Introduction

First Abu Dhabi Bank France (“FAB France”) as a branch of First Abu Dhabi Bank PJSC is committed to providing the highest level of protection regarding the processing of its customers’ personal data based on applicable data protection laws and regulations.

This policy describes how FAB France may collect, use, store, disclose or otherwise process your personal data including personal data provided when using our websites (“FAB Websites”).

Personal data comprises all the details that FAB France collects and processes directly or indirectly about you as individual client or representative of a corporate client, for instance information about your identity and contact details (such as name, email id, contact number), your transactions, your financial information, interactions or dealings with FAB France, including information received from third parties and information collected through use of FAB Websites, cookies or other similar tools and our electronic banking services.

The use of the FAB Websites and any products and services supplied are subject to our Terms and Conditions.

If you have any questions regarding this data protection policy or the protection of your personal data, please contact FAB France’s Data Protection Officer and data protection team at the following:

Data Protection Officer France
10 rue Magellan,
75008, Paris, France.
Email: dpofabfrance@bankfab.com

FAB France may process your Personal Data as an individual client or a representative of a corporate client for the following purposes for the performance of the banking contract(s) concluded with you as an individual client:

• Processing applications for products and services, including assessing customer suitability and performing necessary checks and risk assessments;
• Providing products and services (including electronic banking services), including effecting payments, transactions and completing instructions or requests;
• Establishing and managing banking relationships and accounts.

FAB France also processes your personal data for the following purposes for compliance with applicable legal or regulatory obligations:

• Preventing, detecting, investigating and prosecuting crimes (including but not limited to money laundering, terrorism, fraud and other financial crimes) in any jurisdiction, identity verification, government sanctions screening and due diligence checks;
• Complying with applicable local or foreign law, regulation, policy, voluntary codes, directive, judgement or court order from any authority, regulator or enforcement agency or body or any request coming from said entities;
• Surveillance of premises.

The following processing are based on FAB France legitimate interests to provide you with adequate and qualitative products and services and to prevent against any excessive risk:

• Establishing, exercising or defending legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice in relation to such legal proceedings;
• Monitoring and improving our website and its content;
• Conducting market research and surveys with the aim of improving our products and services.

The following processing is based on your consent:

• Sending you information about our products and services for marketing purposes and promotions.

Personal data requested by FAB France are adequate, relevant and limited to what is necessary for the purposes for which they are processed. If it is not provided, FAB France will be unable to comply with its legal or regulatory obligations or to provide you with the requested products and services.

Your personal data processed by FAB France will only be accessible by a limited list of recipients authorized by executive management on a need-to-know basis or where required by law:

• Employees of the business line(s) concerned by the products and services provided;
• Employees of the compliance department concerned;
• Employees of the accounting department concerned;
• Employees of the IT department(s) concerned;
• Employees of selected service providers who support FAB in the provision of adequate and qualitative products and services.

When you are in a banking relationship with a FAB France, your personal data may be transferred to FAB PJSC in United Arab Emirates or any other FAB branches located outside the EEA for the purposes mentioned above only or to their local service providers for support in the pursuance of such purposes.

FAB PJSC in Abu Dhabi also acts as a service provider for its branches, in particular for the provision of IT services. Transfers to FAB PJSC outside the EEA are covered by standard data protection clauses. You may request and receive a copy of such documents to the following address: dpofabfrance@bankfab.com

Our policy does not apply to third-party websites where our online advertisements are displayed, nor to linked third-party websites which we do not operate or control.

Your personal data processed by FAB are kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed in line with legal, regulatory or statutory obligations.

At the expiry of such periods, your personal data will be deleted or archived to comply with legal retention obligations or in accordance with applicable statutory limitation periods.

To the extent permitted by law, FAB France may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations. This may include the recording of telephone conversations.

Subject to applicable law, regulations and/or banking industry guidelines, you may have the right to invoke a data subject right in relation to your personal data being processed by FAB France.

FAB France may be allowed by law, in particular in case of excessive or manifestly unfounded request, to charge a fee for fulfilling your request, subject to applicable conditions. The rights that you can invoke as a data subject can be:

1- Right of Access

You have the right to obtain from FAB France, confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and the following information:

• The purposes of the processing;
• The categories of personal data concerned;
• The recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine this period;
• The existence of the right to request from FAB France rectification or erasure of your personal data or restriction of the processing of such data or to object to such processing;
• The right to lodge a complaint with a supervisory authority;
• The existence of automated decision-making, including profiling, and meaningful information about the logic involved; and
• Where applicable, the transfer of personal outside EEA and appropriate safeguards implemented.

FAB France shall provide a copy of the personal data undergoing processing. For any further copies requested, please note that FAB France may charge a reasonable fee based on administrative costs.

2- Right to Rectification

You shall have the right to obtain from FAB France without undue delay the rectification of inaccurate personal data concerning you.

3- Right to Erasure

Except in very specific cases where provided by law, you have the right to obtain from FAB France the erasure of personal data concerning you without undue delay where one of the following grounds applies:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• the withdrawal of your consent on which the processing is based and there is no other legal ground for the processing;
• the objection to the processing and there are no overriding legitimate grounds for the processing;
• the personal data have been unlawfully processed;
• the personal data have to be erased for compliance with a legal obligation to which FAB France is subject;
• the personal data have been collected in relation to the offer of information society services directly to a child.

4- Right to Restriction of Processing

You have the right to obtain from FAB France restriction of processing where one of the following applies:

• you contest the accuracy of your personal data (in such a case, the restriction will be for a period enabling FAB France to verify the accuracy of said data); the processing is unlawful;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• FAB France no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
• you object to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

5- Right to Data Portability

You have the right to receive or to transmit those data to another controller in a structured, commonly used and machine-readable format, the personal data concerning you that you have provided to FAB France, without hindrance from FAB France, where the processing is based on your consent or on a contract and the processing is carried out by automated means.

6- Right to Object to the Processing

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you when it is based on FAB France’s legitimate interests. FAB France shall no longer process said personal data unless it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Such right can be exercised at any time where your personal data is processed for direct marketing purposes.

7- Right to object being subject to a decision based solely on automated processing, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except in specific cases provided by law.

8- Right to define post-mortem directives

You have the right to formulate specific and general directives concerning the storage, erasure and communication of post-mortem data concerning you. Regarding the general directives, they must be addressed to a third party who will be designated by decree.

FAB France shall provide information on action taken on a request pertaining to the rights above without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. FAB France shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay.

To invoke your data subject rights, please use the send an email or a postal mail to data protection officer (see contact details above).

Finally, note that you are entitled to lodge a complaint with a competent Data Protection Authority where existing, concerning FAB France’s compliance with the applicable data protection laws and regulation.

The security and confidentiality of your Personal Data is important to FAB France has invested significant resources to protect the safekeeping and confidentiality of your personal data. When using external service providers acting as processors, we require that they adhere to the same standards as FAB France. Regardless of where your personal information is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure.