Personal Data and Processing have very specific meanings under the Singapore Applicable Laws. It is important that you understand these terms.

What is Personal Data?

Personal Data means any data, whether true or not, 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 names, identification numbers, location data or online identifiers, reflecting changes in technology and the way organisations collect information about people.

Examples of Personal Data include, but are not limited to the following:

• Address
• Contact information
• Date of birth
• Financial data
• Gender
• Identification number (e.g., national id, passport number, and driver’s licence number)
• Location data (e.g., gps coordinates)
• Marital status
• Name
• Photographs, videos, voice recordings
• Specimen signature(s)
• Tax and insurance information
• Telephone, mobile, fax numbers and email addresses
• Transactional data
• Website technical data (e.g., your internet protocol (ip) address, website login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites)
• Website profile and usage data (e.g., your interests, habits, activities, preferences, opinions, feedback and survey responses, information about how you use our websites)
• Transaction details while performing online payments (e.g., merchant name, location, device used).

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 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 engage 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:

• Representative(s) of a corporate client.
• Legal representatives (power of attorney) of a client.
• People appointed to act on your behalf.
• Other Emirates NBD Groups.
• Your employer.
• Credit Bureaus or credit reporting agencies.
• Digital identity solutions.
• Government databases.
• Law enforcement officials.
• Co-borrowers / guarantors.
• Criminal records check from organisations authorised to provide this data.
• Beneficiaries of your payment transactions.
• Nominated contact person by an existing account holder.
• Joint account holders.
• Debt recovery agents.
• Publicly available sources.
• 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.
• Reference contacts provided in the application form by you.

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.
• 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.

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:

Emirates NBD only discloses your Personal Data outside of Emirates NBD in limited circumstances. 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 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. Find below the supporting Schedule with a list of categories of third parties with whom Emirates NBD may share your data.

Emirates NBD websites and apps are intended for use only by persons who are above the age of 13. If you are under the age of 13, your parent or guardian must consent on your behalf where Emirates NBD asks for consent in relation to the use of your Personal Data.

The way Emirates NBD analyses Personal Data relating to Emirates NBD Services may involve 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, sanctions checks 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.

You may have a right to certain information about how Emirates NBD make these decisions. You may also have a right to request human intervention in case it pertains to a fully automated process and to challenge the decision. Refer the “How to Contact Us” section for further details on reaching out to us with your request.

Emirates NBD needs your Personal Data to provide you with the Services or products requested by you. Emirates NBD also needs to capture expressed consent to be able to process the Personal Data for fulfilling Emirates NBD’s contractual and legal obligations.

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.

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

ENBD makes it clear on the ENBD 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 ENBD Singapore Branch General Line at +65 64387868.
• Sending an email to sindpo@emiratesnbd.com.
• Writing to us at:
  Attn: Singapore Data Protection Officer,
  Emirates NBD PJSC, Singapore Branch,
  10 Collyer Quay #25-01/05,
  Ocean Financial Centre,
  Singapore 049315.

Further details of how ENBD will use your Personal Data can be found below.

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 addressTechnical information, 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).

Emirates NBD is a global organisation, and your Personal Data may be stored, transferred or processed in any country where Emirates NBD has facilities or in which Emirates NBD engages Service providers and subcontractors. In doing so, Emirates NBD will comply with the PDPA and other applicable data protection and privacy laws. Emirates NBD has put in place appropriate safeguards in accordance with applicable legal and data protection requirements to ensure that your data is adequately protected.

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, or by contacting your Wealth Advisor.
• Right to Access (also known as a ‘Individual Access Request’): You have the right to obtain confirmation as to whether Emirates NBD processes Personal Data about you, receive a copy of your Personal Data held by us, and obtain certain other information about how and why Emirates NBD processes your Personal Data.
• Right to Correction: You have the right to request for your Personal Data to be amended or rectified where there is an error or omission (for example, if you change your name or address) and to have incomplete Personal Data completed. Emirates NBD may take a reasonable period after receiving your correction request to process and update the change.
• Right to Withdraw Consent: Where Emirates NBD process Personal Data based on consent, individuals have a right to withdraw their consent at any time. To do so, please use the contact details below in the “How to Contact Us” section.
• 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 send an email with the details of your complaint using the contact details set out below. You may lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred. The contact details of the competent national supervisory authority, Personal Data Protection Commission, are as follows:
  Address: 10 Pasir Panjang Road, #03-01 Mapletree Business City, Singapore 117438 Telephone: +65 63773131 Website: https://www.pdpc.gov.sg/

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. Emirates NBD has the right to charge a reasonable fee for facilitating a right request that you may raise with the Bank.

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.

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 password.

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 General Terms & Conditions provided as part of account onboarding.

Whilst Emirates NBD takes measures to secure your Personal Data, risks to data security do exist, and there is always a possibility of unauthorised use, disclosure, modification and/or destruction of your Personal Data. In the event of a Personal Data Breach where Emirates NBD has assessed it to be notifiable, Emirates NBD will notify you about it and its likely consequences, measures taken by us to mitigate the increased risk and avenues available to you to mitigate the risk as a result of the Personal Data Breach.

For reporting Personal Data Breaches or further information on how Emirates NBD respond to and handle Personal Data Breaches, please contact us at sindpo@emiratesnbd.com.

The Emirates NBD website and apps 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.

Emirates NBD has appointed a Data Protection Officer (“DPO”) to oversee compliance with this Data Privacy Notice. The DPO can be contacted at sindpo@emiratesnbd.com.

Emirates NBD will keep your Personal Data for as long as Emirates NBD has a relationship with you. 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 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.

In some circumstances you can ask us to delete your data. For further information, please see the “What are your Rights” section.

If you have questions or concerns regarding the way in which your Personal Data is being used, please contact the Emirates NBD Data Privacy Office by emailing sindpo@emiratesnbd.com.

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

If you would like to stop receiving marketing or promotional communications, please contact your respective Wealth Advisors.

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 the “How to Contact Us” section of this Notice.