Privacy Notice

The purpose of this Confidentiality notice is to explain how the Bank ("Bank ABC Algeria", "we", "us" and "our") may process your personal data.

The processing of personal data is a generic term covering the collection, recording, updating, destruction, consultation, analysis and transmission of personal data. This processing may involve operations in association with ABC Group.

The purpose of this Confidentiality notice is to explain how the Bank ("Bank ABC Algeria", "we", "us" and "our") may process your personal data.

The processing of personal data is a generic term covering the collection, recording, updating, destruction, consultation, analysis and transmission of personal data. This processing may involve operations in association with ABC Group.

For the purposes of this Confidentiality notice, "personal data" is information:

• Which identifies you or which can be used to identify you ;
• Relate to, describe, or be associated with; or
• Which may be (directly or indirectly) related to you ;
• Which can be used to authenticate you or give you access to an account.

Where the customer of Bank ABC Algeria is a natural person, any reference to "customer" and "you" shall mean that natural person.

The term "you" refers to the "customer" whose personal data is declared to us by the customer, as well as the personal data of any person having a permanent or occasional relationship with the customer in accordance with the legal provisions in force. We could specify here that this concerns data relating to what the customer presents as personal data linked to acts of civil status (therefore indirectly involving personal data linked to relatives) and for the purpose of the contract concluded with Bank ABC Algeria.

Where the customer of Bank ABC Algeria is a legal entity, any reference to "you" shall mean any natural person directly or indirectly linked to the legal entity.

The personal data we collect as a result of transactions with a legal entity is generally limited to details of the owners (direct, indirect and beneficial), directors, authorised persons, guarantors and any other person connected with the legal entity whose details necessarily appear on the documents provided by the legal entity.

In the case of natural persons, any related person as defined above will be subject to the same procedure as the customer.

In the case of legal entities, their legal representatives as defined (managing director, beneficial owners and any natural person with authority to bind bank ABC Algeria) must ensure that each related person receives a copy of this Confidentiality Notice before their personal data is processed by bank ABC Algeria.

We process your personal data where we have your consent and essentially to enable us to fulfil your requests, any agreements with you and comply with legal obligations.

In some cases, we may use your personal data to protect any legitimate interests of the bank or third parties, including the defence of the bank's legal rights or those of an employee of Bank ABC Algeria or a third party employed by us, in strict compliance with the law.

Some of the reasons for processing below may overlap and there may be several reasons for our use of your personal data.

Related 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 this reason is compatible with the main purpose.

 Please note that we may process your personal data without your knowledge or consent, in accordance with the above rules, where this is required or permitted by law.

• To establish, maintain, fulfil and administer the contractual relationship we have with you;
• Providing you with products and services and processing data to enter into or perform a contract we have with you;
• Allow you to manage your account and carry out transactions with us;
• Perform credit assessments and checks;
• Collect a debt (which may involve passing on your personal data to debt collection agencies);
• Assess the relevance of our products and services to your needs;
• Keep records of your instructions, transactions and communications for any other evidence required, and prevent or detect financial crime or suspected financial crime, including (but not limited to) fraud, money laundering and terrorist financing;
• Test the performance of our products, services and internal processes;
• Administer our internal operating conditions (including credit, compliance and risk management, market research, systems and product development, staff training, quality control, accounting and auditing);
• Keep records of activities carried out on our digital platforms, websites or mobile applications, such as the time-stamp and duration of your connection;
• Process requests relating to the exercise of your rights under data protection laws;
• Develop statistics and for market research, surveys and analyses, including to develop and improve our products and services so that we can offer you new and improved products and services, which may include converting your personal data into statistical or aggregated data that cannot be used to identify you.
  

The personal data we process includes the data you have provided to Bank ABC Algeria , such as:

• Personal data including full name, nationality, gender, date of birth, country of birth, social status, names of related persons, employment status, photos, signature;
• First names, last names, dates of birth and contact details of Collateral ascendants and descendants and dependents.
• Data relating to your identity, including identity documents, biometric data, identity card details, passport details, social security or national insurance number, driving licence number;
• Contact details, including residential address, e-mail addresses, telephone numbers and proof of address;
• Employer, employment status, position, full name, e-mail address, address and telephone number(s) used for business purposes;
• Financial data: income and source of income, source of wealth, account activity and engagement data;
• Details of your tax status,
• Other data provided by you via fill-in forms and other means, including e-mail, electronic messages, recorded calls and face-to-face contact.

The personal data we collect or generate in the course of our business activities includes:

• Details of transactions carried out by you or one of your connected persons.
• Details include dates, amounts, currencies, payer and payee details;
• Data about your relationship with us, the channels you use and the ways in which you interact with us, the technology you use to do so and your language preferences;
• Information on your ability to obtain and manage credit;
• Data concerning complaints and disputes or cases where you have exercised your legal rights relating to the protection of your personal data;
• Market research data, e.g. opinions expressed by you when participating in our market research campaigns or surveys;
• Risk rating information, e.g. credit risk rating, transaction behaviour and underwriting information;
• Due diligence data, e.g. data required to comply with financial crime regulations (anti-money laundering, combating the financing of terrorism, etc.);
• Data used to identify you such as user names, PIN codes, passwords, signatures and biometric information (e.g. fingerprint, iris scan, voice, facial recognition) or a physical token (e.g. debit or prepaid card, security token or electronic key) that is required when using our products or services;
•  E-mail addresses and telephone numbers used to receive digital alerts (i.e. a text or e-mail alert that we send to inform our customers about certain types of transactions or to provide financial information);
• Information about your device or the software you use, e.g. its IP address, technical specifications and unique identification data;
• Data concerning your geographical location and the ATMs you use;
• The data we need to meet our regulatory obligations, e.g. information on transaction details, the detection of suspicious and unusual activity and data on the parties to which you are linked for these activities;
• We may record calls, emails, text messages, social media posts and other communications between you and ABC Group employees;
• Closed circuit television ("CCTV") systems, with or without audio recording, used in and around our premises and ATM locations for physical security and crime prevention purposes; as a result, we may have images of you captured by our CCTV cameras;
• Online identifiers that can leave traces which, when combined with unique identifiers and other data received by servers, can be used to identify the user. Online identifiers may include Internet Protocol addresses (IP addresses) and cookie identifiers (although we do not generally use cookies to track or identify individual users). For more details on cookies, please consult our online cookie policy.
• Data relating in particular to transactions carried out on our digital platform by users. As long as our banking relationship is with our customer, we will collect data specific to transactions carried out by users. For example, we may inform our customer of details (such as dates, amounts, currencies, payer and payee details) of transactions made on our digital platform and which user initiated the transactions. Some of these may be personal data about the user.
  

We collect your personal data from a number of sources, including:

• The data you provide when we establish, administer and manage our relationship with you;
• Data that we receive directly from you or from a person acting on your behalf;
• Data we obtain from third parties, such as credit references, debt recovery, fraud prevention or government agencies;
• The data we collect from publicly accessible sources such as the Internet;
• The data we collect through your use of our services and products, such as when you use our digital platforms or mobile applications, when you visit our websites or when you interact with us via a registered channel (e.g. a registered telephone line);
• The data we identify through our fraud prevention checks;
• Data provided by other members of the ABC Group;
• Data we receive directly from your engagement with our social media platforms.
  
  

We may process information about your physical or mental health or disability status:

• In limited circumstances, with your express written consent.
• When we need to fulfil our legal obligations or exercise our rights.
• When necessary in the public interest.

Less frequently, we may process this type of information where it is necessary in connection with legal claims or where it is necessary to protect your interests (or the interests of someone else) and you are unable to give your consent, or where you have already made the information public.

Bank ABC Algeria can record and track your conversations with it, including phone calls, face-to-face meetings, letters, emails, live chats and any other type of communication.

​These recordings will be used to verify your instructions, evaluate, analyse and improve the quality of our services, train our staff, manage risks or prevent and detect fraud and other offences.

Bank ABC Algeria may also capture additional data about these interactions, e.g. the telephone numbers from which you call us and data about the devices or software used.

We may carry out credit and identity checks with the relevant bodies such as credit rating agencies, the credit bureau or others when you apply for a loan (personal loan, mortgage, car loan, etc.) or when we examine these loans.

To do this, we need to share your personal data with these organisations, including details of the credit application, your financial situation and your financial history. We will also inform these organisations of your reimbursement history.

We may use the data received from these organisations to:

Assess whether we can offer you credit and whether you are eligible for the product you have requested;

• Check the accuracy of the data you have provided;
• Preventing criminal activity, fraud and money laundering;
• Manage your account(s);
• Trace and collect debts, and
• Ensure that all the offers you receive are tailored to your circumstances.

We may use your data to inform you about products and services offered by Bank ABC Algeria or ABC Group.

You may withdraw your consent for these marketing purposes at any time. For more information, see the "Your right to data protection" section of this Notice.

Please note that Bank ABC Algeria will continue to use your details to provide you with important information, such as changes to our terms and conditions or where we have legitimate reasons to do so, including compliance with our regulatory obligations.

We are unable to establish or manage our relationship with you without some of your personal data.

Where providing us with your personal data is optional, we will make this clear, for example by explaining in the forms whether certain fields can be left blank.

When using the digital platforms managed by Bank ABC Algeria, we will collect your consent in order to justify the processing of your personal data.

You are responsible for ensuring that the data you provide is accurate.

If any of the personal data you have provided changes, such as your contact details, please inform us immediately.

Likewise, if we have collected personal data about you that you consider to be inaccurate, please let us know.

Please refer to the "How to contact us" section below to find out how to contact Bank ABC Algeria to update your information.

Bank ABC Algeria may share your personal data with other parties connected to you as set out above.

Bank ABC Algeria may share your data with third parties - "third parties" includes third party service providers (including contractors and appointed agents) as well as ABC Group - in accordance with legal requirements, including where we or such parties are involved:

• We need your personal data to provide you with the products or services you have requested;
• We have a legal obligation to do so, e.g. to help detect and prevent fraud, tax evasion and financial crime;
• For regulatory reporting, litigation or to assert or defend legal rights and interests;
• We have a legitimate business reason for doing so, such as risk management, verifying your identity, enabling another company to provide you with the services you have requested or assessing your suitability for products and services;
• We have asked for your permission to share them, and you have consented.

Bank ABC Algeria may share your data for the specific purposes below with other third parties, including :

• Any person who instructs or operates one of your accounts on your behalf, e.g. holders of a power of attorney, lawyers, intermediaries, auditors, statutory auditors, the person to whom you have entrusted the management of your account and any other person with whom we have been instructed to share your personal data, by you, a joint account holder or any other person who instructs or operates one of your accounts on your behalf;
• All joint account holders, administrators, beneficiaries, public officers of the estate, your legal representatives and their advisers, for the purposes of carrying out a transaction on your account, 
• The parties who provide guarantees (or other security) for the amounts you owe us;
• The parties to whom you make payments or from whom you receive payments;
• ABC Group (including their employees, sub-contractors, service providers, directors and officers) and any of their sub-contractors, agents or service providers such as, for example, providers of server backup and hosting services, providers of computer software and maintenance, providers of document storage and providers of other processing and support services;
• Our legal and professional advisers and certain service providers, such as auditors and external legal advisers, as well as payment method personalisation companies, etc.
• Other financial institutions, clearing houses, custodians, counterparties, fund managers, lenders and security holders on any property you invoice to us;
• Other financial institutions, clearing houses, custodians, hedgers, fund managers, lenders and security holders in respect of any property invoiced by you to us;
• Our business partners with whom we may have agreed to provide a service to you, and any party who provides marketing services to us;
• Parties involved in any litigation for enforcement of the law, government, courts, dispute resolution bodies, our regulators, auditors and any party appointed or required by our regulators to conduct investigations or audits of our activities;
• The card service providers or merchants for whom we must disclose the operation of the cards we have supplied to you;
• Any intermediary to whom we provide instructions or recommendations;
• With any party for a transaction involving risk, or in relation to Bank ABC Algeria's products and services;
• Any governmental, banking, tax or other regulatory authority or similar body having jurisdiction over ABC Group, or under the rules of any relevant stock exchange, including those based abroad (subject to the prior consent of the national data protection authority); 
• Any member of ABC Group to enable you to access our products and services. This includes our account managers (if employed or contracted by a member of the ABC Group) and our IT support teams for digital platform services;
• Any prospective participant or actual sub-participant assignee, beneficiary or novation (and their employees and advisers) in respect of any of our obligations to you under a banking contract,
• The courts, and to any other extent necessary to manage legal cases, to protect vital interests and to protect the security and integrity of our business operations or those of ABC Group.

All of our third-party service providers and the ABC Group to whom your personal information is provided, are required to take appropriate security measures to protect your personal information in accordance with our policies.

We do not authorise our third-party service providers to use your personal data for personal purposes. We only allow them to process your personal data for specific purposes and in accordance with our instructions.

We will share your personal data with ABC Group as part of our regular activities.
​

We may need to share any of the above data with ABC Group where this is required to enter into our contract with you, to comply with a legal obligation, to protect the public interest and/or for our own legitimate interests.

In accordance with current Algerian legislation on the protection of personal data, the transfer of your data abroad is subject to prior authorisation from the National Authority for the Protection of Personal Data (ANPDCP).

For more information on these measures, please refer to the "How to contact us" section.

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it was collected (as described above). Even when you close your account with us, we retain a minimum set of your personal data for as long as necessary to comply with legal and regulatory requirements or in the event of complaints or in order to respond to one of your requests.

Such personal data includes:

• Activities and transactions carried out by users on the customer's account via our digital platform;
• Username (used in our digital platform) of a logged-in person who no longer works for our customer.

Please contact us in accordance with the "How to contact us" section of this notice if you would like more information about the retention of personal data.

We will continue to protect your personal data securely and your rights as set out in this Confidentiality notice will remain in place until your personal data is securely deleted from our systems.

The criteria we use to determine the retention periods for your personal data include the following:

• Storage in the event of requests, we will store some of them in the event of requests from you (for example, if you submit a request for a product or service for the Customer and it is unsuccessful);
• Retention of claims, some of which we will retain for as long as the Customer may lawfully make a claim against us; and
• Retention in accordance with legal and regulatory provisions, we will retain certain data after termination of our contract with the Customer and, in respect of access to our digital platform, after termination of such access, on the basis of our legal and regulatory conditions.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised manner, modified or disclosed.

In addition, we restrict access to your personal data to employees, agents, contractors and other third parties who have a professional need to know. They will only process your personal data on our instructions, are subject to a duty of confidentiality and are required to implement appropriate technical and organisational measures to ensure data security.

We have procedures in place to deal with any suspected breach of data security, and we will notify you and any regulatory body "the national authority" of any suspected breach where we are legally required to do so.

Reminder of the fundamental rights protected by Law 18-07:

• The right to information: the content of the processing mentioned in article 32 of law 18-07 relating to the protection of individuals in the processing of personal data;
• The right of access: the content of the processing mentioned in article 34 of law 18-07;
• The right of rectification: the content of the processing mentioned in article 35 of law 18-07;
• The right to object: the content of the processing mentioned in article 36 of law 18-07;

And so,

• The right to be informed about the processing of your personal data.
• The right to have your personal data rectified, updated, erased and blocked if its processing does not comply with applicable law
• The right to complete your personal data if they are inaccurate and/or incomplete.
• The right to supplement your personal data if it is inaccurate and/or incomplete.
• The right to restrict the processing of your personal data.
• The right to request access to your personal data and obtain information about how we process it. 
• The right to move, copy or transfer your personal data (data portability).
• The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or significantly affects him.
• The right to withdraw your consent at any time

Please note that these rights are not absolute and do not apply in all circumstances to:

• Compelling and legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; where
• The processing is intended for the establishment, exercise or defense of a right in court.

If you wish to exercise any of these rights, please contact us by referring to the "How to contact us" section.

In addition, you have the right to lodge a complaint with the National Authority for the Protection of Personal Data (ANPDCP), which has enforcement powers and can investigate compliance with data protection laws.​

There may be other terms and conditions in our customer contracts that will apply to our use of your personal data. These terms and conditions must be read in conjunction with this confidentiality notice.​

If you have any questions about this Confidentiality notice or how Bank ABC Algeria handles your personal data, please contact us at ABCADataProtection@Bank-ABC.com.​