Terms and Conditions
Effective as of: 4 May 2023
· These terms and conditions govern your use of Qawn (“Qawn” or “Service”). You understand that by subscribing to the Service, you agree to be bound by these terms and conditions (“T&C”) which will apply to and govern your use of the Service.
· If you are using any of Jordan Ahli Bank’s Digital Channel Service(s), you would have accepted the terms and conditions which apply to such service(s) (“Digital Services T&C”). The current T&C are supplementary to and should be read together with the Digital Services T&C (and as same may be amended from time to time). To the extent that there is any inconsistency between both terms and conditions, these T&C shall prevail with regards to the Service. Unless the context provides otherwise, terms capitalised but not defined in these T&Cs shall have the same meaning ascribed to them under the Digital Services T&Cs.
· If you are not using any Digital Channel Services at the date of your acceptance of these T&Cs, then by accepting these T&Cs you are also deemed to accept and warrant complying with the Digital Services T&Cs which can be found at:
· In these T&C, the following terms shall have the meaning so ascribed to them:
· Close of Business: means 10:30 pm of the day which is a business day for the Bank including any change that may be introduced in relation to what constitutes “close of business” for the Bank.
· Beneficiary: means a User (as defined below) who is the holder of a QAWN Account. “Beneficiaries” shall be construed accordingly.
· JoPACC: Jordan Payments & Clearing Company.
· Merchant: means a merchant, being a natural person or a corporate entity, who accepts payment for goods and/or services through QAWN. “Merchants” shall be construed accordingly.
· Qawn Account: means the virtual account held with the Bank which is intended for use via Qawn and through which the User will be able to effect Transactions in accordance with these T&C.
· QR Code: means: (i) in respect of a User, the static Quick Response Code assigned to such User and which allows them to receive Transfers from other Users; (ii) via Cliq, and (iii) in respect of a Merchant, either a static Quick Response Code which a User may scan and/or upload to make a Transfer to the Merchant, and/or a dynamic Quick Response Code which is generated for each invoice payable by the User based on the purchase transaction value and data inserted by the Merchant whereby the User would scan and/or upload the said QR Code in order to make a Transfer to the Merchant accordingly.
· User: means an actual beneficiary user of the Service who has duly subscribed to same. “Users” shall be construed accordingly.
· The Service
o Upon your acceptance of these T&Cs, you are granting the Bank an absolute, unconditional and irrevocable permission and you consent to the Bank opening a QAWN Account for you and on your behalf including taking all measures as well as using and processing all data and information required as to enable the Bank to do so. For this purpose, you hereby agree to the Bank’s account opening terms and conditions.
o Once the Bank has opened a QAWN Account for you, you will be subscribed to the Service and you will become the holder of a QAWN Account through which you will be able to effect Transactions as more fully described in these T&Cs. You acknowledge and agree that the Bank has sole discretion to refuse opening the account without the need to provide any reasoning or clarification behind its decision and such decision shall be deemed final.
o You understand that, you will be able to receive local monetary transfers via CliQ, receive local and international monetary transfers via IBAN, return any amounts received via transactions either in whole or in part, requesting and being granted, once approved, facilities to be determined solely by the Bank, obtain a special QR code on the application QR code, receive payments via QR code (Quick Response Code), view your account statements, usage of a channel of communication and support and having the opportunity to financing/instalment service when purchasing from a supplier.
o You undertake not to use your Account for any commercial purposes and to use same for personal dealings only. You authorise the Bank to close your Account and take all measures it deems necessary should you use your Account in violation of the foregoing and without any liability to the Bank.
o You understand and acknowledge that a QR Code is automatically generated for each User. You therefore agree to hold the Bank, its affiliates, employees, shareholders and directors harmless against any loss or damage sustained as a result of any error in generating and/or sharing the relevant QR Code and therefore any inability to complete a Transfer.
o QR Codes may be shared with other parties, including, but not limited to, other Users and/or Merchants via WhatsApp, SMS, or any other medium, and once shared, the other Users can save the said QR Code on their Device’s photo gallery and then upload it via the Service in order to make a Transfer to the QAWN Account associated with the said User of the uploaded QR Code.
o You understand that by scanning and/or uploading a QR Code of another User, you are automatically adding that User as a Beneficiary for Transfers and that there will not be a need for you to re-confirm such details using any additional authentication mechanisms, including, but not limited to, a One-Time-Password (“OTP”). You agree and acknowledge that you are responsible for reviewing the Transfer details prior to making the said Transfer including ensuring that you have scanned/uploaded the correct QR Code so that the Transfer is received by intended Beneficiary. You agree to hold the Bank, its affiliates, employees, shareholders and directors harmless against any loss or damage sustained as a result of: (a) any error in generating and/or sharing the relevant QR Code and therefore the inability to complete the relevant Transfer; (b) any error in scanning the QR Code of the Beneficiary to which you wish to make a Transfer; (c) making a Transfer to an unintended Beneficiary.
o You understand that in order to make a Transfer to a Beneficiary via the Service without scanning their QR Code, you will need to adjust your Device’s settings in order to allow QAWN access to your Device’s contacts list and as such you then can select a the mobile number of the intended Beneficiary to whom you want to make a Transfer. The Beneficiary of said Transfer will receive a notification about the Transfer via the Service and/or via SMS.
o You further understand that any Transfer executed by selecting the mobile phone number of the intended Beneficiary that is not accepted via the Service prior to the Bank’s Close of Business will automatically be rejected and can no longer be accepted by the Beneficiary thereafter. For the avoidance of doubt, if the Transfer is executed by the User after the Bank’s Close of Business then the Beneficiary will be able to accept the said Transfer before Close of Business immediately after the time of executing the Transfer.
o You understand that by selecting the mobile phone number from your Device’s contacts list, you are automatically adding that contact as a Beneficiary for Transfers. You therefore agree to hold the Bank, its affiliates, employees, shareholders and directors harmless against any loss and/or damage sustained by you as a result of making a Transfer to an unintended Beneficiary.
o You can, at any time, access your Transaction history and track all Transactions you have completed through QAWN. You can also add other Users to your favourites in order to make Transfers to them expeditiously.
o You can, at any time, invite others to download the QAWN application via SMS messages to the mobile phone number you select from your Device’s contacts list via the Service for a fee to be set by the Bank. You understand that said SMS messages may result in a fee as solely determined by and owed to the telecom operator you are subscribed to. You therefore agree to hold the Bank, its affiliates, employees, shareholders and directors harmless against any loss and/or damage sustained by you as a result of making a sending said SMS messages. You acknowledge and understand that the Bank has the full and sole discretion to remove or modify this feature at anytime and for any reason without any liability.
o You may be entitled to receive certain rewards. Please refer to the Terms and Conditions of our conditional cash rewards programs by clicking on this link to learn more about our referral incentives.
o You acknowledge and understand that you may use the Service to scan QR Codes relating to the JoPACC-operated instant payment service, known as “CliQ”, and that upon scanning said QR Codes, you will effect a Transfer to the Beneficiary of said QR Code, and the amount of the said Transfer you wish to effect will be debited from your QAWN Account only, and you will not be able to select a different account for effecting said Transfer via the Service. You acknowledge and understand that effecting Transfers via the CliQ service may be subject to fees as determined by JoPACC and applied by the Bank on said payment service. You acknowledge that these fees may be subject to change from time to time.
· You waive any right of recourse against the Bank in relation to any loss and/or damage which you may incur as a result of your compliance and/or non-compliance with these T&C and/or a result of your use and/or misuse of the Service. You agree and undertake to defend, hold harmless, and indemnify the Bank, its affiliates, employees, shareholders and directors against any loss and/or damage which may be sustained by you as a result of your use and/or misuse of the Service.
· You acknowledge that the Bank’s data in relation the Service, your QAWN Account and any Transactions effected through same is final and conclusive and will be solely relied on to verify your QAWN Account balance and any Transactions effected by you through the Service, as well as any Transaction history related to your QAWN Account. You therefore waive any right to and undertake not to object to the aforementioned data.
· The Bank may, at any time, amend or change these T&Cs without notice to you and your continued use of the Service will be deemed as your acceptance of such changes and/or amendments. The Bank may also add and/or change and/or cancel the Service or any part thereof or any features, and/or capabilities relating to the Service or the software used in connection with same.
· User to User Transfer
o Using the Service, Users can (a) make Transfers from their QAWN Account to QAWN Accounts of other Users, and (b) receive Transfers to their QAWN Account from other Users.
o Using the Service, Users can make Transfers referred to in 6.1 by (a) scanning another User’s QR Code, or (b) uploading another User’s QR Code, or (c) selecting the User’s mobile phone number from their Device’s contacts list:
§ To make a Transfer to another User by scanning their QR Code, the User making the Transfer must use the QR Code scanning feature of the Service to scan the QR Code of the Beneficiary. Once the QR Code of the Beneficiary is identified by the Service, the User making the Transfer would need to enter the amount they wish to Transfer to the Beneficiary and click the “pay” button to confirm and execute the Transfer.
§ To make a Transfer to another User by uploading their QR Code, the User making the Transfer must grant QAWN access to the photo gallery on their Device (via their Device’s settings) and select the stored image of the QR Code associated with the intended Beneficiary for upload. Once the QR Code of the Beneficiary is identified by the Service, the User making the Transfer would need to enter the amount they wish to transfer to the Beneficiary and click the “pay” button to confirm and execute the Transfer.
§ To make a Transfer to a Beneficiary by using their mobile phone number, the User making the Transfer must grant QAWN access to the contacts lists on their Device (via their Device’s settings) and select the mobile phone number of the intended Beneficiary from said contact list. Afterwards, the User making the Transfer would need to enter the amount they wish to Transfer to that Beneficiary and click the “pay” button to confirm and execute the Transfer.
· User to Merchant Transfer
o Using the Service, Users can (a) make Transfers from their QAWN Account to Merchants, and (b) receive Transfers to their QAWN Account from Merchants.
o The User understands and acknowledges that the Merchant may have a static QR Code and the ability to generate dynamic QR Codes.
§ The User may make a Transfer to a Merchant using the Merchant’s static QR Code by following the same steps which need to be followed in order to make a Transfer to a Beneficiary, by scanning or uploading the QR Code (as detailed above), inserting the amount the User wishes to Transfer, and then pressing the relevant button to confirm and execute the Transfer.
§ The User may make a Transfer to a Merchant using the Merchant’s dynamic QR Code by following the same steps which need to be followed in order to make a Transfer to a Beneficiary, scanning or uploading the QR Code (as detailed above), with the exception of the User’s inability to enter the amount they wish to Transfer to the Merchant. In the case of a dynamic QR Code, the Merchant will enter the amount due for payment (Transfer) by the User in exchange for the product(s) and/or service(s) and will generate a QR Code for this amount, which will be presented to the User after scanning or uploading the said QR Code. The User may, using the Service, confirm and execute the Transfer by pressing the “Pay” button.
· By using the Service, the you hereby confirm and acknowledge that you have fully read, understood and agree to these Terms & Conditions and agree to be bound by them.
Privacy Policy
JAB Privacy Policy
Introduction
Welcome to the Jordan Ahli Bank’s privacy policy.
Jordan Ahli Bank (“JAB”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format as set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED?]
4. [HOW WE USE YOUR PERSONAL DATA]
5. [DISCLOSURES OF YOUR PERSONAL DATA]
6. [INTERNATIONAL TRANSFERS]
7. [DATA SECURITY]
8. [DATA RETENTION]
9. [YOUR LEGAL RIGHTS]
10. [GLOSSARY]
11. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how JAB collects and processes your personal data through your use of this website and online channels
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Changes to this privacy policy
We reserve the right to update and make amendments to this privacy policy from time to time. The user is responsible for checking the privacy policy periodically. These updates, amendments or deletions shall be effective immediately upon posting on the privacy policy. If this privacy policy is not agreeable to any user, then the user should abstain from using our website.
In the event of any material changes to the privacy policy, we will notify you about it by providing a notice to the email address you provided us with or by placing a prominent notice on our website. By continuing to use the website following any changes that will be interpreted as acceptance of such changes by the user.
Controller
This privacy policy is issued on behalf of the JAB Group so when we mention “JAB”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the JAB Group responsible for processing your data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Email address: [email protected]
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
· Identity andFamily situation Data includes first name, middle name, last name, username or similar identifier, marital status, number of children, title, date of birth and gender.
· Contact Dataincludes billing address, delivery address, postal address, email address telephone numbers, contact list ].
· Banking and Financial Dataincludes bank account and payment card details.
· Tax status Dataincludes tax ID tax status.)
· Technical Dataincludes [internet protocol (IP) address, your login data, browser type and version, information stored on malware applications installed on your devices, information pertaining to installed application, 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 this website].
· Profile Dataincludes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses] and your photos which you grant us access to through using our mobile applications.
· Usage Dataincludes [information about how you use our website, products and services].
· Marketing and Communications Dataincludes [your preferences in receiving marketing from us and our third parties and your communication preferences].
· Education and employment information (includes Level of education, employment, employer’s name, remuneration)
· Data relating to your habits and preferences:
· Data which relates to your use of our products and services including banking, financial and transactional data.
· Data from your interactions with us, our branches (contact reports),our internet websites, our apps, our social media pages, meetings, calls, emails, interviews, phone conversation:
· Video surveillance (including CCTV) and geolocation data (e.g. showing locations of withdrawals and payments, for security reasons, or to identify the location of the nearest branch or service suppliers for you): and
· Data necessary to fight against over indebtedness.
We may collect the following sensitive data only upon obtaining your explicit prior consent:
· Biometric data includes fingerprint, voice pattern or facial recognition which can be used for identification and security purposes, and
· Health data for instance for the drawing up of some insurance contracts this data is processed on need-to-know basis.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership,). Nor do we collect any information about criminal convictions and offences unless it is required through a legal obligation.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to subscribe or use a specific product or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
· Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our products or services and the personal data which we receive from the relevant authorities upon verifying the data which you have provided us with (including the Civil Status and Passports Department and other authorities) ;
· create an account on our website;
· subscribe to our Digital service or publications;
· request marketing to be sent to you;
· enter a competition, promotion or survey; or
· give us feedback or contact us.
· Automated technologies or interactions. As you interact with our website and digital channels, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
· In certain circumstances, we may collect and use personal data of individuals with whom we have, could have, or previously had, a direct relationship such as:
· Visitors to our websites and digital channels.
· Prospective or existing clients: or.
· Attendees of our events
· We may also collect information about you where you do not have a direct relationship with us. This may happen, for instance, when your employer provides us with information about you or your contact details are provided by one of our clients if you are, for example:
· Family members
· Co-borrowers/guarantors,
· Legal representatives ( power of attorney)
· Beneficiaries of payment transactions made by our clients:
· Beneficiaries of insurance policies and trusts:
· Landlords:
· Ultimate beneficial owners:
· Clients debtors ( e.g. in case of bankruptcy )
· Company shareholders
· Representative of a legal entity (which may be a client or a vendor) and
· Staff of services provider and commercial partners
· Third parties or publicly available sources.We will receive personal data about you from various third parties and public sources as set out below :
Technical Data from the following parties:
· analytics providers;
· advertising networks; and
· search information providers.
· Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
· Identity and Contact Data from data brokers or aggregators.
· Identity and Contact Data from publicly available sources.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract, we are about to enter into or have entered into 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.
· Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for 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.
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new customer |
(a) Identity |
Performance of a contract with you |
|
To process and deliver your order including: |
(a) Identity |
(a) Performance of a contract with you |
|
To manage our relationship with you which will
include: |
(a) Identity |
(a) Performance of a contract with you |
|
To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity |
(a) Performance of a contract with you |
|
To administer and protect our business and this website and digital channels (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity |
(a) 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
reorganisation or group restructuring exercise) |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about products or services that may be of interest to you |
(a) Identity |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
|
To deploy and develop products or services, to
improve our risk management and to defend our legal rights, including: |
(a) Identity |
Necessary for our legitimate interests |
|
To deploy and develop products or services, to
improve our risk management and to defend our legal rights, including: |
|||
Collecting your location details via our applications to provide you with the nearest ATM or branches. |
Technical |
Necessary for our legitimate interests (to enable you to transact through the bank) |
|
Accessing your contact list through our mobile applications to allow you to select a payee to effect a payment |
Contract data |
(a) Performance of a contract with you |
|
Accessing your camera through our mobile application only to allow you to make payments through scanning QR codes and to allow you to select a picture as your profile picture. |
Profile |
Necessary for our legitimate interests (to enable you to transact through the bank) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Marketing
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting DPO at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.
· Internal Third Parties as set out in the Glossary.
· External Third Parties as set out in the Glossary.
· Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
· JAB Group entities (e.g. so that you may benefit from our full range of group products and services) If you are a client of our corporate and institutional Banking business, this would include, for example, personal date being accessed and /or stored in jurisdictions in which and through which transactions are effected, and jurisdictions from which you regularly receive or transmit information about your business with JAB.
· Services providers which perform services on our behalf.
· In depended agent, intermediaries or, banking and specialised partners, with which we have a regular relationship
· In particular, in relation to our corporate and institutional banking business, we may disclose your personal data.
· To any counterparty, custodian, depositary, or nominee appointed or instructed by us on your behalf, or on behalf of the entity you represent, or through whom we may deal or transact in relation to your account or for purposes otherwise ancillary to the provision of services provided by JAB to you or the administration of your account.
· To any licensed credit agency in order to perform a credit assessment for any credit or mortgage-based products requested by or applied for by you and to tracing agents to recover debt:
· To any rating agency, insurer or other provider or credit protection to JAB.
· To fraud prevention agencies (FPA’s) in order to check the identity of the client or individuals or to investigate or prevent money laundering fraud, or other illegal activity, and
· If the disclosure relates to the actual or potential transfer or novation of one or more transactions pursuant to any applicable Terms of Business (or risks relating to such transactions) by us.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the JAB Group. This will involve transferring your data outside) Jordan and the European Economic Area (EEA).
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.
[Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
· Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
· Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 15 years after they cease being customers.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. these rights are:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, 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.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
· If you want us to establish the data’s accuracy.
· Where our use of the data is unlawful but you do not want us to erase it.
· Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
· You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
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.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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 your personal data (or to exercise any of your other rights). This is a 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and 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 law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting DPO.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other companies in the JAB Group acting as joint controllers or processors and who are based and provide IT and system administration services and undertake leadership reporting.
External Third Parties
· Service providers acting as processors who provide IT and system administration services.
· Professional advisers acting as processors or joint controllers including lawyers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
· Regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances. Financial taxation, judicial authorities, state agencies.
JAB Cookie policy
Our website and digital channels use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our website and allows us to improve our site.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
· Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
· Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
· Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
· Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Cookie Name/Title |
Purpose |
More information |
|
[Java Session ID][JSESSIONID] |
Used for identifying the user and authorize to
consume post login services. |
https://javarevisited.blogspot.com/2012/08/what-is-jsessionid-in-j2ee-web.html |
|
[Google Recaptcha] |
Re-captcha uses cookies which identifies
whether the service request are initiated by human or bot |
https://www.termsfeed.com/blog/privacy-policy-recaptcha/ |
To deactivate the use of third-party advertising cookies, you may visit the consumer page to manage the use of these types of cookies.Please note that third parties may also use cookies, over which we have no control. These third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies
You can block cookies by activating the settings on your browser that allows you to refuse the settings of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our websites.
Terms and Conditions for Enrollment in the Digital Channels Services
The Customer understands that by enrolling in the Services, the Customer will be bound by the following terms and conditions:
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By using the Digital Channel Services, I/we (as the case may be), hereby acknowledge that I/we have read these Terms and Conditions and understood them in their entirety and accept to be bound by them.