Privacy Policy

Generally, we collect personal data in the following ways:

• when you submit any form to us, including without limitation via the FAB Websites;
• when you use our electronic banking services, use services or features on our websites or platforms (such as the FAB Websites), or interact with us via such websites or platforms;
• when you when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
• when you interact with our staff and Representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;
• when you use our services provided through online and other technology platforms, such as the FAB Websites, including when you establish any online accounts with us;
• when you request that we contact you, be included in an email or other mailing list, or when you respond to our request for additional personal data, our promotions and other initiatives;
• when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
• when we seek information about you and receive your personal data in connection with your relationship with us, including for our services, for example, from business partners, public agencies, your ex-employer and the relevant authorities;
• when you share comments or feedback with us (such as via the FAB Websites); and/or
• when you submit your personal data to us for any other reason.

If you provide us with any personal data relating to a third party by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their personal data, and for the collection, use and disclosure of their personal data for all purposes set out in our herein and by or for the benefit of the persons referenced herein.

You should ensure that all personal data submitted to us is complete, accurate and correct. Failure on your part to do so may result in our inability to provide you with any products and/or services you have requested.

Generally, we collect, use, and/or disclose your personal data for the following purposes:

• Processing applications for products and services, effecting payments, transactions and completing instructions or requests
• Providing products and services (including electronic banking services)
• Acting in accordance with your instructions, completing your transactions, or otherwise as necessary to facilitate your interaction with us and/or third parties
• Responding to, processing, and handling your queries, requests, feedback, and suggestions, and to provide customer support
• Assessing customer suitability for products and services
• Credit assessments, including conducting credit checks and setting credit limits
• Establishment, continuation and management of banking relationships and accounts
• Conducting market research and surveys with the aim of improving our products and services, and/or analysis for statistical, profiling, or other purposes for us to design our products and services, understand customer behaviour, preferences, and market trends, and to review, develop, and improve the quality of our products and services
• For marketing purposes and promotions, including without limitation organising promotional events
• For the prevention, detection, investigation and prosecution of crime (including without limitation, money laundering, terrorism, fraud and other financial crime) in any jurisdiction, identity verification, government sanctions screening and due diligence checks, and analysing and managing commercial risks
• To provide media announcements and responses
• To comply with local or foreign law, regulations, voluntary codes, directives, judgements or court orders, agreements between any member of the FAB group and any authority, regulator or enforcement agency's policies, reporting requirements under financial transaction legislation and demands or requests of any authority, regulator, enforcement agency or exchange body
• To seek professional advice, including in connection with any claims, actions, or proceedings, whether ongoing or prospective, including without limitation drafting and reviewing documents, obtaining legal advice, facilitating dispute resolution, and/or protecting, enforcing, exercising or defending legal rights
• Managing and preparing reports on incidents and accidents
• Surveillance of premises and ATMs
• Administrative management of invoicing
• Management of data privacy rights exercised by an individual
• Ensuring security of information systems, and consequently preventing, detecting, and avoiding any data breaches, sometimes through cookies
• Monitoring and improving the FAB Websites and its contents including:
  • To analyse the behaviour of Internet users with cookies, in order to optimize and personalize, if necessary, the pages of the FAB websites; and
  • To carry out statistics of visits and use of Bank website with cookies
• Managing our administrative and business operations and complying with internal policies and procedures
• Facilitating business asset transactions (which may include mergers, acquisitions, or asset sales) involving any of the Companies
• Matching any personal data held which relates to you for any of the purposes listed herein
• Any other purpose relating to or reasonably necessary for any of the above

These purposes may apply even if you do not maintain any accounts with us, or have terminated such accounts.

In addition, depending on the nature of our relationship, we may collect, use, or disclose your personal data for the following additional purposes:

• If you submit any application to us as a candidate for employment: (i) conducting interviews; (ii) processing your application which includes pre-recruitment checks involving your qualifications and facilitating interviews; (iii) providing or obtaining employee references and for background screening; (iv) assessing your suitability for the position applied for; (v) processing staff referrals; and/or (vi) any other purposes relating to any of the foregoing
• Any other purpose relating to or reasonably necessary for any of the above

In relation to particular products or services or in your interactions with us, we may specifically notify you of other purposes for which we collect, use and/or disclose your Personal Data. If so, we may collect, use and/or disclose your Personal Data for these purposes as well.

Subject to applicable law, you hereby agree that your personal data may be disclosed for any of the purposes listed in this policy to the following persons (who may be located in Singapore or overseas):

• our group companies, third party service providers, and business partners;
• other banks, credit card companies, financial institutions, and their respective service providers;
• any investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;
• our professional advisors such as our auditors and lawyers;
• relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;
• external business and charity partners in relation to corporate promotional events; and/or
• any other party to whom you authorise us to disclose your Personal Data to.

These arrangements may involve your personal data being located or transferred in various countries around the world including the United Arab Emirates where FAB has its head office.

You should be aware that different privacy laws may apply in these countries, and the data privacy obligations and rights may differ from any laws that may apply in the country where you are located. FAB Singapore will always strive to adopt the highest standards of privacy protection wherever your personal data is located or transferred.

Our privacy policy does not apply to third-party websites where our online advertisements are displayed or to linked third-party websites which we do not operate or control. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

In addition to the above, subject to and in accordance with applicable law, you shall be deemed to have consented to us collecting, using, disclosing and sharing amongst ourselves your personal data, and disclosing such personal data to our service providers and relevant third parties:

• where in response to a request for your personal data in connection with identified purposes, you voluntarily provide such personal data to us for such purpose(s);
• where the collection, use or disclosure of your personal data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organisation entered into at your request, which may include recipients of your personal data not indicated in this Policy; or
• where we have brought to your attention our intention to collect, use or disclose your personal data for identified purposes, and you have not taken any action to opt out within the period specified in our notices. For this purpose, you agree that we may provide you such notices via our website, or via other forms of communication (e.g. SMS or email) based on your contact details in our records from time to time.

In addition to and without limiting the consents you have provided in relation to our collection, use, and disclosure of your personal data for the purposes set out elsewhere in this policy, where permitted by applicable law, we may also, in accordance with the requirements thereof, collect, use, and/or disclose your personal data as further detailed below, without your further consent where we meet the requirements imposed by applicable law:

• for our legitimate interests or the legitimate interests of any other person, including but not limited to the purposes expressly set forth in this policy; or
• for improving the FAB Websites, our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations, based on your personal data.

We encourage you to contact us as soon as possible to enable us to update any personal data we have about you. Incomplete or outdated personal data may result in our inability to provide, or delays in providing, you with products and services you have requested, or processing any requests and applications you may have made to us.

To the extent permitted by applicable law, we may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations.

The security of your personal data is important to us and FAB has invested significant resources to protect the safekeeping and confidentiality of your personal data. When using external service providers, we require that they adhere to the same standards as FAB Singapore. Personal data may be transferred or stored at a location outside of your country of residence. Regardless of where your personal data is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure.

Your personal data may be retained by us for as long as the purpose for which it was collected remains served or until it is no longer necessary for any other legal or business purposes.

After the completion of purpose for which the personal data was collected, and when retention is no longer necessary for legal or business purposes, your personal data will be deleted or securely anonymised.

Subject to applicable law, regulations and/or banking industry guidelines, you may have the right to request a copy of the personal information processed in relation to you. FAB may be allowed, by law, to charge a fee for providing you with a copy of your personal information.

Subject to applicable law, regulations and/or banking industry guidelines, you may have the right to request a correction of inaccurate personal information processed in relation to you.

FAB operates channels, pages and accounts on some social media sites to inform, assist and engage with customers. We may monitor and record comments and posts made on these channels about FAB so that we can improve our services.

Please note that you must not communicate to us through such social media sites the following types of information:

• confidential personal data, including any information regarding your financial situation, bank account details, transactions, etc.;
• sensitive personal data including (i) special categories of personal data meaning any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation and (ii) other sensitive personal data such as criminal convictions and offences and national identification number; and/or
• excessive, inappropriate, offensive or insulting information towards individuals.

We are not responsible for any information posted on those sites other than information we have posted ourselves and we do not endorse the social media sites themselves or any information posted on them by third parties.

If you:

• have any questions or feedback relating to your personal data or this policy;
• would like to withdraw your consent to any collection, use, or disclosure of your personal data by us; or
• would like to obtain access or make corrections to your personal data,

you may write to our Data Protection Officer:
Data Protection Officer
First Abu Dhabi Bank PJSC Singapore Branch
Email: dpo.sg@bankfab.com

If your personal data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to us on your behalf.

Please note that if you withdraw your consent to our collection, use, and/or disclosure of your personal data for any or all the purpose set out above, depending on the nature of your request, we may not be in a position to continue to provide products and/or services to you (including without limitation the FAB Websites). This may also have implications for your contractual relationship with other parties. Our legal rights and remedies in such event are expressly reserved.