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.
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.
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.
Data Subject: The natural person, legal person or individual subject of data.
Data Protection Guardian: The independent/ external person/ entity licensed by the Authority who shall be responsible to implement the provision of the Law.
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.
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.
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.
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.
Third Party: Any person other than:
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.
Joint Controller: Where two or more controllers jointly determine the purposes and means of processing, they shall be joint controllers.
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.
Direct Marketing: Communication, by whatever means, of any marketing material or advertisement which is directed to a person.
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
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:
Records of your interactions with us such as emails and other correspondence and your instructions to us;
Providing your feedback;
By filling in forms, for example to download white papers and/or gather insights on case studies;
By sharing your personal data such as resume for recruitment purpose;
By interacting with us on social media platforms such as Facebook, Instagram, Twitter, and LinkedIn, and others.
Requesting information regarding our products or services;
Subscribing to our services, publications or newsletters;
Request marketing material notifications to be sent to you;
By sending us emails and text messages (SMS);
By adding posts, reviews and other comments to our website; and
By liking or disliking our offers and promotions;
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.
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.
We may collect, store, and use the following categories of personal data about you:
Details about payments to and from you and other details of products and services you have obtained from us.These include:
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: (mailto:firstname.lastname@example.org)
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.
We do not collect, store and use the following “special categories” of sensitive personal data regarding you such as:
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.
We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:
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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|a) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||a) Identityb) Contactc) Technical||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 reorganization or group restructuring exercise)b) Necessary to comply with a legal obligation|
|a) To use data analytics gathered from our website to improve our website, products/services, marketing, customer relationships and experiences||a) Technicalb) Usagec) Aggregated Data||a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant)|
|a) To make suggestions and recommendations to you about goods or services that may be of interest to you||a) Identityb) Contactc) Technicald) Usagee) Profilef) Aggregated Data||a) Necessary for our legitimate interests (to develop our products/services)|
|a) To power our security measures and services in order to protect you and our business||a) Identityb) Technicalc) Usage||a) Necessary for our legitimate interest so you can safely access our website|
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.
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 (mailto:email@example.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
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:
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 (mailto:firstname.lastname@example.org)
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:
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 (mailto:email@example.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 (mailto:firstname.lastname@example.org)
Last Updated: 09 Jun 2021
Licensed by the Central Bank of Bahrain as a Conventional Retail Bank
Last Updated: 17 May 2022