Effective Date: 19/08/2021

JAB Privacy Policy

Introduction

Welcome to the Jordan Ahli Bank’s privacy policy.

Jordan Ahli Bank (“JAB”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format as set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED?]
4. [HOW WE USE YOUR PERSONAL DATA]
5. [DISCLOSURES OF YOUR PERSONAL DATA]
6. [INTERNATIONAL TRANSFERS]
7. [DATA SECURITY]
8. [DATA RETENTION]
9. [YOUR LEGAL RIGHTS]
10. [GLOSSARY]

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how JAB collects and processes your personal data through your use of this website and online channels

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Changes to this privacy policy

We reserve the right to update and make amendments to this privacy policy from time to time. The user is responsible for checking the privacy policy periodically. These updates, amendments or deletions shall be effective immediately upon posting on the privacy policy. If this privacy policy is not agreeable to any user, then the user should abstain from using our website.

In the event of any material changes to the privacy policy, we will notify you about it by providing a notice to the email address you provided us with or by placing a prominent notice on our website. By continuing to use the website following any changes that will be interpreted as acceptance of such changes by the user.

Controller

This privacy policy is issued on behalf of the JAB Group so when we mention “JAB”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the JAB Group responsible for processing your data.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Email address: DPO@ahli.com

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

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.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity and Family situation Data includes first name, middle name, last name, username or similar identifier, marital status, number of children, title, date of birth and gender.
• Contact Data includes billing address, delivery address, postal address, email address and telephone numbers].
• Banking and Financial Data includes bank account and payment card details.
• Tax status Data includes tax ID tax status.)
• Technical Data includes [internet protocol (IP) address, your 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 this website].
• Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
• Usage Data includes [information about how you use our website, products and services].
• Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
• Education and employment information (includes Level of education, employment, employer’s name, remuneration)
• Data relating to your habits and preferences:
• Data which relates to your use of our products and services including banking, financial and transactional data.
• Data from your interactions with us, our branches (contact reports),our internet websites, our apps, our social media pages, meetings, calls, emails, interviews, phone conversation:
• Video surveillance (including CCTV) and geolocation data (e.g. showing locations of withdrawals and payments, for security reasons, or to identify the location of the nearest branch or service suppliers for you): and
• Data necessary to fight against over indebtedness.

We may collect the following sensitive data only upon obtaining your explicit prior consent:

• Biometric data includes fingerprint, voice pattern or facial recognition which can be used for identification and security purposes, and
• Health data for instance for the drawing up of some insurance contracts this data is processed on need-to-know basis.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs,  political opinions, trade union membership,). Nor do we collect any information about criminal convictions and offences unless it is required through a legal obligation.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to subscribe or use a specific product or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.  

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our products or services;
• create an account on our website;
• subscribe to our Digital service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website and digital channels, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• In certain circumstances, we may collect and use personal data of individuals with whom we have, could have, or previously had, a direct relationship such as:
• Visitors to our websites and digital channels.
• Prospective or existing clients: or.
• Attendees of our events
• We may also collect information about you where you do not have a direct relationship with us. This may happen, for instance, when your employer provides us with information about you or your contact details are provided by one of our clients if you are, for example:
• Family members
• Co-borrowers/guarantors,
• Legal representatives ( power of attorney)
• Beneficiaries of payment transactions made by our clients:
• Beneficiaries of insurance policies and trusts:
• Landlords:
• Ultimate beneficial owners:
• Clients debtors ( e.g. in case of bankruptcy )
• Company shareholders
• Representative of a legal entity (which may be a client or a vendor) and
• Staff of services provider and commercial partners
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below :

Technical Data from the following parties:

• analytics providers;
• advertising networks; and
• search information providers.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators.
• Identity and Contact Data from publicly available sources.

4. How we use your personal data

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 we need to perform the contract, we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all 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 us 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.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: a. Notifying you about changes to our terms or privacy policy b. Asking you to leave a review or take a survey c. Provide you with information regarding our products and services d. Assist you and answer your requests. e. Evaluate if we can offer you a product or service and under which conditions and f. Provide products or services to our corporate clients of whom you are member of staff, a shareholder, a beneficial owner or a client (for instance, in the context of cash management).	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website and digital channels (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)
To deploy and develop products or services, to improve our risk management and to defend our legal rights, including: • proof of transactions • fraud prevention • IT management, including in infrastructure management (e.g. shared platforms)& business continuity and it security: • establishing individual statistical models, based on the analysis of transactions, for instance in order to help define your credit risk score: • establishing aggregated statistics, tests and modes, for research and development, in order to improve the risk management of our group of companies or in order to improve existing products and services or create new one, • training of our personnel by recording phone calls to our contact centres: • personalising our offering to you or the entity you represent and that of other JAB entities through, – improving the quality of our banking, financial or insurance products or services: – advertising products or services that match with your circumstances and profiles which may be achieved by: o Segmenting our prospects and clients: o Analysing your habits and preferences in the various channels (visits to our branches, emails or messages, visits to our website, etc.) o Sharing your data with another JAB entity, notably if you or the entity you represent, are or are to become, a client of that other entity: o Matching the products or services that you already hold or use with other data we hold about you ( e.g. we may identify that you have children but no family protection insurance yet) and o Monitoring transactions to identity those which deviate from your normal routing (e.g. when you receive a large withdrawal from your bank account in a country where you do not live).	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	Necessary for our legitimate interests

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Marketing

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties 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 DPO at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

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 us.

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.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• JAB Group entities (e.g. so that you may benefit from our full range of group products and services) If you are a client of our corporate and institutional Banking business, this would include, for example, personal date being accessed and /or stored in jurisdictions in which and through which transactions are effected, and jurisdictions from which you regularly receive or transmit information about your business with JAB.
• Services providers which perform services on our behalf.
• In depended agent, intermediaries or, banking and specialised partners, with which we have a regular relationship
• In particular, in relation to our corporate and institutional banking business, we may disclose your personal data.
• To any counterparty, custodian, depositary, or nominee appointed or instructed by us on your behalf, or on behalf of the entity you represent, or through whom we may deal or transact in relation to your account or for purposes otherwise ancillary to the provision of services provided by JAB to you or the administration of your account.
• To any licensed credit agency in order to perform a credit assessment for any credit or mortgage-based products requested by or applied for by you and to tracing agents to recover debt:
• To any rating agency, insurer or other provider or credit protection to JAB.
• To fraud prevention agencies (FPA’s) in order to check the identity of the client or individuals or to investigate or prevent money laundering fraud, or other illegal activity, and
• If the disclosure relates to the actual or potential transfer or novation of one or more transactions pursuant to any applicable Terms of Business (or risks relating to such transactions) by us.

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.

6. International transfers

We share your personal data within the JAB Group. This will involve transferring your data outside) Jordan and the European Economic Area (EEA).

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.

[Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

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.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 15 years after they cease being customers.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. these rights are:

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:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• 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.

If you wish to exercise any of the rights set out above, please contact us.

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 could 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 one month. Occasionally it could take us longer than a month 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.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 DPO.

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.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the JAB Group acting as joint controllers or processors and who are based and provide IT and system administration services and undertake leadership reporting.

External Third Parties

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances. Financial taxation, judicial authorities, state agencies.

JAB Cookie policy

Our website and digital channels use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name/Title	Purpose	More information
[Java Session ID][JSESSIONID]	Used for identifying the user and authorize to consume post login services. Examples of purposes for which a cookie may be used: This cookie is essential for our site to or enables us to: [(a) All the post login services like Transfer, Bill Payment and P2P uses this cookie to identify the user performing the activity	https://javarevisited.blogspot.com/2012/08/what-is-jsessionid-in-j2ee-web.html
[Google Recaptcha] [NID] [ANID] [DV] [1P_JAR]	Re-captcha uses cookies which identifies whether the service request are initiated by human or bot [(a) Re-captcha is used during login	https://www.termsfeed.com/blog/privacy-policy-recaptcha/

To deactivate the use of third-party advertising cookies, you may visit the consumer page to manage the use of these types of cookies.Please note that third parties may also use cookies, over which we have no control. These third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies

You can block cookies by activating the settings on your browser that allows you to refuse the settings of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our websites.