Any information in any form relating to an identifiable individual, or an individual who can be identified, directly or indirectly, particularly through his/her personal ID number, or one or more of his/her physical, physiological, intellectual, cultural or economic characteristics or social identity. In order to determine whether an individual could be identified, all the means used by, or that may be available to, the Data Manager or any other person shall be taken in consideration. Personal data that we collect may include names, ID and passport numbers, dates of birth, emails and addresses. The type of personal data and supporting documentation that we regularly obtain from you is as set out in our service application forms.
Any personal information that reveals, directly or indirectly, the individual’s race, ethnicity, political or philosophical views, religious beliefs, union affiliation, criminal record or any data related to his/her health or sexual life.
The person who decides, solely or in association with others, the purposes and means of processing certain Personal Data. Where such purposes and means are prescribed by Law, the Data Manager shall be the person responsible for processing all relevant Personal Data.
The person who processes personal data for and on behalf of the Data Manager, not including persons who works for the Data Manager or Data Processor.
Any operation or set of operations carried out on Personal Data by automated or non-automated means, such as collecting, recording, organising, classifying in groups, storing, modifying, amending, retrieving, using or revealing such data by broadcasting, publishing, transmitting, making them available to others, integrating, blocking, deleting or destroying them.
Any communication, by any means, through which a marketing or advertising material is directed to a specific person.
As part of our legitimate business use, and for the purpose of providing our services, we must and do collect and process the following categories of personal data about our past, existing and prospective customers:
|Data class||Indicative data elements (not an exhaustive list)|
|Identifiers||CPR, Passport etc.|
|Contact information||Email, phone number (mobile and fixed), etc.|
|Documents||For example, any service terms and conditions and/or application forms you conclude between yourself and us|
|Account information||For example, the subscription services you use or other details related to your account.|
We collect Personal Data that you provide voluntarily through our website: for example, when completing online forms to contact us, subscribing to a newsletter, subscribing to receive marketing communications from us, participating in surveys or registering for events that we are organising. Personal data we collect may include:
We do not intentionally collect sensitive Personal Data. Information provided by you on behalf of a wholly or partially incompetent data owner shall be considered within the limits of the law if you are the legal guardian, executor or custodian.
When you visit our websites and web applications, we collect certain Personal Data automatically from your device such as:
We also collect information about how your device has interacted with our site, including webpages accessed and links clicked. Collecting this information enables us to better understand visitors who come to our website, such as where they come from and what content on our website is of interest to them. We use this information for internal analytics and to improve the quality and relevance of our website for our visitors. Please note that we are not responsible for any personal data that may be collected and processed by any third party (i.e. any party other than us) as a result of any person accessing any third party plugin or website though our website.
Surveys are conducted by us or on our behalf by third parties. You will voluntarily provide us with Personal Data when participating in and completing a survey (“Survey”). Where you choose not to participate in a Survey, you may not qualify for certain rewards or benefits. Upon completion of a Survey, we may use the information provided by you and other consumers to analyze consumer preferences and contact you to enhance your experience with us. Following your feedback, we may contact you to verify the accuracy of a Survey, to verbally deliver a Survey, to provide customer service, or to award benefits earned as a consequence of completing a Survey. Third parties collecting personal data on our behalf will have undertaken, in advance and in writing, to maintain the confidentiality, integrity and security of the Personal Data provided by you, in accordance with applicable laws. Such third parties may also use the Personal Data provided by you, upon completion of a Survey, for purposes described in their privacy policies. You may discontinue participating in Surveys at any time.
We may process your Personal Data for any or all of the following purposes:
We rely upon the following legitimate bases to process your Personal Data:
We will provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use your identity, contact, technical, usage and profile data to identify potential services which may be of interest to you. Opt-in We will provide you an option to opt-in to our marketing at the time of registering for the services. Existing customers who are already registered in our systems will continue to receive our marketing communications unless they chose to opt-out. Third-party marketing We will request your express consent before we share your Personal Data with any third party company for marketing purposes. Opting out You can ask us 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 us at any time. You may still receive messages for a short period of time until updated marketing preferences are set.
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 know how processing for any 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 to explain the legal basis which allows us to do so or, where required by law, to seek your consent.
We will only disclose your Personal Data to third-parties outside of B-Secure in the following circumstances:
Third-party recipients of Personal Data may include:
Once registered, your Personal Data will be stored with us in both physical and digital formats. Our policy is to retain Personal Data only for as long as it is needed. Retention periods are set in accordance with local regulatory and professional retention requirements to meet our professional and legal requirements, to establish, exercise or defend our legal rights, and for archival purposes. For historical statistical analysis, we may need to retain information for significant periods of time after suitably anonymising the information.
Bahrain’s Personal Data Protection Law 2018 sets out the circumstances under which Personal Data may be transferred outside of Bahrain. Except in the circumstances described in Section 5 above (“Data Disclosure”), where you have explicitly consented to your Personal Data being disclosed to any third party or parties, we will only disclose your Personal Data to such third party or parties where they have undertaken, in advance and in writing, to maintain the confidentiality, integrity and security of the Personal Data concerned, in accordance with applicable laws. Certain Personal Data may be transferred outside Bahrain in order to provide services to you. We minimise the quantity and type of Personal Data that must be transferred in this manner.
Our Data Managers are responsible for ensuring the application of technical and organizational measures capable of protecting Personal Data against unintentional or unauthorized destruction, accidental loss, unauthorized alteration, disclosure or access, or any other form of processing. We have instituted security measures for providing an appropriate level of security aligned to the nature of the data being processed, and the risks that may arise from this processing. Our various security measures include encryption, firewalls and access controls. Data is shared within B-Secure (including employees, contractors, agents, etc.) on a need-to-know basis and under strict confidentiality arrangements. Notwithstanding this, despite our best efforts, we cannot absolutely guarantee the security of data against all threats. We have implemented suitable measures to identify, monitor and report any breaches to personal data in line with the requirements of the law.
Under the provisions of the law, you are provided with the following rights in relation to the processing of your Personal Data. To exercise your rights under the law, you may be required to authenticate yourself with adequate proof of identity.
You have the right to request and obtain information on your Personal Data that we hold and the purpose for which it is maintained by us.
You have the right to object to being contacted by us for direct marketing purposes. On receipt of such objection, we will ensure that you are removed from the relevant our marketing databases, as applicable. To opt-out from receiving direct marketing communications, please contact us at any time through the following channels: Opt-out links:
You may submit an application to request to rectify, block or erase your Personal Data, as the case may be, if the processing thereof is done in contravention of the provisions of the law, and in particular, if the data is incorrect, incomplete or not updated, or if the processing thereof is illegal.
At any time, subsequent to providing consent, you have the right to withdraw the consent provided. Withdrawal of consent will be applicable to future use of the Personal Data and will not in any way impact legitimate use of the personal information prior to the withdrawal of the consent. Withdrawal of consent to process certain mandatory Personal Data related to services provided by us may result in our inability to continue the provision of those services.
You may submit a complaint to the Authority, if you have reason to believe that any violation of the provisions of this privacy law has occurred or that we are processing Personal Data in contravention of its provisions.
We are required by law to confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights) prior to processing any requests from you, to ensure that your 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. It is important that the Personal Data we hold about you is accurate and up-to-date. It is your obligation to keep us informed if your Personal Data changes during your relationship with us.
We take your privacy seriously. If you believe that there has been an alleged breach of privacy of your Personal Data, please reach out to our Legal team on firstname.lastname@example.org. We appreciate the chance to deal with your concerns and are committed to resolving them in an efficient and timely manner.