Privacy Notice

Last Updated: 12 October 2020

Data Privacy Notice

Bahrain Development Bank B.S.C. (c) (hereafter referred to as “we” or “our” or “us” or “BDB” or “organisation” or “organization”) respects your right to data privacy. In this Notice “You” or “Your” refers to data subject (customers, employees, website visitors or contingent workers) whose personal data is processed by BDB.

This privacy notice explains who we are, how we collect, share and use personal data about you, and how you can exercise your data privacy rights. The details on what personal data will be processed and which method will be used depend significantly on the services applied for or agreed upon.

Definitions

1. Consent: Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal/ sensitive personal data relating to him or her.

2. Data Protection Officer (DPO): A person who, either alone or jointly with other persons, determine the purposes and means of processing any particular personal data; except that where the purposes and means of the processing of personal data are determined by law, the person entrusted with the processing obligation is deemed for the purposes of this Law to be the Data Controller.

3. Data Subject: The natural person, legal person or individual subject of data.

4. Data Protection Guardian: The independent/ external person/ entity licensed by the Authority who shall be responsible to implement the provision of the Law.

5. Personal Data: Any information relating to a data subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that data subject. This may also include photographs and/or video footage taken during events or for a specific purpose.

6. Sensitive Personal Data: Data that reveals your racial or ethnic origin, religious, political or philosophical beliefs or trade union membership; genetic data; biometric data for the purposes of unique identification; or data concerning your health.

7. Processing: Processing is any operation or set of operations which is performed on personal/ sensitive personal data or on sets of personal/ sensitive personal data, whether or not by automated means, such as collection, recording, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

8. Data Processor: a person, other than an employee of the DPO or data processor, who processes personal/ sensitive personal data for the DPO’s benefit and on the DPO’s behalf.

9. Third Party: Any person other than:

   • Data subject;
   • DPO;
   • Data processor;
   • Data protection guardian; and
   • Any person, under the direct authority of the DPO or data processor, authorized to process data for the benefit of DPO or data processor

10. Contingent Workers: Contingent workers means non-permanent workers including agents, consultants, independent contractors, sub-contractors, temporary workers, professional advisors, interns, trainees and those affiliated with third parties.

11. Joint Controller: Where two or more controllers jointly determine the purposes and means of processing, they shall be joint controllers.

12. Group Company (Group): includes a holding company, subsidiary, associate company (including a joint venture company) and a subsidiary of a holding company to which the company is also a subsidiary.

13. Direct Marketing: Communication, by whatever means, of any marketing material or advertisement which is directed to a person.

14. Authority: the Ministry of Justice, Islamic Affairs and Waqf (as confirmed by Decree No.78 for the year 2019 issued by His Majesty King Hamad Bin Isa Al Khalifa on 30 September 2019) as the official Independent Authority with the full powers and functions promulgated by Law No. (30) of 2018 with respect to Personal Data Protection Law including monitoring and enacting compliance within Bahrain

When do we collect your personal data?

Direct interactions

You may give us your identity, contact, resume or KYC related information by filling in forms or by corresponding with us by phone SMS, and email or otherwise. This includes sharing of personal data for the following purpose:

1. Records of your interactions with us such as emails and other correspondence and your instructions to us;

2. Providing your feedback;

3. By filling in forms, for example to download white papers and/or gather insights on case studies;

4. By sharing your personal data such as resume for recruitment purpose;

5. By interacting with us on social media platforms such as Facebook, Instagram, Twitter, and LinkedIn, and others.

6. Requesting information regarding our products or services;

7. Subscribing to our services, publications or newsletters;

8. Request marketing material notifications to be sent to you;

9. By sending us emails and text messages (SMS);

10. By adding posts, reviews and other comments to our website; and

11. By liking or disliking our offers and promotions;

Automated technologies or interactions

Log Files.

Log information is data about your use of the Service, such as IP (Internet Protocol) address, browser type, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.

Cookies

A cookie is a small data file transferred to your computer (or other device) when it is used to access our service. Cookies may be used for many purposes, including to enable certain features of our service and remember your preferences, your equipment, browsing actions and patterns, to better understand how you interact with our service, and to monitor usage by visitors and online traffic routing. You may be able to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the online services you visit. If you do not accept cookies, however, you may not be able to use all portions of our Service or all functionality of our website.

Please see our cookie notice for further details.

Cookies Notice

This Notice explains how BDB uses cookies in the web pages of our website (“Website”). It explains what these cookies are and why we use them.

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used to do different jobs, like letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience. If you visit our website, we will deploy these technologies to provide an online service more suited to the device you connect from, as well as to for administrative purposes and to enhance your online experience by keeping track of your behavior within the site. We collect information about your use of this site, information about the device or browser you use to access etc.

Why do we use cookies?

We use a limited number of cookies for several reasons as listed in this notice. Some cookies are required for technical reasons in order for our Websites to operate or for administrative purposes and to enhance your online experience by keeping track of your behavior within the site.

We classify our cookies as:

1. Strictly Necessary:

These cookies are essential, as they help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies and cannot be switched off in our systems.

2. Functional Cookies:

These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Links to other websites

When using our website, you may be directed to other websites. These websites may use their own cookies. We do not have control over the placement of cookies by other websites you visit, even if you are directed to them from our website. If you access those other websites please read any cookie privacy notices on those websites if you wish to know what cookies are being used.

How can I control cookies?

You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still access the landing page of the website but any functionality after login will be unusable. As the means by which you can refuse cookies through your web browser controls vary from browser to browser, you should visit your browser’s help menu for more information.

Cookies Collected in the Past

Collection of your data from our cookies can be deleted. You can delete existing cookies from your browser. If cookies are deleted, the information collected prior to the preference change may still be used, however, we will stop using the disabled cookie to collect any further information from your user experience

How often will you update this Cookie Notice?

We reserve the right to make any changes and corrections to this notice from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Therefore, re-visit this notice regularly to stay informed about our use of cookies and related technologies. The date at the top of this Notice indicates when it was last updated.

Where can you get further information?

You can at any time change or withdraw your consent from cookies notice, as explained in section “how can I control cookies”. To learn more about who we are, how we process personal data using cookies you can contact our DPO at dp@bdb-bh.com

Third parties or publicly available sources

We may receive aggregated personal data about you from various third parties, via public domains such as:

• Technical Data from the following parties:

  • Analytics providers such as Google, Facebook etc.;

  • Social media platforms such as Facebook, Twitter, Instagram, LinkedIn etc.

• Personal data gathered from publicly available directories/ registers are processed fairly, lawfully with adequate level of security and are not excessive in relation to the purpose for which they are collected.

What personal data do we collect?

We may collect, store, and use the following categories of personal data about you:

Identity Data

1. First name
2. Last name
3. Username
4. System generated unique ID
5. Date of Birth
6. Gender
7. Identity Card details
8. Driving license
9. Photographs

Financial Data

1. Bank account number
2. Name as per bank account
3. Copy of cancelled cheque

Contact Data

1. Email address
2. Telephone numbers/ contact number
3. Address

Transaction Data

Details about payments to and from you and other details of products and services you have obtained from us.These include:

1. Any relevant addresses.

Technical Data

1. This statement applies to the BDB’s website www.bdb-bh.com and describes our policy in relation to the processing of personal information (such as your name, address, email address and/or phone number). Other websites that may be linked to the BDB website are not covered by this Privacy Notice.
2. The BDB website does not automatically capture or store personal information about you, other than logging your IP address (the protocol which allows data to be transmitted between two connections to the internet) and session information such as the duration of your visit and the type of browser used. This information is purely used for system administration and is established to produce statistical reports that enable us to evaluate the use of our site.
3. We do not use cookies to collect information about you.
4. You will be asked to provide personal information if you wish to apply through any of our services. This information will only be used for the purpose of addressing the specific request.

Profile Data

1. Your interests, preferences, feedback and survey responses;
2. Profile image; and
3. Information about you (mentioned in resume including qualifications).

Usage Data

1. Information about how you use our website, products and services; and
2. Information on what you view, click on access by way of our emails and text messages, website and mobile.

Corporate Communications data

We may ask you to leave a review or take a survey for providing you better services. We may also collect your personal data for responding to your queries and comments, social media posts and questions/ queries. If you would like to opt-out/ unsubscribe from marketing or promotional communications from BDB, you can do so by reaching out to our Corporate Communication Department at: communication@bdb-bh.com

Aggregated Data (sometimes referred to as pseudonymised data)

We also collect, use and share aggregated data (sometimes referred to as pseudonymized data) such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in the applicable law (s) as this data does 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 data privacy notice.

Sensitive Personal Data or Special Category of Personal Data

We do not collect, store and use the following “special categories” of sensitive personal data regarding you such as:

1. Information about your race or ethnicity, religious beliefs and sexual status;
2. Information about your health, including any medical condition, health and sickness records, medical records and health professional information;
3. Any criminal records information in relation to you, and
4. Biometric information about you, for example fingerprints, retina scans.

Our intent is not to collect or process any sensitive personal data about you, unless required by applicable laws. However, in certain circumstances, we may need to collect, or request your special category of personal data for employment related purposes via Resume shared, for example, data regarding your hobbies and preferences, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations.

How and why do we use your personal data?

We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:

1. The processing is necessary for reasons of substantial public interest, or for official purposes or requested for or by the police or governmental authorities on a lawful basis;
2. It is necessary for the establishment, exercise or defense of legal claims, for the purposes of carrying out the obligations and exercising our or your rights in the field of employment, social security and social protection law; or
3. Based on your explicit consent;
4. Where we need to perform the contract we have entered into with you;
5. 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;
6. Where processing is necessary in order to protect the vital interests of the data subject or of another natural person.

Legitimate Interest

1. 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;
2. 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;
3. 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 laws); and
4. We may also use your personal data in the following situations, which are likely to be rare:
   • Where we need to protect your interests (or someone else’s interests);
   • Where it is needed in the public interest or for official purposes.

Purpose/ activity, type of data and lawful basis for processing

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 base(s) 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.

However, we normally collect personal data from you only where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in the legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In certain cases, we may also have legal obligations to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another data subject.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.

If we ask you to provide any other personal data not described above, then the personal data we will ask you to provide, and the reasons why we ask you to provide the personal data, will be made clear to you at the point we collect your personal data.

However, we may also use your personal data for other purposes such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes where they are permitted by applicable laws.

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.

You will receive marketing communications from us if you have requested information from us or applied to our services or registered for an event/ promotion and, have not withdrawn your consent of receiving such information.

Third-party marketing

We shall get your explicit consent for sharing your personal data for any marketing activities carried out by our third party service providers. In such case, we shall provide you with an option to withdraw your consent from receiving such marketing promotions from our third party service providers.

Request to withdraw consent

At any point, if you wish to withdraw your consent to receive marketing/ promotional information from BDB, you can write an email to our Corporate Communication Department at communication@bdb-bh.com

Kindly note that this does not apply to personal data provided to us as a result of a product/ service subscription/ purchase, product/ service experience or other transactions.

Who do we share your personal data with?

On occasion we may have to share your personal data with the parties set out below for the purposes set out.

Group Entities/ Subsidiaries

We shall share your personal information with our parent/ group company/ entities for reporting purposes, having similar arrangements, to be able to provide you with the same service value and high quality experience for the services provided to you by us. It’s also the only way we can provide you with the best benefits.

External Third Parties

1. Regulators and other authorities: acting as processors or joint controllers based in Bahrain who require reporting of processing activities in certain circumstances.
2. With social media companies such as Facebook, Twitter, LinkedIn and others: who run promotions for us on their platforms;
3. Any new business partners: we may have over time, for example, in the event of a joint venture, reorganization, business merger or sale that affects us.
4. The police, local authorities, the courts and any other government authority: if they ask us to do so (but only if our doing so is lawful).
5. Other people who make a ‘data subject access request’: where we are required to do so by law.
6. We may also share the information we collect where we are legally obliged to do so, e.g. to comply with a court order.
7. Any social media posts or comments you send to us: (on BDB’s Facebook page, for instance) will be shared under the terms of the relevant social media platform (e.g. Facebook, Twitter and LinkedIn) on which they are written, and could be made public. Other people, not us, control these platforms. We are not responsible for this kind of sharing. Before you make any remarks or observations about anything, you should review the terms and conditions and privacy policies of the social media platforms you use. That way, you will understand how they will use your information, what information relating to you they will place in the public domain, and how you can stop them from doing so if you are unhappy about it. It is worth remembering too that any blog, review or other posts or comments you make about us, our products and services on any of our blogs, reviews or user community services will be shared with all other members of that service and the public at large. You should take extra care to ensure that any comments you make on these services, and on social media in general are fit to be read by the public, and are not offensive, insulting or defamatory. Ultimately, you are responsible for ensuring that any comments you make comply with any relevant policy on acceptable use of those services.
8. Third parties/ Data Processors: 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 notice. 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/ data processors 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/ third party agreements.

International Transfers

We may share your personal data within the Parent/ Group company on need to know basis with confidential obligation mentioned herein.

Some of our external third parties maybe based outside the Kingdom of Bahrain so their processing of your personal data could involve a transfer of data outside the Kingdom. Whenever we transfer your personal data out of the Kingdom, including cloud hosting, backup systems or data recovery sites, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• subject to prior approval from CBB; or
• the Authority; or
• with your consent; or
• to countries that have been deemed to provide an adequate level of protection for personal data and are whitelisted by the Authority.

Please contact us if you want further information on how we transfer your personal data out of the Kingdom.

A list of third countries and international organizations to whom personal data may be shared can be made available by contacting our DPO at dp@bdb-bh.com

How we protect your personal data?

We use appropriate technical and organizational measures to protect the personal data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.

A lot of the information we receive reaches us electronically, originating from your devices, and is then transmitted by your relevant telecoms network provider. Where it’s within our control, we put measures in place to ensure this ‘in flight’ data is as secure as it possibly can be.

In addition to encryption, we have implemented robust network security controls to help protect data in transit. Network security solutions like firewalls and / or network access control to secure the networks used to transmit data against malware attacks or intrusions.

We use secure means to communicate with you where appropriate, such as ‘https’ and other security and encryption protocols.

How long will we keep your personal data?

To make sure we meet our legal data protection and privacy obligations, we only hold on to your information for as long as we actually need it for the purposes we acquired it for in the first place. After that we will either delete it, mask it or anonymize it so that it cannot be linked back to you.

We retain personal data we process where we have legitimate interest, performance of the contract, vital interest of data subject or of another natural person, performance of a task carried out in the public interest or in the exercise of official authority vested or for the purposes of satisfying any legal, accounting, or other regulatory reporting requirements or with your consent.

By law we have to keep basic information about our customers (including contact and identity data), BDB has documented and formalized the Privacy Notice in compliance with Kingdom of Bahrain Personal Data Protection Law No. 30 of year 2018.

Automated Decision Making

Automated decisions are decisions concerning you which are made automatically on the basis of a computer determination (using software algorithms), without human intervention. We do not use automated decision making.

What are your data protection rights?

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. You are obliged to inform BDB in writing of any change to personal data submitted by you to the Bank. You may contact your account officer or visit our branches to submit your updates.

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

1. 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.
2. Request rectification: Of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. We may need to verify the accuracy of any new data you provide to us.
3. 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 exercised your right to object to processing, 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.
4. 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. 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 means we can continue to process your personal data.
5. Request the 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; or
   • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Right to 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.
7. Right to lodge a complaint with the Authority: In case you consider that the processing of your personal data infringes any of your rights or provisions related to the laws and regulations in scope.

Time limit to respond

We try to respond to all legitimate requests within 15 business days. Occasionally, it may 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.

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 the information (or to exercise any of your other rights). This is another appropriate 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. If you wish to exercise any of the rights set out above, please contact us at dp@bdb-bh.com

Indemnity and Limitation of Liability

You agree to defend, indemnify and hold harmless BDB, its officers, directors and employees from and against any and all claims, liabilities, damages, losses or expenses, including settlement amounts and reasonable legal fees and costs, arising out of or in any way connected with your misuse of this site and causing it harm in any way.

Although BDB shall make every attempt to keep the Website free from viruses, it cannot guarantee that it is virus/ malware free. For your own protection, you should take necessary steps to implement appropriate security measures and utilize a virus scanner before downloading any information from the website.

BDB, its directors and employees, shall not be liable in any manner whatsoever for any direct, indirect, incidental, consequential, or punitive damage resulting from the use of, access of, or inability to use the information available on the Website or the services provided by us. BDB, its directors and employees shall not be liable in any way for possible errors or omissions in the contents in the Website.

Intellectual Property Rights

All information on this website is protected by copyright and other intellectual property rights. No images, text or other content from this website may be distributed or reproduced without the prior written approval from BDB.

Changes to this data privacy notice

We may update this data privacy notice from time to time in response to emerging legal, technical, contractual, regulatory or business developments. When we update our data privacy notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any privacy notice changes if and when this is required by applicable laws.

You can see when this privacy notice was last updated by checking the “last updated” date displayed at the top of this privacy notice.

If you have any questions or concerns about this privacy notice, please contact the DPO at dp@bdb-bh.com