisk symbol (*).

You can object to further marketing at any time by:

• Calling our customer call centre on +971 600 54 0000 or texting STOP to 4456;
• changing your marketing preferences in your account; or
• sending us an email at [email protected].

Further details of how we will use your information can be found below.

Automated processing

The way we analyse personal data relating to our services may involve profiling or other automated methods to make decisions about you that relate to the following:

• Credit and affordability checks (including credit limits) – we will consider a number of factors including information about your income, expenses and how well you have kept up on payments in the past.
• Anti-money laundering, sanctions checks and screening 'politically exposed' people.
• Monitoring your account for fraud and other financial crime – we will assess your transactions to identify any that are unusual.
• Assessments required by regulators and appropriate authorities – certain details in your information may suggest that you are likely to become financially vulnerable and we may need to help you.

You may have a right to certain information about how we make these decisions. You may also have a right to request human intervention in case it pertains to a full automated process and to challenge the decision.

We 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 Privacy Notice;
• any joint account holders, guarantors, trustees or beneficiaries assigned by you at the onset or during the course of receiving our products/services;
• 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;
• people you make payments to and receive payments from to the extent required for us to meet the contractual and legal requirements;
• 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;
• government-authorised Credit Information Agencies and fraud prevention agencies to comply with our legal and regulatory obligations;

Please be advised about the possible limitations of accessing future financial products and/or services based on your records provided to these agencies.

• any fund managers who provide asset management services to you and any brokers who introduce you to us or deal with us for you;
• independent third-party service providers and agents (including their sub-contractors) such as collection agents or providers who may deliver a gift or provide a gesture of goodwill;
• our business partners, together with whom we provide services such as hotels, restaurants, airline partners (whose logo may appear on a credit card we provide) and service providers or agents who provide services on their behalf;
• insurance providers, including underwriters, brokers and associated parties;
• analytics providers that assist us in the optimisation of our website and apps including by measuring the performance of our online campaigns and analysing visitor activity;
• social media companies so they can display messages to you about our products and services or make sure you do not get irrelevant messages;
• any people or companies where required in connection with potential or actual corporate restructuring, merger, acquisition or takeover including the transfer of any of our rights or duties under our agreement with you;
• law enforcement authorities, government bodies (including Al Etihad Credit Bureau), courts, dispute resolution bodies, regulators, auditors and any party appointed by our regulators to carry out investigations or audits of our activities; and
• where required to do so by court order or where we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation

We take responsibility to protect your personal data. Through due diligence, when engaging with third parties, we ascertain that they either align closely with our Data Privacy Notice or have established comparable standards of protection within their own operations to ensure the utmost safety of your information.

We are headquartered in Dubai in the United Arab Emirates (UAE). We may transfer your personal data to other countries where we (or other companies within the Emirates NBD Group) or our service providers maintain operations.

When we do this, we'll ensure it has an appropriate level of protection and that the transfer is lawful and appropriate consent has been obtained from you/your authorised signatory/anyone who represents you legally. This includes relying on adequacy decisions issued by the relevant data protection authority and using standard contractual clauses for transfers of personal data. You can obtain more details of the protection given to your information when it is transferred by contacting us using the details below.

The security and confidentiality of your personal data is important to us!

We use a range of measures to keep your personal data secure and protected against unlawful processing and analysis, unauthorised access, accidental loss, destruction, and damage. When we use external service providers, we require them to provide the same standards of data protection as we do.

The Bank deploys a wide range of security measures to ensure the security, confidentiality and integrity of your data. This includes but is not limited to the following:

• Asset Security
• Application Security
• Access Controls
• Network Security
• Communication Security
• Physical Security
• Organisational Security

Please contact our Customer Service Helpdesk on +971 600 54 0000 in case you receive fraudulent emails or require any assistance using our online banking services.

Children’s data

Protecting the safety of children when they use the Internet is important to us. Our websites and apps are intended for use only by persons who are at least 18 years of age. If you are under the age of 18, your parent or guardian must consent on your behalf where we ask for consent in relation to the use of your information.

What Happens if There Is a Personal Data Breach?

Whilst we take 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, we will notify you 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 we respond to and handle Personal Data Breaches, please contact us at [email protected].

External Links

Our 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 privacy policies. Please check these policies before you submit any personal data to these websites. We are not responsible for the privacy notices, content of such sites or any personal data collected by such sites

We do not keep your personal data for any period longer than is necessary for the purpose for which your personal data was collected, processed, required by law or where we may need it for our legitimate purposes such as maintaining records for analysis or audit purposes, responding to queries or complaints, monitoring fraud, defending or taking legal action and responding to requests from regulators.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements

In some circumstances you can ask us to delete your data. For further information, please see section “Your Rights”. If you opt out from receiving marketing communications or object to any other processing of your personal data, we may keep a record of your objection to ensure that we continue to respect your wishes and do not contact you further.

Your choices and rights

In certain circumstances, you have the right to:

• Right of Access: ask for a copy of the personal data we hold about you and obtain information about how we process it; ask us to give you (or a third party chosen by you) an electronic copy of the personal data you have given us;
• Right to Rectification: ask us to correct personal data we hold;
• Right to Restrict: ask us to restrict how we use your personal data;
• Right to Erasure: ask us to delete your personal data;
• Right to Object: to particular ways we are using your personal data, including objections to marketing;
• Right to Contact Us: with any enquiries or complaints in respect of your personal data; and
• Right to Withdraw Consent: to the following at any time:
• the processing of your personal data by us except where your personal data is required for business operation in relation to the product or service you obtain from us; and
• sharing your personal data with third parties for purposes such as but not limited to marketing or sales.

Please note that a withdrawal of consent by you will not affect the lawfulness of data processing based on the prior consent. Your withdrawal of consent will take effect within 30 calendar days from the day you request us to do so.

If you wish to exercise any of these rights in relation to the personal data, we hold about you or wish to change your preferences at any time, please contact us, using the details below.

We may need to ask you to verify your identity before allowing you to access your personal data.

Any changes we make to our Privacy Notice will be posted on this page and, in relation to substantive changes, will be notified to you by e-mail.

This privacy notice was last updated on 18th August 2023.

If have any questions about this Privacy Notice, please contact us:

• By email at: [email protected]
• By writing to us:
  FAO Group Data Protection Officer
  Emirates NBD Bank PJSC
  P.O. BOX 777, Dubai, United Arab Emirates
• By phoning our Customer Service Helpdesk: +971 600 54 0000