"Abu Dhabi Commercial Bank PJSC" is the Bank's registered business name. The Bank is regulated by the United Arab Emirates Central Bank ("UAECB"). The registered Head Office of Abu Dhabi Commercial Bank PJSC is at Abu Dhabi Commercial Bank Head Office Building, Sheikh Zayed Street, Plot C-33, Sector E-11, P.O. Box 939, Abu Dhabi, United Arab Emirates.
For the purposes of applicable data protection legislation, the Bank is the data controller in respect of the information that we collect or obtain about you. This is because the Bank is the person who (either acting alone or jointly with others) determines why and how your personal information is processed.Contact us
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.YOUR PERSONAL DATA
Personal data or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Your personal information will be collected or obtained by us whether we deal with you as an individual or on behalf of an individual, business, charity, trust or other organisation that you represent. Broadly, personal information is any information that can identify you as an individual. We process many different types of personal information (for example, your name, address and date of birth). We may process personal data relating to criminal convictions and offences if we have your consent to do so or for fraud prevention purposes.
We will collect, use, store and transfer different kinds of personal data about you, which may include:
- Identifying information: i.e. information used to identify a specific individual, such as: name; date of birth; place of birth; nationality; country of residence; country of tax domicile; passport number and place of issue; residency permit details; tax identification details.
- Contact information: e.g. postal address, telephone number, email address.
- Family information: e.g. marital status.
- Financial information: e.g. source of wealth, personal assets, bank account numbers, spending and income details.
- Professional information: e.g. employer, business interests, career history.
- Website technical data: e.g. your internet protocol (IP) address, website login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Website profile and usage data: e.g. your interests, preferences, feedback and survey responses, and information about how you use our website
Where we need to collect personal data due to the requirements of applicable law or professional standards and you fail to provide that data when requested, we may have to decline a request for services or, if we are already acting, stop providing you with our services. We will notify you if this is the case at the time.
HOW YOUR PERSONAL DATA IS COLLECTED
- We may collect your personal information directly from you in a number of ways, including:
- when you apply for any product on our website (https://www.adcb.com/), through a postal application, telephone or direct with one of our employees;
- when you provide it on-line or by any other method of communication, for example, on "contact us" forms, or when you provide it through the course of our relationship, for example, if you inform us of a change in your circumstances; and
- technical information, including the Internet Protocol (IP) address used to connect to the internet, may be collected from you when you visit our website. We may obtain your personal information indirectly from third parties in the following ways:
- following an introduction to us by another third party, such as an accountancy firm, law firm or management consultancy;
- if another person provides your information to us when they apply to obtain a product from us:
- on your behalf; or
- that is to be held jointly with you; or
- on behalf of a business, charity, trust or other organisation of which you are a director, shareholder, owner, trustee or beneficiary (as applicable); or
- they have nominated you as a guarantor under our agreement with them, or to provide any other security, or informed us that you are a donor or lender of any deposit monies or occupier of any security property;
- when we carry out searches for the purposes of processing your application and/or during the course of your relationship with us; or
- in response to our marketing activities, you request information about our products via a third party (e.g. websites and social media platforms).
If you are applying to us through a third party then they should have provided you with their own privacy notice in order to tell you (whether online or in person) how they may process your personal information.HOW YOUR PERSONAL DATA IS USED
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Create, manage and maintain your experience on the Sites.
- Operate, evaluate and improve our business and the products and services we offer.
- Analyze and enhance our marketing communications and strategies (including by identifying when emails we have sent to you have been received and read).
- Analyze trends and statistics regarding visitors’ use of our Sites, mobile applications and social media assets.
- Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users.
- Notify you from time to time about relevant products and services operated by ADCB.
- Comply with a legal or regulatory obligation.
- Perform the contract we are about to enter into, or have entered into, with you.
- Where it is necessary for the purposes of legal proceedings.
Please refer to the table below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by using the 'unsubscribe' or 'preferences' option in the email or text message or by contacting the Customer Care Team at email@example.com.Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact the Customer Care Team at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Stage||Purpose / activity||Lawful basis for processing|
|Application||We process your personal information in order to consider and process your application for, or enquiry regarding, our products. This is necessary in order to take steps at your request before we enter into an agreement with you and is also necessary for our legitimate interests (i.e. in deciding whether or not we can offer you the product you have applied for). This type of processing is required in order for you to enter into an agreement with us. If you do not provide it then we cannot proceed with your application. In respect of fraud searches and identity verification, this processing is necessary for our legitimate interests (i.e. fraud prevention) and compliance with our legal obligations||(i) Legal obligation
(ii) Performance of a contract
(iii) Legitimate interests
|Declined business||If your application is declined we will store your personal information in accordance with our record retention procedures and to comply with our legal obligations.||(i) Legitimate interests
(ii) Legal obligation
|Account administration||If your application is accepted we will process your personal information in order to administer your account in a number of ways. This will include, for example, providing you with account statements, notices, and other information such as changes to your interest rate; managing any arrears on your account; enforcing any security that we have in place; and dealing with any queries or complaints that you may have. This type of processing is necessary for the performance of our contract with you and in order to fulfil our legal obligations||(i) Legal obligation
(ii) Performance of a contract
|Business operations||We will also process your personal information to manage our business operations, for example, our internal governance functions, which will include monitoring communications and activities in relation to your account, and for accounting and audit purposes. We have legitimate interests in doing so (i.e. it is necessary for our business and compliance purposes) and we may also have legal obligations to fulfil.||(i) Legal obligation
(ii) Legitimate interests
|Assisting you in the exercise of your rights||If we are dealing with a request you have made in order to exercise your legal and regulatory rights, this will be done in order to fulfil our legal obligation to respond to you.||(i) Legal obligation|
|Marketing||We process your personal information for marketing purposes. This is necessary in order to fulfil our legitimate interests of providing you with information about products and services that you may be interested in.||(i) Legitimate interests|
|Analysis||We may process your personal information for the purposes of performing statistical analysis and conducting market research. This is necessary in order to fulfil our legitimate interests (i.e. to enable us to better understand our customer base and the markets in which we operate, or may wish to operate).||(i) Legitimate interests|
|Website||The personal information that we process when you are browsing our website (such as your IP address) is processed on the basis that we have legitimate interests in doing so or that you have given your consent to this by accessing and browsing the website.||(i) Legitimate interests|
|Retention||After your agreement has ended we will retain your personal data in accordance with our record retention procedures and to comply with our legal obligations.||(i) Legal obligation
(ii) Legitimate interests
You will receive marketing communications from us if you have requested information from us or used our services or if you provided us with your details (e.g. a business card) in a marketing context and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting the Customer Care Team at email@example.com at any time. Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us for other purposes.Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the Customer Care Team at firstname.lastname@example.org.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties as further described in the Glossary below.
- External Third Parties as further described in the Glossary below.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Your personal data will be shared with Internal Third Parties. In some circumstances, this will involve us transferring your data outside the United Arab Emirates (“UAE”).
When we transfer your personal information to any other territories or countries outside the UAE we will take such steps as are necessary to ensure appropriate safeguards apply to maintain the same levels of protection as are needed under data protection laws. If we do so you may contact us to obtain a copy of the applicable safeguards.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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: see “Request Erasure” below for further information.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please read further below to find out more about these rights:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact the Customer Care Team at email@example.com.No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.Time limit to respond
We try to respond to all legitimate requests within four weeks. Occasionally it may take us longer than 4 weeks if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
GLOSSARYExternal third parties
- Anyone acting on your behalf with authority to do so, such as a debt charity, power of attorney or your professional advisors.
- Legal and regulatory bodies such as the United Arab Emirates Central Bank, the Securities and Commodities Authority (SCA), fraud prevention agencies, our professional advisors and/or the courts when it is necessary for our legitimate interests (e.g. to obtain legal advice or for fraud prevention purposes) and/or when we have a legal obligation to do so.
- Organisations that provide us with business support services. For example, account service and administration companies, back-up and server hosting, IT software and maintenance and platforms, document storage and management services. This processing is undertaken as it is necessary for the performance of our agreement with you and is necessary for our legitimate interests (i.e. for our commercial operations).
- Third parties who have introduced you to us (e.g. an intermediary or broker) in order 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 us to resolve any complaint made by you and/or any dispute between you and us. This type of processing is necessary for our legitimate business interests (e.g. to help us to ensure that the intermediary or broker is fulfilling the terms of their contract with us) and in order for us to fulfil our legal obligations (e.g. our complaint-handling obligations).
- Market research organisations who we engage to assist us in developing and improving our products and services. This type of processing is necessary for our legitimate interests (e.g. for our commercial operations).
- 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 us and their professional advisors. This type of processing is necessary for the fulfilment of our contract with you (e.g. to enable us to recover any sums we have advanced under our agreement with you).
- Any entity (and their professional advisors) that provides funding to us or members of the Bank's group, any entity that provides us with debt or equity finance and any potential purchasers of any part of our business. This type of processing is necessary for our legitimate interests (e.g. to enable us to fund our business).
We may share your personal information with other companies within the Bank’s group so that they can provide you with relevant products and services. This type of processing is necessary to enable us to take steps at your request prior to you entering into a contract with a company within the Bank's group.Lawful bases
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means a freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of your personal data.
Legal proceedings means processing your personal data where the processing is necessary for the purpose of, or in connection with, any legal proceedings or is necessary for the purpose of obtaining legal advice or is otherwise necessary for the purposes of establishing, exercising or defending legal rights.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.Special category data
- data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership;
- genetic or biometric data that is processed for the purpose of uniquely identifying a natural person;
- data concerning health;
- data concerning a natural person’s sex life or sexual orientation; or
- data relating to a natural person’s criminal record or alleged criminal activity.
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You will also, under certain circumstances, have the right to data portability, meaning that you have the right to receive your personal data in a structured, commonly used and machine-readable format to transmit those data to another controller.