What Does Al-Tijari Do?
Commercial Bank of Kuwait is one of the largest financial institutions in Kuwait with a strong and growing corporate and retail banking franchise providing innovative financial and investment solutions to its ever growing customer base.
Data Privacy Inquiries
Address: Commercial Bank of Kuwait Mubarak Al Kabeer Street, P.O Box 2861, Postal Code 13029, Safat Kuwait, Tel: 22990000, Fax: 22464870
Tel: +965 22990000 Ext 6730/6837/0905/6836
When Do We Collect Your Personal Data?
We collect and hold information about you when you:
- Complete an online application through AlTijari online (internet banking or cbk mobile), PACI Kuwait mobile ID, Cinet/credit score, fill a soft form or a form at the branch (Kiosk,Selfservice ,Smart teller machine STM)
- Provide us with your contact address or email address;
- Access and use our services through our website and online banking (IB and mobile)
We also collect some statistical information about visitors from our website
(For example, the number of visitors, the viewed pages, the types of transactions conducted, the time spent on the website and the downloaded documents). Some of this statistical information is collected by using cookies, but none of the statistical information we collect allows us to identify a visitor. We use this information to evaluate our website performance and continually improve our digital services
Automated Technologies or Interactions
Log information is data about your use of the Service, such as IP (Internet Protocol) address, browser type, referring/exit pages, operating system, date/time stamps, and related data, stored in log files.
A cookie is a small data file transferred to your computer (or other device) when it is used to access our service. Cookies may be used for many purposes, including to enable certain features of our service and remember your preferences, your equipment and your browsing actions and patterns. Cookies can help us better understand how you interact with our service so we can provide you with advertising on and off the service, and so we can monitor the visitors’ usage as well as the online traffic routing. You may be able to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the online services you visit. Nevertheless, if you do not accept cookies you may not be able to use all the portions or functionalities of our service.
Third Parties or Publicly Available Sources
We may receive aggregated personal data about you from various third parties as mentioned below: Technical Data from the following
Technical Data from the following parties:
- Analytics providers such as Google Analytics and Facebook;
- Social media platforms such as Facebook, Twitter, Instagram, Whatsapp,SnapChat, YouTube, LinkedIn or any social media platform used by the bank in future.
What Personal Data Do We Collect?
The types of information that we keep on record will depend on the type of product or banking services requested by you. Generally, we may collect, store, use and keep a record of one or more of the following categories of personal data about you:
- Identity Data
- Full name
- Email ID
- Telephone numbers/ contact number
- Credit information about you and property in case the transaction is for loan or any collateral held by the bank (,deposits credit cards..etc)
- Account transaction information including credit and debit.
- Your interests, preferences, feedback and survey responses.
- Profile image.
- Biometrics credentials(voice,face,fingerprint) used for banking purpose.
- About (mentioned in resume).
- Information about how you use our website,
- products and services;
- Information on what you view, click on and access through our emails and text messages, website, online banking and CBK mobile.
Marketing and Communications Data
We do not collect any personal data for marketing purposes. However, we may ask you to leave a review or take a survey to help us provide you with better services. We may also collect your personal data when responding to your queries and comments, social media posts and questions.
We do not actively seek to collect sensitive information, unless it is necessary for our Bank business purposes. If we do have to collect sensitive information, we will do so in accordance with the Bank’s Information Security Policy. Our intent is not to collect or process any sensitive information about you, unless required by applicable laws. However, in certain circumstances, we may need to collect, or request your sensitive information for employment related purposes via a shared resume. This can include for example data on your hobbies, gender or disabilities for the purposes of equal opportunities monitoring and in order to comply with anti-discrimination laws and government reporting obligations (such as Know Your Customer KYC and any applicable compliance forms)
How and Why Do We Use Your Personal Data?
We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:
- To respond to your request or to be able to process your application for our banking products or services (including performing the identity check required by the Financial Transaction Reports, and the analysis in relation to other banking services where necessary)
- To effectively manage and administer all the products and banking services we provide to you including banking, corporate banking, treasury, financial planning and other services (for example we may use your email address, mobile or telephone number to communicate with you about the banking services we provide to you)
- For reasons of substantial public interest, or for official purposes or as requested by the investigation authorities, police or governmental authorities on a lawful basis
- Where it is necessary for the establishment to exercise or defend legal claims, or for the purposes of carrying out obligations and exercising our or your rights in the fields of employment, social security and social protection law
- Based on your explicit consent ,Where we need to perform the contract we have entered into with you
- Where it is necessary for our legitimate interests (or those of a third party) and where your interests and fundamental rights do not override those interests
- Where processing is necessary in order to protect the vital interests of the data subject
- It means the interest of our business in conducting and managing our business activities to enable us to give you the best service/product and the best and most secure experience;
- We make sure that we consider and balance any potential impact on you (both positive and negative) as well as your rights before we process your personal data for our legitimate interests
We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by laws).
- We may also use your personal data in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else's interests);
- Where it is needed in the public interest or for official purposes.
Data collected through the bank’s channels such as IP address ,device ID, cookies and links to 3rd part sites
Aggregated data refers to numerical and non-numerical information that we are collecting for example through “Google Analytics” and social media UTM parameters.
Purpose/ Activity, Type of Data and Lawful Basis for Processing
We have set out below, in a table format, a description of all the ways we plan to use your personal data and the legal bases we rely on to do so. We have also identified our legitimate interests, where appropriate.
Note that we may process your personal data based on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
However, we normally collect personal data from you only where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is within the legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In certain cases, we may also have legal obligations to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another data subject.
Some of the above grounds for processing will overlap and there may be several grounds that justify our use of your personal data.
| Purpose/Activity|| Type of data||Lawful basis for processing including basis of legitimate interest|
| To manage our relationship with you, which will include:|
- Asking you to leave a review or take a survey;
- Responding to your queries and comments, social media posts and questions.
- Performance of a contract with you;
- Necessary to comply with a legal obligation;
- Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise);
- Necessary to comply with a legal obligation.
- To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
- Necessary for our legitimate interests (to study how customers use our products/ services and to develop them).
- To use data analytics gathered from our website in order to improve our website, products/services, marketing, customer relationships and experiences.
- Aggregated Data
- Necessary for our legitimate interests (to define the types of customers for our products and services and to keep our website updated and relevant).
- To make suggestions and recommendations to you about products or services that may be of interest to you.
- Necessary for our legitimate interests (to develop our products/services).
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
| Aggregated Data|
- To power our security measures and services to protect you and our business
- Necessary for our legitimate interest so you can safely access our website and mobile applications.
If we ask you to provide any other personal data not described above, then the reason for requesting that personal data will be made clear to you at the point we collect it.
However, we may also use your personal data for other purposes that are not incompatible with the purposes we have disclosed to you if and where this is permitted by applicable laws.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details provided.
With Whom Does Al-Tijari Share My Personal Data?
Occasionally, we may have to share your personal data with the parties defined below for the set out purposes.
External Third Parties
- Regulators and other authorities that require reporting of processing activities in certain circumstances.
- The Police, local authorities, courts and any other government authority if they ask us to do so (but only if our doing so is lawful).
- Other parties who make a ‘data subject request', where we are required to do so by law.
- We may also share the information we collect where we are legally obliged to do so, i.e. to comply with a court order.
Some of our external third parties are based outside Kuwait, so their processing of your personal data will involve a transfer of data outside Kuwait. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
How Do We Protect Your Personal Data?
We use appropriate technical and organizational measures to protect the personal data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.
A lot of the information we receive reaches us electronically, originating from your devices, and is then transmitted by your relevant telecoms network provider. Where it is within our control, we put measures in place to ensure this 'in flight' data is as secure as it possibly can be.
Sensitive data like passwords are protected for data in transit by data encryption. In addition to encryption, we have implemented robust network security controls to help protect data in transit. These include network security solutions like firewalls and / or network access control that secure the networks used to transmit data against malware attacks or intrusions.
We use secure means to communicate with you where appropriate, such as 'https' and other security and encryption protocols.
How Long Will We Keep Your Personal Data?
To make sure we meet our legal data protection and privacy obligations, we only hold on to your information for as long as we need it for the purposes we acquired it for in the first place and as required by the law. After that, we will either delete it or anonymised it so that it cannot be linked back to you.
We retain personal data we process where we have legitimate interest, performance of the contract, vital interest of data subject or of another natural person, performance of a task carried out in the public interest or in the exercise of official authority vested in our organization, or for the purposes of satisfying any legal, accounting, or other regulatory reporting requirements, or with your consent.
Automated Decision Making
Automated decisions are decisions concerning you which are made automatically on the basis of a computer determination (using software algorithms), without human intervention. We do not use automated decision making.
What Are Your Data Protection Rights?
Your Duty to Inform Us of Changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes by keeping your details up to date on our website.
Your Rights in Connection with Personal Data
Under certain circumstances, by law you have the right to:
- Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing it, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. However, note that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
- Right to withdraw consent at any time
Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up our response.
If you wish to exercise any of the rights set out above, please contact us at email@example.com
Indemnity and Limitation of Liability
You agree to defend, indemnify and hold harmless AlTijari, its officers, directors and employees from and against any and all claims, liabilities, damages, losses or expenses, including settlement amounts and reasonable legal fees and costs, arising out of or in any way connected with your access to or use of this site.
Although the bank shall make every attempt to keep the website free from viruses, it cannot guarantee that it is virus/ malware free. For your own protection, you should take the necessary steps to implement appropriate security measures and utilize a virus scanner before downloading any information from the website.
Al-Tijari, its directors and employees, shall not be liable in any manner whatsoever for any direct, indirect, incidental, consequential, or punitive damage resulting from the use of, access of, or inability to use the information available on the Website or the services provided by the bank. Al-Tijari, its directors and employees shall not be liable in any way for possible errors or omissions in the content of the Website.
Intellectual Property Rights
All information in this website is protected by copyright and other intellectual property rights. No images, text or other content from this website may be distributed or reproduced without the prior written approval from AlTijari Bank.
Changes to This Data Privacy Notice
We may update this data privacy notice from time to time in response to emerging legal, technical, contractual, regulatory or business developments. When we update our data privacy notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material privacy notice changes if and where this is required by applicable laws
If you have any questions about this privacy notice, please contact the Data Privacy officer at firstname.lastname@example.org