Data Privacy Notice

Emirates National Bank of Dubai S.A.E, (referred to as “we”, “us”, “our” or “Emirates NBD” in this Data Privacy Notice) primarily refers to all the Personal Data that is collected and used about Emirates NBD Customers for the purposes of the CBE circular dated 19^th of February 2019. Emirates National Bank of Dubai S.A.E is part of the Emirates NBD Group.

Emirates NBD is registered in plot 85 Banks’ zone s. teseen st. fifth settlement, New cairo, Cairo, Egypt.

This Data Privacy Notice describes the Personal Data Emirates NBD collect, how it is used and shared, and your choices regarding this data. Emirates NBD is the Data Controller for the Personal Data collected in connection with the use of Emirates NBD Services.

SCOPE

This Data Privacy Notice applies to all Customers of Emirates NBD Services, including Customers of Emirates NBD’s mobile application, websites, and other banking Services (collectively, the “Services”) and through other interactions and communications you may have with us. This Notice specifically applies to:

Customers: individuals who hold accounts with Emirates NBD.
Non-Customers: representatives of account holders such as delegated / authorised persons.
Prospective customers: individuals and/ or their representatives who requested doing business with Emirates NBD either in their persons or in their capacity as representatives of legal person.
Users of our digital channels: individuals who use our websites, mobile applications, and other digital channels.
This notice also governs Emirates NBD’s other collection of Personal Data in connection with its Services.

Emirates NBD’s most important asset is you and your trust. Emirates NBD are committed to providing you with exceptional banking Services and want you to have confidence in the way Emirates NBD use your Personal Data. Emirates NBD is committed to protecting your privacy and your Personal Data.

Further this Notice explains the various measures Emirates NBD have in place to protect the security of your Personal Data.

CONFIDENTIALITY OF PERSONAL DATA

When Emirates NBD collects Personal Data, Emirates NBD provides a safe, secure, and confidential environment in all our delivery Channels to ensure that your Personal Data remains private and used for the purposes for which it is obtained and held.

Emirates NBD has a legal obligation to keep your data confidential, however, Emirates NBD may disclose your data to a third party where:

Emirates NBD is legally obliged to do so. In circumstances where the disclosure of your data is imposed by a legal and/or regulatory authority, including but not limited to courts.
In circumstances where the disclosure is made with your express consent or through a representative nominated by you.

UNDERSTANDING PERSONAL DATA AND PROCESSING

Personal Data and Processing have very specific meanings. It is important that you understand these terms.

What is Personal Data?

Personal Data as per the Applicable Laws means, any data which relates to a living individual who can be identified directly or indirectly from that data. The definition includes a wide range of personal identifiers that constitute Personal Data, including but not limited to:

Identification information (e.g., name, date of birth, government-issued ID)
Contact information (e.g., address, email address, phone number)
Financial information (e.g., account numbers, transaction history, credit score reports)
Employment information (e.g., occupation, employer)
Demographic information (e.g., gender, marital status)

What is Processing?

Processing means doing anything with Personal Data, e.g. viewing, collecting, using, storing, sharing, manipulating, printing, copying, archiving etc.

Processing activity means any task that involves doing anything with Personal Data.

PERSONAL DATA EMIRATES NBD COLLECTS ABOUT YOU

Personal Data That You Provide To Us

Emirates NBD collects Personal Data directly from you as our Customer or Prospective Customer. Emirates NBD collects information you provide directly to us through your access or use of Emirates NBD Products and Services. For example, when you apply for a product or Service on our website(s), by telephone or when you enter an Emirates NBD premises and share/provide Personal Data with one of Emirates NBD’s employees.

Personal Data Emirates NBD Collects About You From Other Sources

Emirates NBD may collect Personal Data about you from other sources such as, but not limited to the following:

Beneficiaries of your payment transactions.
Co-borrowers / guarantors.
Credit Bureaus or credit reporting agencies.
Criminal records check from organisations authorised to provide this data.
Digital identity solutions.
Government databases.
Law enforcement officials.
Legal representatives (power of attorney) of a client.
Nominated contact person by an existing account holder.
Other Emirates NBD Groups.
People appointed to act on your behalf.
Reference contacts provided in the application form by you.
Representative(s) of a corporate client.
Third party providers and partners to help us improve the Personal Data Emirates NBD hold and to provide more relevant and interesting products and Services to you.
Your employer.

Personal Data Emirates NBD May Collect About Other Individuals

In certain circumstances, Emirates NBD may be provided Personal Data from you about individuals who do not have a direct relationship with us. This may happen, for instance, when you provide us with Personal Data about:

Beneficiaries of your payment transactions.
Beneficiary IBAN validation IBAN & beneficiary names.
Co-borrowers / guarantors.
Employers of Emirates NBD Customers.
Landlords.
Legal representatives (power of attorney) of a client.
Next of Kin
Reference contacts provided in the application Representative(s) of a corporate client.
Shareholder(s)/Director(s) of a corporate client.
Spouses
Successors and right holders.
Ultimate beneficial owners.
Form by an Emirates NBD (prospective) Customer.

USE OF YOUR PESONAL DATA

Personal Data includes information that Emirates NBD collect and process about you depending on the products or Services you obtain or receive.

The below is a non-exhaustive list which highlights some, but not all, examples of categories of Personal Data Emirates NBD collect about you:

Category	Description	Example
Account Management	Used to administer your account with Emirates NBD. Used to identify you when you sign-in to your account. Used to provide you with Services, and to fulfil your requests for certain products and Services.	To enable Emirates NBD to process your data for the sole purpose of administering your relationship with the Bank.
Account Opening	Used for the setup and management of Customer accounts, including meeting the regulatory requirements such as KYC (Know Your Customer) process.	To enable Customers to create an Account, log in to your instance on the Emirates NBD App, or verify their credentials.
Analytics	Used to collect data about how Customers use the Emirates NBD App or how it performs. Used to understand how you use and interact with our Services and the people or things you’re connected to and interested in.	To see how many Customers are using a particular gesture, to monitor app health, to diagnose and fix bugs or crashes, or to make future performance improvements.
App Functionality	Used for Features that are Available in the App. Used to improve the design and functionality of Emirates NBD channels for a better Customer experience.	To enable app features, or to authenticate Customer.
Decline Onboarding	If your application is declined, Emirates NBD will store your Personal Data in accordance with the Emirates NBD record retention procedures and to comply with Emirates NBD legal obligations.	To keep track of the reasons for the declining of Onboarding to be used as reference, if and when the Customer approaches the Bank again.
Developer Communications	Used to send news or notifications about the app or the developer.	Sending a push notification to inform Customers about an important security update.
Financial Mediations / Debt Recovery	Used to authorise debt Service partners to carry out collection activities on Emirates NBD behalf. Used to recover debt and exercise other rights Emirates NBD have under any agreement with Emirates NBD Customers as well as to protect Emirates NBD against harm to Emirates NBD rights and interests in property.	Partners of Emirates NBD engage with Customers who have defaulted, to settle their liabilities with Emirates NBD.
Fraud Prevention, Security and Compliance	Used for fraud prevention, security, or compliance with laws. Used to prevent and detect fraud, money laundering and other crimes such as identity theft.	Monitoring failed login attempts, geolocations, device information (e.g., model number, OS information), IP address, etc., to identify possible fraudulent activity.
General Correspondence	Personal Data you give to us by filling in any of Emirates NBD forms or by communicating with us, whether face-to-face, by phone, email, online, mobile, any other digital means or otherwise.	To contact you if you have asked us to do so including to resolve troubleshooting problems and helping with any issues concerning Emirates NBD website or apps.
Personalised Commercial and Promotional Communications (Marketing)	To send commercial and promotional communications through telematic or conventional means, in relation to similar goods and Services than the ones previously contracted or acquired from Emirates NBD. This also includes for the purpose of conducting market research and accompanying statistical analysis to better understand our Customer base and the markets in which we operate.	Emirates NBD sends Customers a promotional email or SMS relating to a Product or Service on offer.
Regulatory Requests	To handle requests and instructions from regulators, law enforcement Agencies, etc. that specific information about individuals.	To meet the legal and regulatory obligations Emirates NBD has, as a Licenced Financial Institution, governed by the CBE.
Satisfaction Surveys	To contact you for your opinions about Emirates NBD Services including through surveys and other market research.	Sending Customer satisfaction surveys.
Service Communications	Used to keep Customers informed of the products and Services they are availing of. Used to tell you about important updates and changes to Emirates NBD Channels, including to Emirates NBD Data Privacy Notice and other Policies and Terms.	Sending Customers reminders to update their Personal Data in the App such as their mobile number and home address.
Video Protection (CCTV)	Used at Emirates NBD premises and ATMs for security purposes.	To protect Emirates NBD Customers, employees, visitors, and its premises.

DISCLOSURE OF YOUR PERSONAL DATA BY US

Emirates NBD only discloses your Personal Data outside of Emirates NBD in limited circumstances and in accordance with CBE instructions. If Emirates NBD does share the Personal Data outside of Emirates NBD, we will put in place appropriate controls and data sharing/processing agreements that require recipients to protect your Personal Data, unless Emirates NBD is legally required to share that Personal Data. All contractors or recipients that work for Emirates NBD will be contractually obliged to follow Emirates NBD instructions. Emirates NBD does not sell your Personal Data to third parties.

Emirates NBD may disclose your Personal Data to Emirates NBD third-party Service providers, agents, and subcontractors (Suppliers) for the purposes of providing Services to us or directly to you on Emirates NBD’s behalf.

When Emirates NBD uses Suppliers, Emirates NBD only discloses to them the Personal Data that is necessary to provide their Services and only where Emirates NBD has a contract in place which requires them to keep your Personal Data secure and not to use it other than in accordance with Emirates NBD’s specific instructions.

Emirates NBD take steps to ensure that any third-party service providers who handle your Personal Data comply with the Applicable Laws and protect your Personal Data to the same extent that Emirates NBD does. Emirates NBD will aim to anonymise your Personal Data or use aggregated non-specific data sets where possible.

CHILDRENS DATA

Emirates NBD websites, mobile and apps and any other digital means are intended for use only by persons who are at least 21 years of age. If you are under the age of 21, your parent or guardian must consent on your behalf where Emirates NBD asks for consent in relation to the use of your Personal Data.

AUTOMATED PROCESSING

The way Emirates NBD analyses Personal Data relating to Emirates NBD Services may involve (according to the applicable laws and regulations) profiling or other automated methods to make decisions about you that relate to the following:

Credit and affordability checks (including credit limits) - Emirates NBD will consider several factors including information about your income, expenses and how well you have kept up on payments in the past.
Anti-money laundering, combatting the financing of terrorism, sanctions checks, KYC validations (including through national identity systems) and screening ‘politically exposed’ people.
Monitoring your account for fraud and other financial crime -Emirates NBD will assess your transactions to identify any that are unusual.
Assessments required by regulators and appropriate authorities - certain details in your information may suggest that you are likely to become financially vulnerable and Emirates NBD may need to help you.
Identifying customers for specific campaigns and offers.

IS IT OBLIGATORY OR VOLUNTARY FOR ME TO PROVIDE MY PERSONAL DATA

Emirates NBD needs your Personal Data to provide you with the Services or products requested by you.

If you do not provide us with the requested Personal Data, Emirates NBD may have to decline your request for our Product(s) and/or Service(s), or if Emirates NBD is already providing you with the product(s) and Service(s), Emirates NBD may need to suspend or stop providing you with the product(s) or Service(s), which can lead to closure of your banking relationship with us, subject to compliance with Emirates NBD’s legal obligations to retain data.

MARKETING

It is voluntary for you to provide us your Personal Data or consent for direct sales or marketing purposes.

Emirates NBD makes it clear on the Emirates NBD physical application forms, during your onboarding digitally and on all communications received from the Bank as to what data is required to be provided by you by marking the mandatory fields with the asterisk symbol (*).

You can object to further marketing at any time by:

Calling Emirates NBD Customer Call Centre on +216664
Changing Emirates NBD marketing preferences in your Emirates NBD Application account.
Sending an email to egydpo@emiratesnbd.com.

Emirates NBD collects Personal Data about your internet activity using technology known as cookies, which can often be controlled through internet browsers and by using Emirates NBD cookie preference centre on the Emirates NBD website.

Technical information, such as your IP address and device ID.
Information about your visit, such as your URL and website interaction.
Location data, with your approval, used to show you the location of the nearest branch or ATM based on your IP address, coordinates or a unique device code.
Networks and connections, when you interact with us and the people and groups that you are connected to (for example, through social media).

WHAT ARE YOUR RIGHTS

You have certain rights in respect of your Personal Data, and Emirates NBD have processes to enable you to exercise these rights. Your rights are as follows:

Opt Out/Unsubscribe: You can request to be removed from the Emirates NBD marketing mailing list, from the unsubscribe button in the email itself. We have other channels to request removal as well, such as calling the customer care centre and sending SMS to the designated number communicated to you as part of the marketing content.
Right to Rectification: You have the right to request for your Personal Data to be amended or rectified where it is inaccurate (for example, if you change your name, contact details or address) and to have incomplete Personal Data completed.
Right to Lodge a Complaint with a Supervisory Authority: Emirates NBD sincerely hope that you will never need to, but if you do want to complain about our use of Personal Data, please use the contact details set out below.

Please note, all rights are subject to qualifications and limitations. In other words, there may be instances and justifiable grounds to deny any request where Emirates NBD are required or permitted by law to do so. Emirates NBD will always be clear and communicate this to you if these instances arise.

Also note, for the purpose of upholding the security, confidentiality, and integrity of your Personal Data, Emirates NBD may verify your identity before allowing you to access your Personal Data.

Emirates NBD reserves the right to request a fee for the facilitation of any of the above rights.

UNDERSTANDING PERSONAL DATA AND PROCESSING

Personal Data and Processing have very specific meanings. It is important that you understand these terms.

What is Personal Data?

Identification information (e.g., name, date of birth, government-issued ID)
Contact information (e.g., address, email address, phone number)
Financial information (e.g., account numbers, transaction history, credit score reports)
Employment information (e.g., occupation, employer)
Demographic information (e.g., gender, marital status)

What is Processing?

Processing means doing anything with Personal Data, e.g. viewing, collecting, using, storing, sharing, manipulating, printing, copying, archiving etc.

Processing activity means any task that involves doing anything with Personal Data.

PERSONAL DATA EMIRATES NBD COLLECTS ABOUT YOU

Personal Data That You Provide To Us

Personal Data Emirates NBD Collects About You From Other Sources

Emirates NBD may collect Personal Data about you from other sources such as, but not limited to the following:

Beneficiaries of your payment transactions.
Co-borrowers / guarantors.
Credit Bureaus or credit reporting agencies.
Criminal records check from organisations authorised to provide this data.
Digital identity solutions.
Government databases.
Law enforcement officials.
Legal representatives (power of attorney) of a client.
Nominated contact person by an existing account holder.
Other Emirates NBD Groups.
People appointed to act on your behalf.
Reference contacts provided in the application form by you.
Representative(s) of a corporate client.
Third party providers and partners to help us improve the Personal Data Emirates NBD hold and to provide more relevant and interesting products and Services to you.
Your employer.

Personal Data Emirates NBD May Collect About Other Individuals

Beneficiaries of your payment transactions.
Beneficiary IBAN validation IBAN & beneficiary names.
Co-borrowers / guarantors.
Employers of Emirates NBD Customers.
Landlords.
Legal representatives (power of attorney) of a client.
Next of Kin
Reference contacts provided in the application Representative(s) of a corporate client.
Shareholder(s)/Director(s) of a corporate client.
Spouses
Successors and right holders.
Ultimate beneficial owners.
Form by an Emirates NBD (prospective) Customer.

USE OF YOUR PESONAL DATA

Personal Data includes information that Emirates NBD collect and process about you depending on the products or Services you obtain or receive.

The below is a non-exhaustive list which highlights some, but not all, examples of categories of Personal Data Emirates NBD collect about you:

Category	Description	Example
Account Management	Used to administer your account with Emirates NBD. Used to identify you when you sign-in to your account. Used to provide you with Services, and to fulfil your requests for certain products and Services.	To enable Emirates NBD to process your data for the sole purpose of administering your relationship with the Bank.
Account Opening	Used for the setup and management of Customer accounts, including meeting the regulatory requirements such as KYC (Know Your Customer) process.	To enable Customers to create an Account, log in to your instance on the Emirates NBD App, or verify their credentials.
Analytics	Used to collect data about how Customers use the Emirates NBD App or how it performs. Used to understand how you use and interact with our Services and the people or things you’re connected to and interested in.	To see how many Customers are using a particular gesture, to monitor app health, to diagnose and fix bugs or crashes, or to make future performance improvements.
App Functionality	Used for Features that are Available in the App. Used to improve the design and functionality of Emirates NBD channels for a better Customer experience.	To enable app features, or to authenticate Customer.
Decline Onboarding	If your application is declined, Emirates NBD will store your Personal Data in accordance with the Emirates NBD record retention procedures and to comply with Emirates NBD legal obligations.	To keep track of the reasons for the declining of Onboarding to be used as reference, if and when the Customer approaches the Bank again.
Developer Communications	Used to send news or notifications about the app or the developer.	Sending a push notification to inform Customers about an important security update.
Financial Mediations / Debt Recovery	Used to authorise debt Service partners to carry out collection activities on Emirates NBD behalf. Used to recover debt and exercise other rights Emirates NBD have under any agreement with Emirates NBD Customers as well as to protect Emirates NBD against harm to Emirates NBD rights and interests in property.	Partners of Emirates NBD engage with Customers who have defaulted, to settle their liabilities with Emirates NBD.
Fraud Prevention, Security and Compliance	Used for fraud prevention, security, or compliance with laws. Used to prevent and detect fraud, money laundering and other crimes such as identity theft.	Monitoring failed login attempts, geolocations, device information (e.g., model number, OS information), IP address, etc., to identify possible fraudulent activity.
General Correspondence	Personal Data you give to us by filling in any of Emirates NBD forms or by communicating with us, whether face-to-face, by phone, email, online, mobile, any other digital means or otherwise.	To contact you if you have asked us to do so including to resolve troubleshooting problems and helping with any issues concerning Emirates NBD website or apps.
Personalised Commercial and Promotional Communications (Marketing)	To send commercial and promotional communications through telematic or conventional means, in relation to similar goods and Services than the ones previously contracted or acquired from Emirates NBD. This also includes for the purpose of conducting market research and accompanying statistical analysis to better understand our Customer base and the markets in which we operate.	Emirates NBD sends Customers a promotional email or SMS relating to a Product or Service on offer.
Regulatory Requests	To handle requests and instructions from regulators, law enforcement Agencies, etc. that specific information about individuals.	To meet the legal and regulatory obligations Emirates NBD has, as a Licenced Financial Institution, governed by the CBE.
Satisfaction Surveys	To contact you for your opinions about Emirates NBD Services including through surveys and other market research.	Sending Customer satisfaction surveys.
Service Communications	Used to keep Customers informed of the products and Services they are availing of. Used to tell you about important updates and changes to Emirates NBD Channels, including to Emirates NBD Data Privacy Notice and other Policies and Terms.	Sending Customers reminders to update their Personal Data in the App such as their mobile number and home address.
Video Protection (CCTV)	Used at Emirates NBD premises and ATMs for security purposes.	To protect Emirates NBD Customers, employees, visitors, and its premises.

DISCLOSURE OF YOUR PERSONAL DATA BY US

CHILDRENS DATA

AUTOMATED PROCESSING

Credit and affordability checks (including credit limits) - Emirates NBD will consider several factors including information about your income, expenses and how well you have kept up on payments in the past.
Anti-money laundering, combatting the financing of terrorism, sanctions checks, KYC validations (including through national identity systems) and screening ‘politically exposed’ people.
Monitoring your account for fraud and other financial crime -Emirates NBD will assess your transactions to identify any that are unusual.
Assessments required by regulators and appropriate authorities - certain details in your information may suggest that you are likely to become financially vulnerable and Emirates NBD may need to help you.
Identifying customers for specific campaigns and offers.

IS IT OBLIGATORY OR VOLUNTARY FOR ME TO PROVIDE MY PERSONAL DATA

Emirates NBD needs your Personal Data to provide you with the Services or products requested by you.

MARKETING

It is voluntary for you to provide us your Personal Data or consent for direct sales or marketing purposes.

You can object to further marketing at any time by:

Calling Emirates NBD Customer Call Centre on +216664
Changing Emirates NBD marketing preferences in your Emirates NBD Application account.
Sending an email to egydpo@emiratesnbd.com.

Technical information, such as your IP address and device ID.
Information about your visit, such as your URL and website interaction.
Location data, with your approval, used to show you the location of the nearest branch or ATM based on your IP address, coordinates or a unique device code.
Networks and connections, when you interact with us and the people and groups that you are connected to (for example, through social media).

WHAT ARE YOUR RIGHTS

You have certain rights in respect of your Personal Data, and Emirates NBD have processes to enable you to exercise these rights. Your rights are as follows:

Opt Out/Unsubscribe: You can request to be removed from the Emirates NBD marketing mailing list, from the unsubscribe button in the email itself. We have other channels to request removal as well, such as calling the customer care centre and sending SMS to the designated number communicated to you as part of the marketing content.
Right to Rectification: You have the right to request for your Personal Data to be amended or rectified where it is inaccurate (for example, if you change your name, contact details or address) and to have incomplete Personal Data completed.
Right to Lodge a Complaint with a Supervisory Authority: Emirates NBD sincerely hope that you will never need to, but if you do want to complain about our use of Personal Data, please use the contact details set out below.

Also note, for the purpose of upholding the security, confidentiality, and integrity of your Personal Data, Emirates NBD may verify your identity before allowing you to access your Personal Data.

Emirates NBD reserves the right to request a fee for the facilitation of any of the above rights.

SECURITY

The Security of your Personal Data is important to us. We make every effort to ensure that your Personal Data is secure on our system. Emirates NBD has staff dedicated to maintaining the Emirates NBD security standards as set forth herein. Emirates NBD implements technical and organisational measures to ensure a level of security appropriate to the risk to the personal information Emirates NBD processes. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. Emirates NBD evaluates these measures on a regular basis to ensure the security of the processing.

Your Emirates NBD profile is password-protected so that only you and authorised Emirates NBD employees have access to your account information. Emirates NBD staff will never reach out to you and ask for any personal account information, including your passwords, pin number, one time password or any other secured details to access your data.

Emirates NBD make every effort to ensure that your Personal Data is secure on its system. Emirates NBD have staff dedicated to maintaining the Emirates NBD security standards as set forth herein. Emirates NBD implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information Emirates NBD process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. Emirates NBD evaluate these measures on a regular basis to ensure the security of the processing.

Unfortunately, you would appreciate that, no data transmission over the Internet can be fully guaranteed to be 100% secure. As a result, Emirates NBD cannot guarantee the security of any Personal Data you transmit to us, and you do so at your own risk. If you have any further questions on this issue, refer to the Emirates NBD Terms of Service.

Please contact the Emirates NBD Customer Service Helpdesk on +216664 in case you receive fraudulent emails or require any assistance with regards to our online banking Services.

EXTERNAL LINKS

The Emirates NBD website, mobile apps and other digital means may, from time to time, contain links to external sites. If you follow a link to any of these websites, please note that these websites have their own Data Privacy Notices. Please check these Notices before you submit any Personal Data to these websites. Emirates NBD is not responsible for the Data Privacy Notices, content of such sites or any Personal Data collected by such sites.

HOW LONG DOES EMIRATES NBD STORE YOUR DATA FOR?

Emirates NBD will keep your Personal Data for as long as Emirates NBD has a relationship with you and for meeting our legal, accounting or reporting requirements. Once the Emirates NBD relationship with you has come to an end, Emirates NBD will retain your Personal Data for a period that enables us to:

Maintain business records for analysis and/or audit purposes.
Comply with record retention requirements under the law.
Defend or bring any existing or potential legal claims.

Emirates NBD will delete/store with limited access and appropriate safeguards your Personal Data when it is no longer required for these purposes. If there is any information that Emirates NBD is unable, for technical reasons, to delete entirely from Emirates NBD systems, we will put in place appropriate measures to prevent any further processing or use of the data.

HOW TO CONTACT US?

If you are unsatisfied with the way your Personal Data is being processed, please raise a complaint by reaching out to egydpo@emiratesnbd.com.

If you would like to lodge a complaint to your local supervisory authority, please get in touch and Emirates NBD will provide you with instructions and contact details to your local supervisory authority.

If you would like to stop receiving marketing or promotional communications, please call at +216664 or unsubscribe through any of the communications received.

Emirates NBD are committed to working with you to obtain a fair resolution to any complaint or concern you may have. If, however, you believe that Emirates NBD have not been able to assist with your complaint or concern you have the right to make a complaint to the data protection authority of your country.

UPDATES TO THIS NOTICE

Emirates NBD may occasionally update this notice. If Emirates NBD make significant changes, Emirates NBD will notify Customer in advance of the changes through the Emirates NBD apps or through other means, such as email. Emirates NBD encourages Customers to periodically review this Data Privacy Notice for the latest information on the Emirates NBD data privacy practices.

Should you wish to contact us to discuss any questions, concerns, and comments you may have regarding your Personal Data that we process, please reach us through our contact details provided in section 21, “How to Contact Us” section of this Notice.

GLOSSARY OF TERMS AND DEFINITIONS

Term	Definition
Authority(ies)	Means legal, supervisory, regulatory, governmental, and quasi-governmental bodies such as the Centre, Central Bank of Egypt, fraud prevention agencies, tax authorities etc.
Automated Processing	Means Processing that is conducted using an electronic application or system that operates automatically, either independently without any human intervention or under the supervision and limited intervention of a human.
Biometric Data	Means Personal Data resulting from specific technical processing relating to the physical, physiological, and behavioural characteristics of the Data Subject, which allow the identification or confirm the unique identification of the Data Subject, such as facial recognition images.
Central Bank of Egypt (CBE)	Means the Central Bank of Egypt.
Consent	Means the Consent by which the Data Subject authorises Emirates NBD or third parties to process their Personal Data.
Consumer(s)	Means a Customer for the purpose of Central Bank of Egypt Consumer Protection Regulation and the accompanying Consumer Protection Standards. A Customer is any natural or juristic person who obtains Services and/or products directly from Emirates NBD, or indirectly through the outsourced Company.
Data Controller(s)	Means any natural or juristic person who has - by virtue of the nature of their activities - the right to obtain Personal Data and to specify the method and criteria of retaining, processing or controlling such data according to a specific purpose or to their activities.
Data Processor	Means any concerned natural or juristic person, by virtue of the nature of its work, to process Personal Data for its own benefit or on behalf of the Controller as agreed with and instructed by the Controller.
Data Subject(s)	Means any natural person to whom electronically processed personal data is attributed which identifies him/her legally or factually and enable his/her identification from any other person.
Data Transfer(s)	Means the transfer of data from one jurisdiction to another.
Destruction of Personal Data	Means the removal or deletion of Personal Data.
Egypt	Means the Arab Republic of Egypt.
Emirates NBD	Means Emirates NBD Bank S.A.E and any of its branches, successors, and assignees.
Encryption	Means the process of encoding information stored on a device and can add a further layer of security. It is considered an essential security measure where Personal Data is stored on a portable device or transmitted over a public network.
Know Your Customer or KYC	Means mandatory requirements to ensure updated information about Emirates NBD’s Customers, to perform identity verification and prevention of illegal transactions through the business relationship with Emirates NBD such as money-laundering, identity theft.
Personal Data	Means any data relating to an identified natural person, or one who can be identified directly or indirectly by way of linking such personal data and other data such as name, voice, picture, identification number, online identifier, or any data which determines the psychological, medical, economic, cultural, or social identity of a natural person.
Processing	Means any electronic or technological operation to write, collect, record, save, store, merge, display, send, receive, circulate, publish, erase, change, edit, retrieve, or analyze personal data using any electronic or technological medium whether partially or wholly.
Profiling	Means a form of Automated Processing consisting of the use of Personal Data to evaluate certain personal aspects relating to the Data Subject.
Pseudonymisation	Means the processing of Personal Data in such a manner that the Personal Data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the Personal Data are not attributed to an identified or identifiable natural person.
Sensitive Personal Data	Means data which discloses psychological, mental, or physical health, or genetic, biometric, or financial data, religious beliefs, political views, or criminal records. In all cases, data relating to children is considered to be sensitive personal data.
Staff	Means full time employees and contractors of Emirates NBD.
Subject Access Request	Means a request to receive a copy of one's data from an organisation in an accessible, readily available, and legible format. Such requests are limited to information that is specific and limited to that one individual.

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