Effective Date: 26/08/2020
- [IMPORTANT INFORMATION AND WHO WE ARE]
- [THE DATA WE COLLECT ABOUT YOU]
- [HOW IS YOUR PERSONAL DATA COLLECTED?]
- [HOW WE USE YOUR PERSONAL DATA]
- [DISCLOSURES OF YOUR PERSONAL DATA]
- [INTERNATIONAL TRANSFERS]
- [DATA SECURITY]
- [DATA RETENTION]
- [YOUR LEGAL RIGHTS]
- Important information and who we are
Email address: DPO@ahli.com
Telephone number: +96265206000 Ext. 1408
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.
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 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.
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
- Legal representatives ( power of attorney)
- Beneficiaries of payment transactions made by our clients:
- Beneficiaries of insurance policies and trusts:
- 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.
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|
|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 |
(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:|
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 |
(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 |
(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|
|(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 |
(e) Marketing and Communications
|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 |
|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 |
(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 |
(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.
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.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
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 usa599551 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.
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.
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.
- 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.
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.
- 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.
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.
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.
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 usa599551.
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.
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.