We're committed to safeguarding your privacy and personal information
FAB Private Bank (Suisse) SA (‘FAB Suisse’) as a subsidiary of First Abu Dhabi Bank PJSC (‘FAB PJSC’) is committed to providing the highest level of protection regarding the processing of its clients’ personal data based on applicable data protection laws and regulations.
Please also refer to our General Terms and Conditions, which can be found on the FAB Suisse website (www.fabsuisse.ch).
The information we collect about you and from where
Personal data comprises all the details that FAB Suisse, if applicable with FAB PJSC, collects and processes directly or indirectly, including information received from third parties (credit reference and fraud prevention agencies, public sources of information, etc.), about you as individual client or representative of a corporate client, in particular the following data:
For prospective clients and prospective job applicants, we collect (to the extent permitted by applicable law):
- personal identification details (such as name, address, gender, nationality), contact information (such as telephone, e-mail address), and family details (such as marital status);
- information related to the professional profile (such as directorship / positions and professional networks) and information related to company ownership and financial background;
For current and former clients or prospective clients with whom we enter into a business relationship or not, we collect (to the extent permitted by applicable law):
- personal details such as your name, identification number, date of birth, compliance related documents (including a copy of your national identity card, passport or residency permit), phone number, address and domicile, electronic address, and family details such as the name of your spouse, partner or children;
- financial information, including payment and transaction records and information relating to your assets (including fixed properties), financial statements, liabilities, taxes, revenues, earnings and investments (including your investment objectives);
- tax domicile and other tax-related documents and information;
- where relevant, professional information about you, such as your job title and work experience;
- your knowledge of and experience in investment matters;
- any emails or records of phone calls between you and FAB Suisse, specifically phone log information such as your phone number, calling-party number, receiving-party number, forwarding numbers, time and date of calls and messages, duration of calls, routing information, and types of calls;
- where relevant, details of your nomination of a mandate; and
- information collected through use of FAB Websites, cookies or other similar tools and our electronic banking services.
Controllers contact details
Data Protection Team,
FAB Private Bank (Suisse) SA
5 Quai de l’Ile, PO Box,
CH 1211 Geneva, Switzerland
For more information about using of cookies please refer to FAB Suisse’s Cookie Declaration which can be found on our website.
Purposes of Processing Personal Data
FAB Suisse may process your personal data for the following purposes in the context of the performance of precontractual or contractual measures concluded with FAB Suisse:
- Processing applications for products and services, including assessing client 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;
- 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, as well as event organization;
- Preventing, detecting and investigating 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 from any authority, regulator or enforcement agency or body or any request coming from said entities, to the extent permitted by law;
- 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 Suisse 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;
- Surveillance of premises;
- Pre-litigation and litigation, namely 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;
- Management of the exercise of their data-processing rights and freedoms formulated by the data subjects;
- Ensuring the security of information systems, and consequently preventing, detecting and avoiding any data leakage, sometimes through cookies.
FAB Suisse processes your personal data for the performance of the banking contract(s), compliance with applicable legal or regulatory obligations or FAB Suisse legitimate interests in fulfilling the purposes mentioned above and to provide you with adequate and qualitative products and services and to prevent against any excessive risk.
Personal data requested by FAB Suisse are usually necessary. If it is not provided, FAB Suisse will be unable to comply with its legal or regulatory obligations or to provide you with the requested products and services.
Indirect collection of personal data
Certain personal data, namely nominative, financial and professional information, may be collected indirectly by FAB Suisse. Indeed, depending on the needs of the clients, it may be transmitted by other branches or FAB PJSC to which the client would have initially addressed himself/herself. These categories of data may also, if need be, be collected from public data sources, where available.
Who your personal information may be shared with
Within FAB Suisse, access to your data is granted only to personnel requiring it for the fulfilment of contractual and legal obligations towards you (need-to-know principle).
Your data might be also process by employees of selected Swiss based service providers and suppliers, who support FAB Suisse in the provision of adequate and qualitative products and services. If the service providers concerned need to process your data on behalf of FAB Suisse, data protection compliant contracts are in place with the related suppliers and service providers. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will hold it securely, retain it for the period we instruct, and implement the organisational and technological measures required to protect your data. For example, companies in the areas of IT (e.g. data hosting and processing, IT development, support, and operation), administration of financial instruments and other financial assets (e.g. payments, processing of transactions and services, reporting and output services), services related to trading, execution, and processing of financial instruments and other financial assets, financing and credit services, as well as other back- and middle office activities, etc.
Outside FAB Suisse, your personal information is only forwarded by FAB Suisse
- if you have given an express consent (secrecy waiver) through agreements you have concluded with FAB Suisse;
- if there is a legal requirement (for example, under a court order or based on AML regulations);
- if this is required for the execution of your orders (e.g. for payment and securities).
Subject to these conditions, recipients of personal data can include, amongst others:
- credit and financial services institutions, professional advisers and consultants to which FAB Suisse transfers personal data within the context of its business relationship with you (e.g. correspondent banks, custodian banks, brokers, stock exchanges, or information agencies);
- public bodies and institutions (e.g. the Swiss National Bank, FINMA or law enforcement authorities) in the event of a statutory or official obligation;
- other data recipients for which you have expressly given your consent;
- other companies of FAB PJSC, for risk management purposes as a result of legal or regulatory obligations;
- service providers and other agents appointed by the FAB Suisse, who are contractually bound to confidentiality, such as IT hardware, software and outsourcing providers, logistics, mail, courier, printing services and storage providers, and others. FAB Suisse takes all the necessary steps to ensure that those providers meet our data security standards, so that your personal data remains secure.
Transfers outside Switzerland and safeguards
When you are in a banking relationship with FAB Suisse, your personal data may be transferred to FAB PJSC in the UAE, Saudi Arabia or Singapore only when you have given an express consent (secrecy waiver) such as when you opted to have a relationship manager in the UAE, Saudi Arabia or Singapore handle your account, or if you have requested a credit and data needs to be shared with the credit team in the UAE to monitor the consolidated Group wise exposure.
We have entered into a contract with FAB PJSC based on standard contractual clauses or terms approved by the Swiss Federal Data Protection authorities, to ensure your information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses, please contact us.
Finally, we may transfer relevant elements of your personal data to countries within the EEA or to the UK provided that such countries continue to provide for an adequate level of data protection according to the assessment of the competent authority.
Retention of Personal Information
Your personal data processed by FAB Suisse are kept in a form which permits your identification for 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 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.
Your Data Protection Rights
Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information. We have generally one month to respond to you. If your request is complex or you make more than one, the response time may be extended and this extension and the reason would be explained to you. We shall inform you of any such extension or requirement of fee within one month of receipt of the request, together with the reasons. FAB Suisse may be allowed by law, in particular in case of excessive or manifestly unfounded request, to charge a fee for fulfilling the request of the client, subject to applicable conditions.
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 verbally or in writing, please use the contact details stated earlier.
Right of Access - You have the right to obtain from FAB Suisse, 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 (purposes of the processing, categories of personal data concerned, recipients, envisaged period will be stored, etc.), and check that we are doing it lawfully.
FAB shall provide a copy of the personal data undergoing processing.
Right to Rectification - You shall have the right to obtain from FAB Suisse 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 Suisse 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;
- the personal data have to be erased for compliance with a legal obligation to which FAB is subject;
Right to Restriction of Processing - You have the right to obtain from FAB Suisse 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 Suisse to verify the accuracy of said data); the processing is unlawful;
- FAB Suisse 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 the legitimate grounds of the controller override those of the data subject.
- the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
If you exercise your right to restriction, FAB Suisse will no longer be able to process your personal data, unless:
- you have given the consent;
- for the establishment, exercise or defense of legal claims,
- for the protection of the rights of another natural or legal person,
- for important reasons of public interest of Switzerland.
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 Suisse, without hindrance from FAB Suisse, 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 - You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you. FAB Suisse 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.
Such right can be exercised at any time where the client’s personal data is processed for direct marketing purposes.
Right to object being subject to a decision based solely on automated processing, including profiling - You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except in specific cases provided by law.
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.
Security of your data
The security and confidentiality of your Personal Data is important to us and FAB Suisse 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 Suisse. 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 Suisse and FAB PJSC operates channels, pages and accounts on some social media sites to inform, assist and engage with clients. 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 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 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.
Your use of the FAB Suisse website
Complaints / Regulatory Authority
If you believe that our processing of your Data contradicts the applicable data protection laws, you have the possibility to lodge a complaint with the appropriate data protection authority.
The data protection authority for FAB Suisse is the Swiss Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Berne, Switzerland (https://www.edoeb.admin.ch). Based on your residence, you may have the possibility to lodge a complaint with the appropriate data protection authority of your place of residence.
FAB Suisse may in its absolute discretion update this policy from time to time.