First Abu Dhabi Bank PJSC (“FAB” or “we”) are committed to providing the highest level of protection regarding the processing of their customers’ personal data based on applicable data protection laws and regulations.
This policy describes how FAB’s head office in the United Arab Emirates (UAE) and its UAE branches may collect, use, store, disclose or otherwise process your personal data, including in the context of your application for, or use of, one or more of our products or services, or when you use the UAE version of our website (“Website”). It applies to you whenever you use the Website including if you are an individual client or a representative of a corporate client (including former, current and prospective clients).
Personal data comprises all the information that FAB collects and processes about you that can identify you directly or indirectly, including information received from third parties and information collected through use of the Website, cookies or other similar technology and our electronic banking services.
More specifically, the personal data FAB collects or processes about you may include:
- Identifying information
including your name, date of birth, place of birth, nationality, country of residence, country of tax domicile, passport number, residency permit details, tax identification details, passport details, and photo;
- Our interactions with you
including any records of phone calls between you and FAB, and logs of related information including your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls;
- Identifiers FAB assigns to you
such as your client, business relation, partner, or account number;
- Contact information
including postal address, telephone number, email address and mobile number;
- Family information
including marital status and details of any dependants;
- Financial information
including information about your financial circumstances and source of wealth, details of personal assets, bank account numbers, spending, income and credit bureau reports from relevant authorities;
- Professional information
including details of your employer, your education and career history, and business interests; and
- Website technical data
including your IP address used to access the Website, 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 the Website.
FAB Data Protection Team
First Abu Dhabi Bank
Abu Dhabi, United Arab Emirates
Processing Personal Data
FAB may process your personal data for the following purposes:
- Processing 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 the 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
- Marketing and promotion, conducted with or without the support of third parties engaged by the Bank
- Remaining competitive as well as developing and improving our products and services
- 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 request by any authority, regulator or enforcement agency or body in respect of any member of the FAB group
- 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
- Surveillance of premises and ATMs
FAB processes your personal data for the performance of the banking contract(s) concluded with you as an individual client, compliance with applicable legal or regulatory obligations or FAB legitimate interests to provide you with adequate and qualitative products and services and to prevent against any excessive risk.
FAB processes your personal data for the performance of the banking contract(s) concluded with you as an individual client or a representative of a corporate client, compliance with applicable legal or regulatory obligations or to provide you with adequate and qualitative products and services and to prevent against any excessive risk. FAB processes your personal data based on your consent. Personal data requested by FAB is usually necessary for the provision of a service or product to you or for your use of the Website. If your personal data is not provided, FAB may be unable to comply with its legal or regulatory obligations or to provide you with the requested products and services. When providing your data is necessary for the provision of a service or product, FAB will inform you of that and the consequences of failing to provide it.
You have the right to withdraw your consent to the use of your personal data at any time through the methods communicated by FAB through its various communication channels from time to time. Your withdrawal of consent will come into effect within 30 days from the receipt of the withdrawal request, but will not affect the lawfulness of any personal data processing that occurred prior to such withdrawal coming into effect (for example, if a credit check is run at the start of your contract) or any subsequent processing related to FAB’s business operations.
Access to Personal Data
Your personal data processed by FAB will be kept confidential and will only be accessed on a need-to-know basis or where required by law, regulation or court orders by our employees involved in the provision of the products and services concerned, and third parties such as service providers involved in the provision of our products and services, other financial institutions, financial intermediaries, regulatory and governmental authorities and our professional advisors. FAB notifies you from time to time which third parties may access your personal data, including in information given to you in the context of forms you complete when you apply for our products or services. For more information, please also see clause 30 of FAB's General Terms and Conditions for Accounts.
Retention of Personal Information
Your personal data processed by FAB are retained by FAB in a form which permits your identification for a minimum of 5 years from the end of our business relationship (or closing of your account) or completion of the relevant transaction (if we have no business relationship with you) but no longer than is necessary for the purposes for which the personal data are processed in line with legal, regulatory or statutory obligations.
At the expiry of such periods, your personal data will be deleted or securely archived to comply with legal retention obligations or in accordance with applicable statutory limitation periods.
To the extent permitted by law, we 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.
Subject to applicable law, regulations and/or banking industry guidelines, you may be entitled to invoke a data subject’s right in relation to your personal data being processed by FAB.
The rights that you can invoke as a data subject may include:
- Right of Access
You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, ask us for copies of your personal information. For any further copies requested, please note that we may charge a reasonable fee based on administrative costs.
- Right to Rectification
You have the right to obtain from FAB without undue delay the rectification of inaccurate personal data concerning you.
- Right to Request Erasure
Subject to compliance with the applicable mandatory retention periods, you have the right to request from FAB the erasure of personal data concerning you where (a) the personal data is no longer necessary for FAB’s business operations (including offering you the financial services or products) or (b) you withdraw your consent to the processing of your personal data and there is no other ground for the processing.
- Right to Restriction of Processing
You have the right to obtain from FAB restriction of processing 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 to verify the accuracy of said data) or the processing is unlawful;
- FAB 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;
- you object to processing pending the verification whether FAB’s legitimate grounds override those of the data subject.
- Right to Transfer Data
You have the right to the transfer of your personal data to another financial institution or financial service provider, upon your request and where the processing is based on your consent.
- Right to Object to the Processing
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you. FAB shall no longer process said personal data except where such personal data is required for business operations related to the products or services offered to you.
Any future withdrawal of consent will not affect the lawfulness of personal data processing prior to such withdrawal (for example, if a credit check is run at the start of your contract) or any subsequent processing related to FAB’s business operations.
Such right can be exercised at any time where your personal data is processed for direct marketing purposes.
To invoke your data subject rights, please send an email to FAB’s data protection officer (see contact details above).
The security and confidentiality of your personal data is important to us and FAB 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. Regardless of where your personal information is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure.
FAB operates channels, pages and accounts on some social media sites to inform, assist and engage with customers. FAB monitors and records comments and posts made on these channels about FAB in order to improve its products and services.
Please note that you must not communicate to FAB through such social media sites the following types of 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, or trade union membership, 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 and national identification number;
- excessive, inappropriate, offensive or insulting information towards individuals.
FAB is not responsible for any information posted on those sites other than the information posted by its employees on its behalf. FAB is only responsible for its own use of the personal data received through such sites.