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GFH Data Privacy Notice

GFH Capital (hereafter referred to as “we” or “our” or “us” or “organization”) respects your right to data privacy. In this Notice “You” or “Your” refers to data subject (customers, employees, website visitors or contingent workers) whose personal data is processed by GFH Capital.

This privacy notice explains who we are, how we collect, share and use personal data about you, and how you can exercise your data privacy rights. The details on what personal data will be processed and which method will be used depend significantly on the services applied for or agreed upon.

Scope of this Policy

This Privacy Policy applies to all personal data collected by GFH Capital from our customers, website visitors, job applicants, and any other individuals whose personal data we process. This includes data collected through our website, mobile applications, branches, and other channels.

When do we collect your Personal Data?

Direct interactions

You may give us your identity, contact, resume by filling in forms or by corresponding with us by phone, and email or otherwise. This includes sharing of Personal Data for the following purpose:

  1. Records of your interactions with us such as emails and other correspondence and your instructions to us;
  2. Providing your feedback;
  3. By filling in forms, for example to download white papers and/or gather insights on case studies;
  4. By sharing your Personal Data such as resume for recruitment purpose;
  5. By interacting with us on social media platforms such as Facebook, Instagram and LinkedIn etc.
  6. By subscribing to our newsletter on our website or other online medium/channel

Automated technologies or interactions

Log Files. 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, which is stored in log files.

 

Cookies. 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, browsing actions and patterns, to better understand how you interact with our service, to provide you advertising on and off the service, and to monitor usage by visitors and 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. If you do not accept cookies, however, you may not be able to use all portions of our service or all functionality of our service.

 

Please see our cookie policy for further details.

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 parties:
  • Analytics providers such as Google, Facebook;
  • Social media platforms such as Facebook, Twitter, Instagram or LinkedIn

 

What Personal Data do we collect?

We may collect, store, and use the following categories of Personal Data about you:

Identity Data

  1. Full name
  2. Resume

Contact Data

  1. Email address
  2. Telephone numbers/ contact number

Financial

  1. Bank Account Details
  2. credit/debit card information
  3. income details
  4. credit history

Technical Data

  1. Internet protocol (IP) address;
  2. We also track how often you visit and use our website. We do this via email and website cookies and similar tracking technology built into our website. Please see our cookie policyfor further details.

Profile Data

  1. Your interests, preferences, feedback and survey responses;
  2. Profile image;
  3. About (mentioned in resume);

 Usage Data

  1. Information about how you use our website, products and services;
  2. Information on what you view, click on access by way of our emails and text messages, website and 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 for providing you better services. We may also collect your Personal Data for responding to your queries and comments, social media posts and questions/ queries.

Aggregated Data (sometimes referred to a pseudonymised data)

We also collect, use and share aggregated data (sometimes referred to a pseudonymised data) such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data in the applicable law (s) as this data does 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 data privacy notice.

Sensitive Personal Data or Special Category of Personal Data

We do not collect, store and use the following “special categories” of Sensitive Personal Data regarding you such as:

  1. Information about your race or ethnicity, religious beliefs and sexual orientation;
  2. Information about your health, including any medical condition, health and sickness records, medical records and health professional information;
  3. Any criminal records information in relation to you, and
  4. Biometric information about you, for example fingerprints, retina scans.

 

Our intent is not to collect or process any Special Category of Personal Data about you, unless required by applicable laws. However, in certain circumstances, we may need to collect, or request your Special Category of Personal Data for employment related purposes via resume shared, for example, data regarding your hobbies and preferences, gender and disabilities for the purposes of equal opportunities monitoring, to comply with anti-discrimination laws and for government reporting obligations.

 

How We Use Your Personal Data

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. We will use your personal data in the following circumstances:

  1. To provide you with our services: To process your applications, and provide you with our services you have requested.
  2. To comply with our legal obligations: To comply with applicable laws and regulations, such as anti-money laundering and counter-terrorism financing laws.
  3. For our legitimate interests: To manage our business, improve our services, and protect our legal rights.
  4. For marketing purposes: To send you marketing communications about our services, but only with your consent.

 

 Legitimate Interest

  1. 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;
  2. 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;
  3. 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).
  4. We may also use your Personal Data in the following situations, which are likely to be rare:
  5. Where we need to protect your interests (or someone else’s interests);
  6. Where it is needed in the public interest or for official purposes.

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 which of the lawful base(s) 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.

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 in 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 which 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:

a) Notifying you about changes to our terms or privacy policy

b) Asking you to leave a review or take a survey

c) Responding to your queries and comments, social media posts and questions.

a) Identity

b) Contact

c) Profile

a) Performance of a contract with you

b) Necessary to comply with a legal obligation

c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

d) Your consent

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) a) Identity

b) Contact

c) Technical

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 reorganization)

b) 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 may serve to you a) Identity

b) Contact

c) Profile

d) Usage

e) Technical

a) 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 to improve our website, products/services, marketing, customer relationships and experiences a) Technical

b) Usage

c) Aggregated Data

a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant)
To make suggestions and recommendations to you about goods or services that may be of interest to you, where we choose to do so. a) Identity

b) Contact

c) Technical

d) Usage

e) Profile

f) Aggregated Data

a) Necessary for our legitimate interests (to develop our products/services)
a) To power our security measures and services in order to protect you and our business a) Identity

b) Technical

c) Usage

a) 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 Personal Data we will ask you to provide, and the reasons why we ask you to provide the Personal Data, will be made clear to you at the point we collect your Personal Data.

However, we may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) 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.

Who do we share your Personal Data with?

On occasion we may have to share your Personal Data with the parties set out below for the purposes set out.

Internal Third Parties / Our Group Companies

. For example, we’ll share information from our website at https://gfh-capital.com/ with the internal third parties, having similar arrangements between our other businesses. This is because we hope to have a relationship with you across all our businesses, if not now, then sometime in the future and we want to be able to provide you with the same value for money and high-quality experience for the services provided to you by us. It’s also the only way we can provide you with the best benefits.

External Third Parties

  1. Regulators and other authorities: acting as processors or Joint Controllers based in Bahrain who require reporting of Processing activities in certain circumstances.
  2. With social media companies such as Facebook, Twitter and LinkedIn: who run promotions for you on their platforms;
  3. Any new business partners: we may have over time, for example, in the event of a joint venture, reorganization, business merger or sale that affects us.
  4. The Police, local authorities, the courts and any other government authority: if they ask us to do so (but only if our doing so is lawful).
  5. Other people who make a ‘data subject access request’: where we are required to do so by law.
  6. We may also share the information we collect where we are legally obliged to do so, e.g. to comply with a court order.
  7. Any social media posts or comments you send to us (on the GFH Capital Facebook page, for instance) will be shared under the terms of the relevant social media platform (e.g. Facebook, Twitter and LinkedIn) on which they’re written, and could be made public. These platforms are controlled by third parties and not by us, and their use of your information is governed by their own terms and privacy policies, which we would encourage you to review. Any comments you post about us or our products and services on a public platform may be visible to other users of that platform and to the public at large.
  8. 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 notice. 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 will ensure that any third party with whom we share your personal data is contractually bound to protect your data and to use it only for the purposes for which we have shared it.

International Transfers

We share your Personal Data within the Group on need to know basis with confidential obligations mentioned here in. This may involve transferring your data outside the Kingdom of Saudi Arabia.

Some of our external third parties are based outside the Kingdom of Saudi Arabia and so their Processing of your Personal Data will involve a transfer of data outside the Kingdom. Whenever we transfer your Personal Data out of the Kingdom, 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.

Please contact us if you want further information on how we transfer your Personal Data out of the Kingdom.

International Data Transfers

 

How 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’s 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. Network security solutions like firewalls and / or network access control to 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 actually need it for the purposes we acquired it for in the first place. After that we will either delete it, mask it or anonymize 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, performance of a task carried out in the public interest or in the exercise of official authority vested or for the purposes of satisfying any legal, accounting, or other regulatory reporting requirements or with your consent.

By law we have to keep basic information about our customers (including contact and identity data) for 10 years after they cease being customers for legal purposes.

 

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 and by sharing your updated details with our Data Protection Officer at

Your rights in connection with Personal Data

Under certain circumstances, by law you have the right to:

  1. The right to be informed: You have the right to be informed about how we collect and use your personal data.
  2. The right of access: You have the right to access your personal data and to receive a copy of it.
  3. The right to rectification: You have the right to have your personal data rectified if it is inaccurate or incomplete.
  4. The right to erasure: You have the right to have your personal data erased in certain circumstances.
  5. The right to restrict processing: You have the right to restrict the processing of your personal data in certain circumstances.
  6. The right to object: You have the right to object to the processing of your personal data in certain circumstances.
  7. Rights in relation to automated decision-making and profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
  8. The right to withdraw consent: If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time.
  9. The right to complain: You have the right to lodge a complaint with SDAIA if you believe that we have infringed your rights under the PDPL.

Time limit to respond

 

To exercise any of these rights, please contact our DPO. Upon receiving your request, we will acknowledge it and process it without undue delay, ensuring that it is resolved within a period not exceeding 30 days in accordance with the applicable PDPL requirements. This period may be extended for an additional 30 days where necessary, such as in cases requiring disproportionate effort or where multiple requests are received from the same Data Subject. In such instances, the Data Subject will be notified in advance of the extension along with the reasons for the delay.

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 dpo@gfh-capital.com.

 

Indemnity and Limitation of Liability

You agree to defend, indemnify and hold harmless GFH Capital, 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 organization 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 necessary steps to implement appropriate security measures and utilize a virus scanner before downloading any information from the website.

To the fullest extent permitted by applicable law, GFH Capital, its officers, directors and employees do not accept liability for any loss or damage arising from your use of, access to, or inability to use this website or the information available on it, or from any errors or omissions in its contents. Nothing in this notice excludes or limits any liability that cannot be excluded or limited under applicable law, including liability for fraud, gross negligence or wilful misconduct.

Intellectual Property Rights

All content on this website, including text, images, graphics, layout, the GFH and GFH Capital names, logos and trade marks, is owned by or licensed to the organization and is protected by copyright, trade mark and other intellectual property rights. No content from this website may be copied, distributed, reproduced, adapted or otherwise used without the prior written approval of the organization. Nothing on this website is to be construed as granting any licence or right to use any such name, logo or trade mark.

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.

You can see when this privacy notice was last updated by checking the “last updated” date displayed at the top of this privacy notice.

If you have any questions about this privacy notice, please contact us dpo@gfh-capital.com.