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This section lists places where we get data that counts as part of your Personal Data. Collection of Personal Data: We collect Personal Data about you: When you provide it to us (e.g., where you contact us via telephone or by any other means) In the ordinary course of our relationship with you (e.g., in the course of managing your transactions)
That you choose to make public, including via social media (e.g., we may collect information from your social media profile(s) to the extent that you choose to make your profile publicly visible)
From third parties who provide it to us (e.g., your employer; our customers; credit reference agencies; law enforcement authorities and so forth) When you visit our websites or use any features or resources available on or through our website. When you visit our website, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to our website and other technical communications information), some of which may constitute Personal Data
When you download, register or use our mobile applications we will automatically collect Personal Data, including Device Data, Location Data and Usage Data. We collect this data using cookies and other similar technology Creation of Personal Data: We create Personal Data about you, such as records of your interactions with us, and details of your accounts, subject to the PDPL.
Unique application number: When you wish to install or uninstall the App containing a unique application number or when such application searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
Relevant Personal and Sensitive Personal Data:
This section explains what different types of Personal Data mean.
Pursuant to the PDPL, the categories of Personal Data about you that we Process are as follows:
Type of Personal Data
Description
Contact details
Address; telephone number; and email address
Personal details
given name(s); preferred name(s); gender; date of birth / age; marital status; Social Security number; passport number(s); driving license number(s); nationality; lifestyle and social circumstances; images of passports, driving licenses, and signatures; authentication data (passwords,
mother's maiden name, challenge/response questions and answers, PINs); photographs; visual images; and personal appearance and behavior
Family details
Names and contact details of family members and dependents.
Financial
Your financial position; financial status; financial history; billing address; bank account numbers; credit card numbers; cardholder or accountholder name and details; instruction records; transaction details; and counterparty details
Transactional
Details about payments to and from your accounts with us, and insurance claims you make
Behavioral
Details about how you use products and services from us and other organisations
Employment details
Industry; role; business activities; names of current and former employers; work address; work telephone number; and work email address
Electronic Identifying Data
IP addresses; cookies; activity logs; online identifiers; unique device identifiers; and geolocation data.
Sensitive Personal Data: Any personal information that directly or indirectly discloses any of the following: the ethnic origin of the individual, their ethnic group, political or philosophical views, religious beliefs, trade union affiliation, criminal record, or any data relating to their health or sexual status.
Processing your Sensitive Personal Data: We do not seek to collect or otherwise Process your Sensitive Personal Data, except where:
1. The Processing is necessary for compliance with a legal obligation;
2. The Processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by the PDPL;
3. You have made those Sensitive Personal Data public;
4. The Processing is necessary for the establishment, exercise or defence of legal rights;
5. We have, in accordance with the PDPL, obtained your explicit consent prior to Processing your Sensitive Personal Data;
or
6. Processing is necessary for reasons of substantial public interest and occurs on the basis of an applicable law that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your fundamental rights and interests.
Purposes for which we may Process your Personal Data:
We will only use your Personal Data when the law allows us to do so, most commonly we will use your Personal Data in the following circumstances:
• where you have consented before the processing;
• where we need to perform a contract we are about to enter or have entered with you;
• 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;
and
• where we need to comply with a legal or regulatory obligation(s).
Here is a list of all the ways that we may Process your Personal Data:
Anti-Money Laundering / KYC
• fulfilling our regulatory compliance obligations, including 'Know Your Client' checks
• confirming and verifying your identity (including by using credit reference agencies)
• screening against government, supranational bodies (including but not limited to the United Nations Security Council, the European Union, the UK HM Treasury, the U.S. Department of the Treasury’s Office of Foreign Asset Control) and/or law enforcement agency sanctions lists as well as internal sanctions lists and other legal restrictions
Client on-boarding
• on-boarding new clients
compliance with our internal compliance requirements, policies and procedures
Credit worthiness
• conducting credit reference checks
• conducting other financial due diligence
Providing products and services to you
• managing relationships and related services
• performance of tasks necessary for the provision of the requested services
communicating with you in relation to our services
Marketing
• communicating with you via any means (including via email, telephone, text message, social media, post
or in person) subject to ensuring that such communications are provided to you in compliance with the PDPL
• maintaining and updating your contact information where appropriate
Operation of our website and App
• operation and management of our website and App
• providing content to you
• displaying advertising and other information to you
• communicating and interacting with you via our website and App
IT operations
• management of our communications systems
• operation of IT security
• IT security audits
Financial management
• Sales
• Finance
• corporate audit
• vendor management
Research
• conducting market or customer satisfaction research
• engaging with you for the purposes of obtaining your views on our products and services
Investigations
Detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
Legal compliance
Compliance with our legal and regulatory obligations under applicable law
Legal proceedings
Establishing, exercising and defending legal rights.
Improving our products and services
• Identifying issues with existing products and services
• planning improvements to existing products and services
• creating new products and services
Risk Management
• Audit
• Compliance
• Controls
• Other risk management
Fraud prevention
Detecting, preventing and investigating fraud.