Privacy Notice

WHO WE ARE AND HOW TO CONTACT US
Mashreq Bank is a data controller of your personal information. “Personal information” means information that is about you or from which we can identify you. This privacy notice describes how we deal with your personal information. Mashreqbank shall protect the data that you provide in compliance with the Data Privacy Policies which are in line with the relevant Data Privacy Laws (“Laws”) and it's implementing rules and regulations. We are the data controller of this information under Personal Data and other relevant data protection regulations because in the context of our business relationship with you we decide how and why it is processed in the ways explained in this privacy notice. When we use terms such as we, us and our in this privacy notice, we mean Mashreqbank.

This privacy notice may be updated from time to time. You should check www.mashreqbank.com and / or other Mashreq websites regularly so that you can read the up to date version. We may send you an updated copy (depending on whether we are required to do that or not).

HAVE YOU BEEN INTRODUCED TO US BY A BROKER OR OTHER INTERMEDIARY?
Our products and services are available through our own branches and on our own website as well as through professional and financial advisors and anyone else who acts as a person sitting in between you and us in relation to what we do for you. In this notice we will call these persons “brokers and other intermediaries”. When a broker or other intermediary processes your personal information on our behalf, this privacy notice will apply and you should contact us to exercise your rights under data protection laws. When a broker or other intermediary processes your personal information as a data controller, its own privacy notice will apply and you should ask them for a copy if you do not have one by the time you are introduced to us.

WHAT KINDS OF PERSONAL INFORMATION ABOUT YOU DO WE PROCESS?
This will depend on the products or services you apply for and (if your application is successful) obtain from us. We set out below personal information that we generally process in connection with all our products and services, followed by personal information that we generally process in connection with specific products and services.

PERSONAL INFORMATION THAT WE GENERALLY PROCESS IN CONNECTION WITH ALL OUR PRODUCTS AND SERVICES
This includes:

• Your title, full name, signature, and contact details, including for instance your email address, home and mobile telephone numbers and fax number;
• Your home address, correspondence address (where different from your home address) and address history;
• Your date of birth and/or age, e.g. to make sure that you are eligible to apply for the product and/or that it is suitable for you;
• Your place of birth, nationality, residency details and any other citizenships if this is necessary for us to comply with our legal and regulatory requirements;
• Your government identification number and identification documents including for instance document type, number, country of issue and expiry date;
• Records of how you have contacted us and, if you get in touch with us online, details such as your mobile phone location data, IP address and MAC address;
• Details of your marital status, spouse’s name and account information, dependents, beneficiaries, beneficial owners, representatives, indemnifiers, tax status, sources of income and funds, assets and liabilities, and whether you are a politically exposed person;
• Details of shareholdings, prominent functions, directorships and/or employment including for instance your occupation, salary, employer and length of service;
• Details of your products and services including for instance application information, customer ID number, account number, account balance and currency, account history, security or collateral held by us, your branch name, standing orders, direct debits, payment transactions, cards held, card numbers, details of additional signatories, online banking details, information relating to complaints and/or fraud reports, and details associated with account closure and/or card cancellation;
• Security identifiers including for instance mother’s maiden name;
• To regulatory bodies governing the jurisdiction

WHAT IS THE SOURCE OF YOUR PERSONAL INFORMATION?
We will generally collect your personal information from you directly. If you are introduced to us by an approved intermediary, we will obtain some personal information about you indirectly from them when they introduce you to us.

In addition, we obtain your personal information from other sources such as fraud prevention agencies, credit reference agencies, your employer, landlord, other lenders, publicly available directories and information (e.g. telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies. In addition, some of your personal information may come from other members of our Group if you already have a product with them.

Some of the personal information obtained from Credit Reference Agencies will have originated from publicly accessible sources. In particular, credit reference agencies draw on court decisions, bankruptcy registers and the electoral register (also known as the electoral roll). We explain more about Credit Reference Agencies below. We have also mentioned above in the lists of personal information that we process some of the Credit Reference Agencies’ other sources of information (which are our own source of information too).

WHAT ARE THE LEGAL GROUNDS FOR OUR PROCESSING OF YOUR PERSONAL INFORMATION (INCLUDING WHEN WE SHARE IT WITH OTHERS)?
Data protection laws require us to explain what legal grounds justify our processing of your personal information (this includes sharing it with other organisations). For some processing more than one legal ground may be relevant (except where we rely on a consent). Here are the legal grounds that are relevant to us:

1. Processing necessary to perform our contract with you or for taking steps prior to entering into it:
   1. Administering and managing your account(s) and related services, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt;
   2. Sharing your personal information with other payment services providers such as when you ask us to share information about your account with them; and
   3. All stages and activities relevant to managing your account(s) including enquiry, application, administration and management of accounts, illustrations, requests for transfers of equity, and setting up/changing/removing guarantors
2. Where we consider that, on balance, it is appropriate for us do so, processing necessary for the following legitimate interests which apply to us and in some cases other organisations (who we list below) are:
   1. Administering and managing your account(s) and services relating to that, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt, to assess your credit worthiness and advise you in relation to products and services;
   2. To test the performance of our products, services and internal processes;
   3. To adhere to guidance and best practice under the regimes of governmental and regulatory bodies such as Monetary Authority of Hong Kong or any other relevant authority;
   4. For management and audit of our business operations including accounting and insurance;
   5. To carry out searches at Credit Reference Agencies pre-application, at the application stage, and periodically after that. Where you have been introduced to us by a broker or other intermediary they may do these searches on our behalf;
   6. To carry out monitoring and to keep records (see below);
   7. To administer our good governance requirements and those of other members of our Group;
   8. For market research and analysis and developing statistics;
   9. When we share your personal information with these other people or organisations;
      • Your guarantor (if you have one);
      • Joint account holders, trustees and beneficiaries and any person with power of attorney over your affairs (in each case only if relevant to you);
      • Members of our Group;
      • Other payment services providers such as when you ask us to share information about your account with them;
      • Other account holders or individuals when we have to provide your information to them because some money paid to you by them should not be in your account;
      • Our legal and other professional advisers, auditors and actuaries;
      • Financial institutions and trade associations;
      • Governmental and regulatory bodies;
      • Tax authorities who are overseas for instance if you are subject to tax in another jurisdiction we may share your personal information directly with relevant tax authorities overseas;
      • Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions;
      • Buyers and their professional representatives as part of any restructuring or sale of our business or assets;
      • Credit Reference Agencies (see below where we explain more); and
      • Market research organisations who help us to develop and improve our products and services.
3. Processing necessary to comply with our legal obligations:
   1. For compliance with laws that apply to us;
   2. For establishment, defence and enforcement of our legal rights or those of any other member of our Group;
   3. For activities relating to the prevention, detection and investigation of crime;
   4. To carry out identity checks, anti-money laundering checks, and checks with Fraud Prevention Agencies pre-application, at the application stage, and periodically after that. Where you have been introduced to us by a broker or other intermediary they may do these searches on our behalf.
   5. To carry out monitoring and to keep records (see below);
   6. To deal with requests from you to exercise your rights under data protection laws;
   7. To process information about a crime or offence and proceedings related to that (in practice this will be relevant if we know or suspect fraud); and
   8. When we share your personal information with these other people or organisations:
      • Your guarantor (if you have one);
      • Joint account holders, Trustees and beneficiaries, and the person with power of attorney over your affairs;
      • Other payment services providers such as when you ask us to share information about your account with them;
      • Other account holders or individuals when we have to provide your information to them because some money paid to you by them should not be in your account;
      • Fraud Prevention Agencies and Law enforcement agencies
4. Processing with your consent:
   1. When you request that we share your personal information with someone else and consent to that;
   2. For some of our processing of special categories of personal data such as about your health or if you are a vulnerable customer (and it will be explained to you when we ask for that explicit consent what purposes, sharing and use it is for.)

HOW AND WHEN CAN YOU WITHDRAW YOUR CONSENT?
Much of what we do with your personal information is not based on your consent, instead it is based on other legal grounds. For processing that is based on your consent, you have the right to take back that consent for future processing at any time. You can do this by contacting us using the details above.

We will tell the broker or other intermediary who introduced you to us that you have withdrawn your consent only if it is our data processor (this means an organisation who is processing personal information on our behalf) or if we are required to do when you exercise certain rights under data protection laws. You should make sure to contact them directly to withdraw your consent for what they do with your personal information as a data controller in their own right.

To comply with payment services regulations, we have to share some of your personal information with other payment service providers in some circumstances such as when you ask us to share information about your account with them. Whilst those payment services regulations mention ‘consent’ for this, ‘consent’ in that context does not have the same meaning as ‘consent’ under data protection laws. The legal grounds which may be relevant to this are compliance with our legal obligations, performance of our contract with you, our legitimate interests, or a combination of these. Therefore, if you ask to withdraw consent from what we do with your personal information where we need to have it the payment services regulations, we may still have to hold and use your personal information.

IS YOUR PERSONAL INFORMATION TRANSFERRED OUTSIDE?
Sometimes your personal information may be transferred outside the Country of origin. Some countries outside your country do not have adequate protection for personal information under laws that apply to us. We will make sure that suitable safeguards are in place before we transfer your personal information to countries outside the country which do not have adequate protection under laws that apply to us.

For more information about suitable safeguards and (as relevant) how to obtain a copy of them or to find out where they have been made available you can contact us using the details above.

WHAT SHOULD YOU DO IF YOUR PERSONAL INFORMATION CHANGES?
You should tell us without delay so that we can update our records. If you were introduced to us by a broker or other intermediary who is data controller in its own right, you should contact them separately. [In some cases where you exercise rights against us under data protection laws (see below) we may need to inform the broker or other intermediary but this will not always be the case.]

DO YOU HAVE TO PROVIDE YOUR PERSONAL INFORMATION TO US?
We are unable to provide you with products and services or to process your application without having personal information about you. Your personal information is required before you can enter into the relevant contract with us, or it is required during the life of that contract, or it is required by laws that apply to us. If we already hold some of the personal information that we need – for instance if you are already a customer – we may not need to collect it again when you make your application.

DO WE DO ANY MONITORING INVOLVING PROCESSING OF YOUR PERSONAL INFORMATION?
In this section monitoring means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person face to face meetings and other communications.

We may monitor where permitted by law and we will do this where the law requires it.

Some of our monitoring may be to comply with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures, to have a record of what we have discussed with you and actions agreed with you, to protect you and to provide security for you (such as in relation to fraud risks on your account) and for quality control and staff training purposes.

Some of our monitoring may check for obscene or profane content in communications.

We may conduct short term carefully controlled monitoring of your activities on your account(s) where this is necessary for our legitimate interests or to comply with our legal obligations. For instance, where we suspect fraud, money laundering or other crimes.

Telephone calls and/or in person meetings between us and you in connection with your application and/or your account(s) may be recorded to make sure that we have a record of what has been discussed and what your instructions are. We may also record these types of calls for the quality control and staff training purposes.

FOR HOW LONG IS YOUR PERSONAL INFORMATION RETAINED BY US?
Unless we explain otherwise to you, we will hold your personal information for 10 years following the conclusion of our business relationship in case of:

1. queries from you;
2. legal claims by you; and/or
3. legal and/or regulatory requirements to which we are subject.

WHAT ARE YOUR RIGHTS UNDER DATA PROTECTION LAWS?
Here is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to exercise any of them we will explain at that time if they are engaged or not.

• The right to be informed about your processing of your personal information;
• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
• The right to object to processing of your personal information;
• The right to object processing of your personal information;
• The right to have your personal information erased (the “right to blocking or erasure”);
• The right to request access to your personal information and to obtain information about how we process it;
• The right to move, copy or transfer your personal information;
• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

If you wish to exercise any of these rights against the credit reference agencies, the fraud prevention agencies, or a broker or other intermediary who is data controller in its own right, you should contact them separately.

DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION
Your personal information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described in this privacy notice.

DATA PRIVACY NOTICES FROM OTHER ORGANISATIONS
We have mentioned that we share your personal information with fraud prevention agencies and credit reference agencies. They require us to pass on to your information about how they will use your personal information to perform their services or functions as data controllers. These notices are separate to our own.

All banking transactions requested by Mashreq customers are governed by Bank’s Terms and Conditions that might change from time to time according to Mashreq Bank’s sole discretion

If you have any questions about our privacy practices write to us at DPO@Mashreq.com or Mashreqbank, Attn: Customer Care Center, P.O. Box 1250, Dubai, UAE.