Privacy Policy
Who are we
First Abu Dhabi Bank PJSC together with its subsidiaries, affiliates and related entities (“FAB PJSC”) are committed to providing the highest level of protection to your Personal Data in accordance with applicable data protection laws and regulations.
First Abu Dhabi Bank, ADGM ("FAB ADGM”, “we”, “us”, or “our”),is a branch of FAB PJSC registered in the Abu Dhabi Global Market (Company No. 000007162), with its registered office at Unit 1, 7th Floor, Al Sarab Tower, Abu Dhabi Global Market Square, Al Maryah Island, United Arab Emirates. FAB ADGM is regulated by the ADGM Financial Services Regulatory Authority as a branch of a foreign limited liability company.
The Data Protection Regulations 2021 ("DP Regulations") apply to this policy . For the purposes of DP Regulations, FAB ADGM is the controller of your Personal Data.
What is the purpose and scope of this Privacy Policy
This policy describes how FAB ADGM may collect, use, store, disclose or otherwise process your Personal Data, including Personal Data provided when using our websites (“FAB Websites”) and also to explain your rights relating to the privacy of your Personal Data and how the law protects you.
What is Personal Data and what Personal Data do we collect
Personal data comprises all the details that FAB ADGM collects and processes directly or indirectly about you as an individual client, or representative of a corporate client. The types of personal information we may collect includes, without limitation, information about:
The use of the FAB Websites and any products and services supplied are subject to our terms and conditions.
Processing Personal Data
Legal basis and purposes for collection and the use of your Personal Data:
FAB ADGM may process your Personal Data as an individual client or a representative of a corporate client for the following purposes:
- processing account opening application forms for products and services, including assessing customer suitability and performing necessary checks and risk assessments (e.g., in case of credit request);
- providing products and services (including electronic banking services), including effecting payments, transactions and completing instructions or requests;
- monitoring and improving our website and its content;
- establishing and managing banking relationships and accounts;
- conducting market research and surveys with the aim of improving our products and services;
- sending you information about our products and services for marketing purposes and promotions;
- preventing, detecting, investigating and prosecuting crimes (including but not limited to money laundering, terrorism, fraud and other financial crimes) in any jurisdiction, identity verification, government sanctions screening and due diligence checks;
- complying with applicable local or foreign law, regulation, policy, voluntary codes, directive, judgement or court order, as well as any contractual obligation pursuant to agreements between any member of FAB PJSC and any authority, regulator or enforcement agency or body or any request coming from said entities;
- establishing, exercising or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings;
- monitoring: to the extent permitted by law, FAB ADGM may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations; or
- surveillance of premises.
FAB ADGM processes your Personal Data for the performance of banking contract(s) to the extent relevant, compliance with applicable legal or regulatory obligations, FAB ADGM legitimate interests to provide you with adequate and qualitative products and services and to prevent against any excessive risk, and/or, in certain circumstances relies on your consent given for specific purposes in accordance with the DP Regulations.
Personal Data collected by FAB ADGM is usually necessary. If it is not provided, FAB ADGM will be unable to comply with its legal or regulatory obligations or to provide you with the requested products and services.
When how and with whom will we share your Personal Data:
We share your Personal Data with our own employees who have access to your Personal Data on a need-to-know basis for the performance of their duties. We may share your Personal Data with FAB PJSC to perform our obligations under our contract with you.
We may also share your Personal Data with our service providers involved in the provision of the information or services you have requested from us for lawful purposes in order to help us run our business. We rely on such trusted third parties for a range of our business operations and provision of services. We do not share your Personal Data with third parties for their own marketing purposes, except with your specific consent.
We may share your data with any of the parties mentioned below, if this is permissible under DP Regulations:
- Any court, regulatory body, or government authority to comply with any obligations and requirements issued by legal and regulatory authorities within the Kingdom.
- Any debt collection agency, credit bureau, or insurer.
- Any professional advisors (e.g. auditors and lawyers)
- Any agents, service providers and vendors and suppliers (e.g. IT suppliers)
- Any member of FAB PJSC or their service providers for the purpose of providing you with the products or services, enhancing our products, services, and your experience across our channels, and promoting new financial investment products and services that may be of interest to you and for the purposes of centralising our business operations.
We take extra care when we transfer or share information and will enter into suitable contracts with the third parties with whom we share your information, thus ensuring your confidentiality is maintained and your rights under the applicable law are upheld.
Transfers outside ADMG and how we protect your Personal Data when transferred
When you are in a banking relationship with a FAB office within the Abu Dhabi Global Market ("ADGM"), your Personal Data may be transferred to FAB PJSC in the UAE or any other jurisdiction outside the ADGM, for the purposes mentioned in the above section only or to their local service providers for support in the pursuance of such purposes.
We only transfer your information to organisations or jurisdictions outside the ADGM which, protect it in accordance with applicable laws and where:
- the Commissioner of Data Protection in the ADGM has decided that the country or the organisation we are sharing your information with will protect your information adequately;
- the transfer has been authorised by the relevant data protection authority; or
- in the absence of an adequacy decision or approval by the relevant data protection authority, we have entered into a contract with the organisation with which we are sharing your information based on standard contractual clauses or terms approved by the ADGM's Commissioner of Data Protection, to ensure your information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses, please contact us.
How and why do we retain your Personal Data
We will retain your Personal Data in a form which permits your identification for no longer than is necessary for the purposes for which the Personal Data is processed in line with legal, regulatory or statutory obligations.
At the expiry of such periods, your Personal Data will be deleted or archived in a secure manner to comply with legal retention obligations or in accordance with applicable statutory limitation periods. Retention periods for records are determined based on the type of record, the nature of the activity, product or service, applicable legal or regulatory requirements.
Retention periods may be changed from time to time based on business or legal and regulatory requirements. We may, by exception, retain information for longer, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators.
What are your right to your Personal Data
Under the DP Regulations, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information. You are not required to pay any charge for exercising your rights unless your request is unreasonable or excessive. We have up to two months to respond to you. If your request is complex or you make more than one, the response time may be extended to a maximum of three calendar months, starting from the day after receipt of your request. We shall inform you of any such extension or requirement of fee within one month of receipt of the request, together with the reasons.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that Personal Data is not disclosed to any person who has no right to receive it. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
Your data protection rights are highlighted below. You can submit a request in writing by contacting us at our address provided in this privacy policy.
Right of Access
You have the right to obtain from FAB ADGM, confirmation as to whether or not Personal Data concerning you is being processed, and, where that is the case, access to the Personal Data and the supplementary information that helps you to understand how and why we are using your data, and check that we are doing it lawfully. We shall provide a copy of the Personal Data undergoing processing. For any further copies requested, please note that FAB ADGM may charge a reasonable fee based on administrative costs.
Right to Rectification
You shall have the right to obtain from FAB ADGM without undue delay the rectification of inaccurate or incomplete Personal Data concerning you.
Right to Erasure
Except in very specific cases where provided by law, you have the right to obtain from FAB ADGM the erasure of Personal Data concerning you without undue delay where one of the following grounds applies:
- the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you withdraw your consent on which the processing is based and there is no other legal ground for the processing;
- you object to the processing and there are no overriding legitimate grounds for the processing;
- the Personal Data have been unlawfully processed; and
- the Personal Data have to be erased for compliance with a legal obligation to which FAB ADGM is subject.
Right to Restriction of Processing
You have rights to ‘block’ or suppress further use of your information where one of the following applies:
- you contest the accuracy of your Personal Data (in such a case, the restriction will be for a period enabling FAB ADGM to verify the accuracy of said data);
- the processing is unlawful and you request that your Personal Data is restricted rather than erased;
- FAB ADGM no longer needs the Personal Data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; and you object to processing pending the verification of whether the legitimate grounds of the controller override those of the data subject.
Right to Data Portability
You have the right to receive or to transmit those data to another controller in a structured, commonly used and machine-readable format, the Personal Data concerning you that you have provided to FAB ADGM , without hindrance from FAB ADGM , where the processing is based on your consent or on a contract and the processing is carried out by automated means.
Right to object to the Processing of your Personal Data
You have the right to object, on grounds relating to your particular situation, at any time to processing of Personal Data concerning you. FAB ADGM shall no longer process said Personal Data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. You can object to our use of your Personal Data for direct marketing purposes, including profiling.
Right to object being subject to a decision based solely on automated processing, including profiling
Decisions based solely on automated decision-making is not applicable for FAB ADGM customers.
Right to withdraw consent (Opt-Out)
You can withdraw consent for any processing that we do based on your consent in relation to your Personal Data. If you withdraw your consent, it will not affect the lawfulness of any processing of your Personal Data we conducted based on your consent prior to you withdrawing that consent. This includes your right to withdraw consent to us using your personal information for marketing purposes.
You are entitled to lodge a complaint about the way we handle or process your personal information with ADGM Commissioner of Data Protection.
How do we protect your Personal Data
The security and confidentiality of your Personal Data is important to us and FAB ADGM has invested significant resources to protect the safekeeping and confidentiality of your Personal Data. When using external service providers acting as processors, we require that they adhere to the same standards as FAB ADGM. Regardless of where your personal information is transferred, we take all steps reasonably necessary to ensure that Personal Data is kept secure.
Using FAB ADGM social media channels
FAB ADGM operates channels, pages and accounts on some social media sites to inform, assist and engage with customers. FAB ADGM monitors and records comments and posts made on these channels about FAB ADGM in order to improve its products and services.
Please note that you must not communicate withal ADGM through such social media sites the following information:
- confidential Personal Data, including any information regarding your financial situation, bank account details, transactions, etc;
- sensitive Personal Data including (i) special categories of Personal Data meaning any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation and (ii) other sensitive Personal Data such as criminal convictions and offences or related security measures; and
- excessive, inappropriate, offensive or insulting information towards individuals.
FAB ADGM is not responsible for any information posted on those sites other than the information posted by its employees on its behalf. FAB ADGM is only responsible for its own use of the Personal Data received through such sites.
Use of Cookies on FAB Website
In order to improve our customers’ experience, FAB Websites use a standard technology called "cookies" to collect information about how our websites are used, which may include your personal data. The use of cookies is essential to the operation of FAB Websites. For more information about our use of cookies please refer to our cookie policy which is available here: Cookie Declaration | First Abu Dhabi Bank (FAB) - UAE (bankfab.com).
Cookies help to make a website or app function better and make it easier for us to give you a better user experience on our online channels. To use or store cookie types that are not required for the functioning of the website or app and are optional, we will obtain your consent first.
For this reason, we limit our use of cookies to:
- providing products and services that you request;
- delivering advertising through marketing communications;
- providing you with a better online experience and tracking website performance; and
- helping us make our website more relevant to you.
Changes to this Privacy Policy
FAB ADGM may in its absolute discretion update this policy from time to time. We keep our privacy policy under regular review to make sure it is up to date and accurate. This privacy policy was last updated in September 2024 Any significant changes to our privacy policy will be communicated to the affected individuals using the most suitable channel including e-mails or post.
Communicating with us
If you have any questions regarding this privacy policy, the protection of your Personal Data, would like the privacy information to be provided verbally, would like more information about the way in which we use your personal information, wish to complain or would like to withdraw consent to any processing we do on your data based on consent, or to exercise your data protection rights, please contact us at this address:
First Abu Dhabi Bank ADGM
Unit 1, 7th Floor, Al Sarab Tower
Abu Dhabi Global Market Square
Al Maryah Island
United Arab Emirates
Email: ADGMprivacy@bankfab.com
Disclaimer
This Privacy Policy is not intended to, nor does it, create any contractual rights whatsoever or any other legal rights, nor does it create any obligations on us in respect of any other party or on behalf of any party. When you log in to third parties’ websites, you will not be subject to or under this Privacy Policy. Moreover, we are not responsible for their websites’ content and we do not represent third parties. Therefore, when you leave the FAB Websites, we recommend you to review the privacy and security policy of each website you visit.