HBTF Data Privacy Notice

Housing Bank for Trade and Finance - Bahrain Branch (hereafter referred to as "we" or “our” or "us" or “HBTF” or “organization”) is committed to protect your data privacy rights. In this Notice “You” or “Your” shall mean any data subject, including without limitation, customers, employees, website visitors, and contingent workers, whose personal data is processed, stored, or otherwise handled by HBTF.

This privacy notice outlines who we are, the way we collect, disclose, and process your personal data about you, and the ways in which you may exercise your data protection and privacy rights. The type, extent, and method of processing will depend on the specific services you have requested, applied for, or otherwise agreed to receive from HBTF. The Bank processes Personal Data in strict compliance with the Bahrain Personal Data Protection Law (Law No. 30 of 2018), applicable regulatory requirements issued by the Central Bank of Bahrain, applicable banking secrecy obligations, and all other relevant laws, regulations, and regulatory requirements governing the financial services sector.

Definitions

Data Subject - The person or individual subject of data.

Personal Data - Data or Personal Data is any information in any form concerning an identified individual (applies to customers, employees, vendors, subcontractors, or any stakeholders with whom the organization has a business relationship), being identified by reference, in particular, to his or her personal identification number, name, personal identification number, addresses, contact numbers, license numbers, records, personal property, bank account and credit card numbers, fixed or moving pictures of the individual, online identifier, or by reference to one or more factors specific to his or her physical, physiological, intellectual, cultural, economic, Email addresses, biometric identifiers (fingerprint, facial scan), and signatures or social identity.

In determining whether an individual is identifiable, due consideration shall be given to all the means reasonable to the organization whether directly or indirectly, that could be used to identify such individual.

Data Subject Right

• Right to access
• Right to rectification
• Right to withdraw consent
• Right to erasure
• Right to restriction of processing
• Right to objection
• Right to data portability

Processing - Processing means any operation or set of operations performed upon personal data by the organization or its representatives, whether by automatic means, including collecting, recording, organizing, classifying, storing, adapting, altering, retrieving, using, disclosing by transmission, dissemination, transference or otherwise making available for others, or combining, blocking, erasing, or destroying such data.

Special Category / Sensitive Personal Data - Personal data that may reveal directly or indirectly - an individual’s race, ethnic origin, political or philosophical opinions, religious beliefs, union affiliation, personal criminal record and security data, biometric data, genetic data, credit data, location data, and data that indicates whether both parents of an individual or one of them is unknown or any information related to their health or sexual condition.

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

Data Controller – Housing Bank for Trade and Finance – Bahrain Branch or its employees representing the organization who, determines the purposes and means of processing personal data which the organization processes.

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 entities (including a joint venture company) and a subsidiary of a holding entity to which the entity is also a subsidiary.

If you have any questions or concerns about our Processing of your Personal Data, then please contact us at [DPG@hbtf.com.jo].

When do we collect your Personal Data?

Direct interactions

You may provide us your identity, contact, and resume by filling out forms or by corresponding with us by phone, and email or otherwise. This includes sharing of personal data for the following purposes:

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 and LinkedIn etc.
6. By subscribing to our newsletter on our website or other online medium/channel

Automated technologies or interactions

 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 deployed for a variety of legitimate business and operational 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, to provide you advertising on and off the 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 service. 

Please see our cookie policy for further details.

Third parties or publicly available sources

We may receive aggregated Personal Data about you from various third parties as mentioned below:

• Technical Data from the following parties:

What Personal Data do we collect?

We may collect, store, and use the following categories of Personal Data about you:

Identity Data

1. Full name
2. Resume

Contact Data

1. Email address
2. Telephone numbers/ contact number

Technical Data

1. Internet protocol (IP) address;
2. We also track how often you visit and use our website. We do this via email and website cookies and similar tracking technology built into our website. Please see our cookie policyfor further details.

Profile Data

1. Your interests, preferences, feedback and survey responses;
2. Profile image;
3. About (mentioned in resume);

 Usage Data

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

Marketing and Communications data

We do not collect Personal Data for marketing purposes. However, HBTF may process limited categories of Personal Data for legitimate business purposes, including service-related communications, responding to your queries, feedback, comments, and for the purpose of conducting your satisfaction surveys or requesting service reviews in order to enhance service quality and your experience.

Where permitted under applicable laws and regulations, HBTF may also process limited Personal Data for the purpose of providing information relating to HBTF’s products or services, strictly subject to applicable legal and regulatory requirements, including obtaining any required consent and providing appropriate opt out mechanisms in accordance with applicable data protection laws and regulatory requirements. If you wish to opt out of, or unsubscribe from, receiving marketing or promotional communications from HBTF, you may do so at any time by using the unsubscribe option included in the relevant communication or by contacting HBTF through the designated communication channels.

Aggregated Data (sometimes referred to a 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 under 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 in a way that 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 orientation;
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 Special Category of Personal Data relating to you, except where such collection is required or permitted by applicable laws and regulations. However, in certain circumstances, HBTF may need to collect, or request certain 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.

Purposes for which HBTF collect and process 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 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 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).
4. We may also use your Personal Data in the following situations, which are likely to be rare:
5. Where we need to protect your interests (or someone else's interests);
6. 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 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. Where relevant, we have also identified the legitimate interests pursued by HBTF.

Note that HBTF 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 obtained your valid 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.

In some circumstances, more than one legal basis may apply to HBTF’s processing of your Personal Data.

Where HBTF requests that you provide any additional Personal Data not described above, HBTF will, at the point of collection, clearly notify you of the specific categories of Personal Data requested and the purposes for which such Data is required, in accordance with applicable data protection laws and regulatory requirements. However, we may also use your personal data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable laws.

Change of purpose

We will process your Personal Data solely for the purposes for which it was originally collected, unless we reasonably consider that further processing is necessary for additional purposes that is compatible with the original purpose, and is permitted under applicable laws and regulatory requirements.

If we need to process your Personal Data for a purpose that is not compatible with the original purpose of collection, we will notify you and will explain the applicable legal basis that permits such processing.

If you wish to obtain further explanation regarding the manner in which processing for the new purpose is assessed as being compatible with the original purpose, please contact us using the contact details provided.

Who do we share your Personal Data with?

On occasion we may be required to disclose, share, or otherwise make available your Personal Data to the parties set out below for the purposes set out.

Internal Third Parties

Different branches within the Bank. For example, we’ll share information from our website at https://hbtf.bh/en  with the internal third parties, having similar arrangements between our other businesses. This is because we hope to have a relationship with you across all our businesses, if not now, then sometime in the future and we want to be able to provide you with the same value for money 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 and LinkedIn: who run promotions for you on their platforms;
3. Any new business partners: we may have overtime, 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 the HBTF 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: 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 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.

International Transfers

We share your Personal Data within the Group on need-to-know basis with confidential obligations mentioned herein. This may involve transferring your data outside the country of business.

Some of our external third parties are based outside the country and so their Processing of your Personal Data will involve a transfer of data outside the country of business. Whenever we transfer your Personal Data out of the country of business, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will transfer your Personal Data only to countries that have been formally recognized as providing an adequate level of protection for Personal Data and are approved or 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 organization to whom Personal Data may be shared can be made available by contacting our Data Protection Guardian (DPG) at [DPG@hbtf.com.jo].

How we protect your Personal Data?

We implement and maintain appropriate technical and organizational security measures to protect the Personal Data that we collect and process. The measures are designed to ensure a level of security that is appropriate to the risk of Processing your Personal Data.

A significant portion of the information we received is transmitted electronically from your devices via telecommunications networks. To the extent such transmission falls within our control, we put measures in place to ensure this 'in flight' data is protected against unauthorized access.

Sensitive data are protected through encryption during transmission. In addition to encryption, HBTF maintains robust network security measures designated to protect data in transit, including, the use of firewalls, network access controls, and other security to ensure the protection of the networks against malware attacks or intrusions.

We also use secure means to communicate with you where appropriate, including 'https' and other security standards 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 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) for 10 years after they cease being customers for legal purposes.   

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. Please keep us informed if your Personal Data changes by keeping your details up to date on our website and by sharing your updated details with our Data Protection Guardian (DPG) at [DPG@hbtf.com.jo].

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 for 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 to continue processing 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 for erasure due to 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 situation which makes you want to object to Processing on this ground. You also have the right to object where we process your Personal Data for direct marketing purposes. In certain circumstances, we may demonstrate that we have compelling legitimate grounds to continue processing your personal data which overrides your rights and freedoms.
5. Request the restriction of the Processing of your Personal Data: This enables you to request that we suspend the processing of your Personal Data under the following circumstances:
   1. if you want us to establish the data's accuracy;
   2. where our use of the data is unlawful, but you do not want us to erase it;

• where you require us to retain the data even if we no longer need it, as you require it to establish, exercise or defend legal claims; or

1. where you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to continue using it. 

1. Request the portability of your Personal Data to another party: We will provide your personal data to you, or to a third party designated by you have, in a structured, commonly used, and machine-readable format. Please note that this right applies only to information process by automated means where you have provided consent for us to process such data, or where the processing is necessary for the performance of a contract with you. 
2. Right to withdraw consent at any time: Where we rely on your consent to process your Personal Data, you have the right to withdraw such consent at any time. However, this will not affect the lawfulness of any processing carried out period to the withdrawal of your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will inform you if this is the case at the time you withdraw your consent.
3. Right to lodge a complaint with the Authority: You have the right to lodge a complaint with the competent authority if you believe that the processing of your Personal Data infringes your rights or violates applicable data protection laws and regulations.

Fees for excessive or unreasonable requests

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Time limit to respond 

We aim to respond to all legitimate requests within 10 days. In certain cases this may take longer particularly when a request is complex, or multiple requests have been submitted. In such cases, 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 you have 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 regarding your request to speed up our response.

If you wish to exercise any of the rights set out above, please contact us at [DPG@hbtf.com.jo]. 

Indemnity and Limitation of Liability

You agree to defend, indemnify and hold harmless HBTF, 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 access to or use of this site.

HBTF, its officers, 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 to, or inability to use the information available on the website or the services provided by the organization. HBTF, its officers, directors and employees, shall not be liable in any way for possible errors or omissions in the contents of the website.

Intellectual Property Rights

All information contained on this website is protected by copyright and other intellectual property rights. No images, text or other content from this website may be copied, distributed, reproduced, or otherwise used, in whole or in part, without prior written approval from the organization.

Changes to this data privacy notice

We may update this data privacy notice from time to time in response to reflect changes in legal, technical, contractual, regulatory or business developments. When we make updates, we will take appropriate steps to inform you, considering the nature and significance of the changes. Where required by applicable laws and regulations, we will obtain your consent prior to implementing any material changes to this privacy notice.

You can find out 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 about this Privacy Notice, please contact us [DPG@hbtf.com.jo].

In addition, we shall promptly assess any Personal Data breach and, where required by applicable laws and regulations, notify the competent Personal Data Protection Authority without undue delay and within 72 hours of becoming aware of the breach. Where the breach is likely to result in a high risk to affected individuals, HBTF will also notify the Data Subjects concerned and take appropriate measures to mitigate its impact.