This Policy explains how we may Process your Personal Data. This Policy may be amended or updated from time to time, so please check it regularly for updates.
This Policy is issued by Arab Finance, an Egyptian joint stock company, in accordance with Law no. 159 for the year 1981.
The Policy addressed to individuals outside our organization with whom we interact, including clients, representatives of client organizations, visitors to our Sites, users of our Apps, and other uses of our services (together, “you”). Defined terms used in this Policy are explained in Section (Q) below.
For the purposes of this Policy, all related entites to Arab Finance entities are considered Controllers. Contact details for any enquiries or other correspondences relating to this Policy are provided in Section (P) below.
This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make to the terms of this Policy.
Collection of Personal Data
We may collect or obtain Personal Data about you: (i) directly from you; (ii) in the course of our relationship with you; (iii) when you make your Personal Data public; (iv) when you download, install, or use any of our Apps; (v) when you visit our Sites; (vi) when you register to use any of our services; or (vii) when you interact with any third party content or advertising on our Site or App. We may also receive Personal Date about you from third parties.
Creation of Personal Date We may create Personal Data about you through your interaction with us.
Categories of Personal Data we may Process We may Process: (i) your personal details; (ii) demographic data; (iii) your contact details; (iv) matter details; (v) records of your consents to our Processing of your Personal Data; (vi) payment details; (vii) information about your use of our Sites and Apps; (viii) information about your interactions with our content or advertising; and (ix) any views or opinions you provide to us.
Sensitive Personal Data Where we need to Process your Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.
We may have to Process your Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:
-Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law;
-Detection and Prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
-Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; or
-Consent: We may Process your Sensitive Personal Data where have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is not used in relation to processing that we are legally required to carry out).
Purposes of Processing and legal basis for Processing We Process Personal Data for the following purposes: providing our Sites, Apps, and services to you; compliance checks; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigating where necessary; compliance with applicable law; improving our Sites, Apps, and services; fraud prevention; and recruitment and dealing with job applications.
The purposes for which we Process Personal Data, subject to applicable law, and the legal basis on which we perform such Processing, are as follows:
Processing activity
Legal basis for Processing
Provision of Sites, Apps, and services: providing our Sites, Apps, or services; providing promotional items and information upon request; and communicating with you in relation to those Sites, Apps, or services
The Processing is necessary in connection with any consent that you have entered into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, Apps, and services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary- it is not used for Processing that is necessary or obligatory).
Compliance checks: fulfilling our regulatory compliance obligations; ‘Know Your Client’ checks; and confirming and verifying your identity; use of credit reference agencies; and screening against government and/ or law enforcement agency sanctions list and other legal restrictions
The Processing is necessary for compliance with a legal obligation; or The Processing is necessary in connection with any contract you have entered into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of fulfilling our regulatory and compliance obligations (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary- it is not used for Processing that is necessary or obligatory).
Operating our business: operating and managing our Sites, our Apps, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, our Apps, or our services; and notifying you of changes to any of our Sites, our Apps, or services.
The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, our Apps, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing.
Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; maintaining and updating your contact information where appropriate; obtaining your prior opt- in consent where required; and recording telephone calls, meetings, depositions, and other interactions in which you are involved, in accordance with applicable law.
The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the Purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing.
Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring such systems.
The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations.
The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or The Processing is necessary to protect the vital interests of any individual.
Financial management: sales; finance; corporate audit; and vendor management.
We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing.
Surveys: engaging with you for the purposes of obtaining your views on our Sites, our Apps, or our services.
We have a legitimate interest in carrying for the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing.
Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security.
The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises.
Investigations: gathering analysis and collating evidence and materials; creating and maintaining recordings of telephone calls, meetings, and other interactions, in accordance with applicable law; and detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Legal compliance: compliance with all our legal and regulatory obligations under applicable law.
The Processing is necessary for compliance with a legal obligation.
Improving our Sites, Apps, and services: identifying issues with our Sites, our Apps, or our services; planning improvements to our Sites, our Apps, or our services; and creating new Sites, Apps, or services.
We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, our Apps, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing.
Fraud prevention: Detecting, preventing and investigating fraud.
The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or We have a legitimate interest in carrying out the Processing for the purpose of detecting, protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.
We have a legitimate interest in carrying out the Processing for the purpose of recruitment activities and handling job applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing.
Disclosure of Personal Date to third parties We may disclose your Personal Data to: (i) legal and regulatory authorities; (ii) our external advisors; (iii) our Processors; (iv) any party as needed in connection with legal proceedings; (v) any party necessary for investigating, detecting or preventing criminal offense; (vi) any purchase of our business; and (vii) any third party providers of advertising, plugins or content used on our Sites or our Apps.
We may disclose your Personal Data to other Arab Finance entities, for legitimate business purposes (including operating our Sites and Apps, and providing services to you), in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. In addition, we may disclose your Personal Data to:
legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
accountants, auditors, lawyers and other outside professional advisors to Arab Finance, subject to binding contractual obligations of confidentiality;
third party Processors (such as providers of data hosting services and document review services), located anywhere in the world, subject to the requirement noted below in this Section (G);
any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
any relevant third party acquirer(s), in the event that we sell or transfer all or any portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
any relevant third party provider, where our Sites and our Apps use third party advertising, plugins or content. If you choose to interact with such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party privacy policy before interacting with its advertising, plug ins or content.
If we engage a third party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data, together with any additional requirements under applicable law.
Data security
We implement appropriate technical and organizational security measures to protect your Personal Data. Please ensure that any Personal Data that you send us are sent securely.
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protection your personal data, we cannot guarantee the security of your data transmitted to us using the internet- any such transmission is set at your own risk and you are responsible for ensure that any Personal Data that you send us are sent securely.
Data accuracy
We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.
We take every reasonable step to ensure that:
your Personal Data that we Process are accurate and, where necessary, kept up to date; and
any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your Personal Data.
Data minimization
We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.
We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.
Data retention
We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed.
We take every reasonable step to ensure that your Personal Data are only Processes for the minimum period necessary for the purposes set out in this Policy.
The criteria for determining the duration for which we will keep your Personal Data are as follows: we retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.
Your legal rights
Under applicable law, you may have a number of rights, including: (i) the right not to provide your Personal Data to us; (ii) the right of access to your Personal Data; (iii) the right to request rectification of inaccuracies; (iv) the right to request the erasure, or restriction or Processing, of your Personal Data; (v) the right to object to the Processing of your Personal Data; (vi) the right to have your Personal Data transferred to another Controller; (vii) the right to withdraw consent; (viii) and the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.
Subject to applicable law, you may have a number of rights regarding our Processing of your Relevant Personal Data, including:
the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our Sites, our Apps, or our services, if you do not provide us with your Personal Data);
the right to request rectification of any inaccuracies in your Personal Data;
the right to request, on legitimate grounds;
erasure of your Personal Data; or restriction of Processing of your Personal Data;
the right to have certain Personal Data transferred to another Controller, in a structured, commonly used and machine- readable format, to the extent applicable;
where we Process your Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the data on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
the right to lodge complaints with a Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf.
Nothing in this Policy affects your other legal rights.
To exercise one or more of the rights described in this Policy, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (P) below. Please note that:
we may require proof of your identity before we can give effect to these rights; and where your request requires the establishment of additional facts (for example a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.
Cookies and similar technologies
We may Process your Personal Data by our use of Cookies and similar technologies.
When you visit a Site or use an App we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.
Terms & Conditions
Our Terms & Conditions govern all use of our Sites and our Apps. Please click here to read them.
All use of our Sites, our Apps, or our services is subject to our Terms & Conditions. We recommend that your review our Terms & Conditions regularly, in order to review any changes we might make from time to time.
Direct marketing
We may Process your Personal Data to contact you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.
We may Process your Personal Data to contact you via e-mail, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.
Contact details
If you have any comments, questions, or concerns about data privacy, including the processing of personal data carried out by us, or on our behalf, please visit our contact us page and submit a contact request.
Definitions
App means any application made available by us (including where we make application available via third party stores or marketplaces, or by any other means).
Controller means the entity that decides how and why Personal Data are Processed.
Cookies means a small file that is place on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogues technologies such as web beacons and clear GIFs.
Data Protection Authority means an independent public authority that is tasked, by law, with overseeing compliance with applicable data protection laws.
Personal Data means information that is about any individual, or from which any individual is directly or indirectly identifiable, 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 individual.
Process, Processing or Processed means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Processor means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
Sensitive Personal Data means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offenses or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
Site means any website operated, or maintained, by us or on our behalf.