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Privacy Policy

Understanding Our commitment to protecting your personal information

Privacy Notice

1. Overview

"SNB Capital" is the investment banking and asset management arm of Saudi National Bank (SNB). It is a regulated company with headquartered on King Saud Road, Al Murabba, P.O.Box 12624, Riyadh, Kingdom of Saudi Arabia.  

This privacy notice (“Privacy Notice”) describes how SNB Capital (“We”, “Us” or “Our”) may collect, use, store, share, or process your personal data. It is important to us that you are aware of our personal data, security practices and policies while using our products, services and online services.

We also describe the measures we take to protect your personal data and how you can contact us about our privacy practices. 

We also think it is important to highlight that SNB Capital operates across multiple jurisdictions, such as the Kingdom of Saudi Arabia (“KSA”) and the Dubai International Financial Centre (“DIFC”). We have therefore developed two separate Data Privacy Notices and this notice will cover KSA. This Privacy Notice is applicable to the Saudi Personal Data Protection Law (“PDPL”), which was issued on16 September 2021. 

2. Purpose

This Privacy Notice aims to give you information about how we may collect and process your personal data. It is important that you read this Privacy Notice together with any other privacy notice or fair processing notices that we may issue, so that you are fully aware of how and why we are using your personal data. This Privacy Notice replaces previous privacy notices (on how we may collect and process your personal data).

3. Controller and Processor

SNB Capital determines the “how” and “why” your personal data is collected and processed. Therefore, SNB Capital acts as the data controller of your personal data under the PDPL Law.  

In some cases, we will act as the data processor when processing your information on behalf of another SNB Group entity. In these cases, we carry out the processing of the data under the specific instructions from the SNB Group entity acting as the data controller.

4. Contact Details

You can contact us via various available channels, using the below contact details to further details regarding the processing of your Personal Data and how to exercise your rights.

Website: https://www.alahlicapital.com 
Address: King Saud Road, Al Murabba, P.O.Box 12624, Riyadh, Kingdom of Saudi Arabia.
Phone Number: 8002440123
E-mail: alahlitadawul@ncbc.com   
License or Commercial Register: 37-06046

5. Review and Updates

This Privacy Notice is updated from time to time. New and updated Privacy Notices can be found on the bottom of our website’s home page.

It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if any of the information we hold on you changes during your relationship with us.

6. What Personal Data is Collected?

Personal data means any data by which you may be identified as an individual. It does not include data where the identity has been removed and the person is not or no longer identifiable (anonymized data).

Your personal data will be collected or obtained by us whether we deal with you as an individual or as a representative of another individual, business, charity, trust or other organization. We process many different types of personal data (as further described below).

We will collect, use, store and transfer different kinds of personal data about you, which may include:

  • identifying information, includes information used to identify a specific individual, such as: name; date of birth, place of birth, nationality, national ID, country of residence, passport number and place of issue, visa details, tax identification details, passport details, photo;
  • contact information: includes information related to postal address, telephone number, email address, mobile number, and emergency contact details;
  • family information: includes information related to marital status, and children details;
  • financial information: includes information related to source of wealth, personal assets, bank account numbers, spending, credit bureau reports from relevant authorities, transaction history, annual income details and credit data; 
  • professional information: includes information related to employer; employee ID, business interests, and career history;
  • website technical data: includes information related to your internet protocol (“IP”) address, website login data, browser type and version, 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 our website;
  • website profile and usage data: includes information related to the interests, preferences, feedback and survey responses, and information about how you use our website;
  • transaction details while performing online payments: includes information related to merchant name, location, and device used; and/or
  • sensitive data: includes personal data relating to security criminal convictions and offenses, biometric or Genetic Data for the purpose of identifying the person, Health Data. 

In certain circumstances, we will also collect, use, store and transfer sensitive data about you. Note that we will only process sensitive data to the extent permitted under the PDPL Law.

Where we rely on consent as the legal basis (please refer to section 10), we will provide you with full details of the data that we intend to process and why. So, you can carefully consider whether or not you want to consent to the processing of your personal data. Where we require your explicit consent to use and / or share your personal data, you have the right to withdraw your consent. If you do withdraw your consent, we may not be able to provide you with the products or services for which we need to use your personal data.

Please note that if certain information is not shared with us, that may limit what we are able to do for you and in some cases, you may be unable to access our website or receive our offers. 

7. If you Fail to Provide Personal Data

Where we are required by applicable laws or professional standards to collect personal data and you fail to provide that data when requested. We may have to decline your request for our services or, if we are already providing services, suspend or discontinue them. This can happen if we need to use your personal data to provide services to you.

8. How do we collect Your Personal Data?

We may collect your personal data directly from you in a number of ways, including:

  • when you apply for any product on our website (www.alahlicapital.com) or digital application, through website, mobile application, telephone or directly with one of our employees;

  • when you provide it online or by any other method of communication, for example, on "contact us" forms, or when you provide it through the course of our relationship; and

  • technical information, including the IP address and device ID used to connect to the internet, may be collected from you when you visit our website or our mobile applications.

We may obtain your personal data indirectly from third parties in the following ways:

  • following an introduction to us by another third party, such as an accountancy firm, law firm or management consultancy;

  • if another person provides your information to us when they apply to obtain a service from us: 

  1. on your behalf; or

  2. that is to be held jointly with you; or

  3. on behalf of a business, charity, trust or other organization of which you are a director, shareholder, owner, trustee or beneficiary (as applicable); or

  4. they have nominated you as a guarantor under our agreement with them, or to provide any other security, or informed us that you are a donor or lender of any deposit monies or occupier of any security property;

  • when we carry out searches for the purposes of processing your application and/or during the course of your relationship with us; or

  • in response to our marketing activities, you request information about our products via a third party (e.g., websites and social media platforms).

If you are applying to us through a third party, then the third party should have provided you with their own privacy notice explaining how they may process your personal data.

9. Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of the ways we use your personal data. SNB Capital will use the appropriate legal basis to process your personal data (refer to section 11). Collecting and processing your personal data is required (mandatory) in order for us to provide you with our services. You should be aware that you have various data subject rights (refer to section 20) that you can exercise. We have developed a record of processing activity register that maps all our processing activities to an appropriate lawful basis.

10. Purposes for Which We Will Use Your Personal Data

SNB Capital operates in the Kingdom of Saudi Arabia and we will only process your personal data in line with the lawful basis outlined in the PDPL law. SNB Capital shall process your personal data based on one of the following conditions:

  • Processing is based on consent;
  • Processing achieves your definite interest and it is impossible or difficult for us to contact you;
  • Processing is in accordance with another law or in implementation of an agreement to which the personal data owner is a party;
  • Fulfillment of a contractual obligation, for example the terms and conditions.
  • If the controlling entity is a public entity, and such processing is required for security purposes or to meet judicial requirements; or, processing is necessary to achieve a lawful interest of SNB Capital, without prejudice to your rights and interests.
11. How do we store your Personal Data?

Your Personal Data is stored securely at our data center in the Kingdom of Saudi Arabia, pursuant to our Data Retention Policy.

We also retain the data we collect to fulfill our purposes mentioned in “9. Purposes for Which We Will Use Your Personal Data” for a period of 10 years, as per our regulatory requirements, after which we will securely dispose of such data in a manner that prevents access or retrieval, using international best practices for data disposal. 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, reporting or data privacy law requirements.

12. Marketing From Us

You may receive marketing communications from us about our products and services. You may request to stop receiving marketing messages at any time by following the links on any marketing message to withdraw your consent. Or by contacting the SNB Capital’s Client Care department alahlitadawul@alahlicapital.com at any time. Where you withdraw your consent to receiving marketing messages, this will not apply to personal data provided to us for other purposes.

13. How do we Disclose your Personal Data?

Your personal data may be shared with third parties to fulfil the purposes described in this Privacy Notice. In some circumstances where the PDPL Law permits, your data will be transferred to other SNB Capital entities or our SNB Capital Subsidiary within the same jurisdiction or within a different jurisdiction. Such transfers will be performed in compliance with the relevant data privacy laws across the jurisdiction. 

When we transfer your personal data, we will take the necessary steps to apply appropriate safeguards to ensure your personal data is protected in line with the PDPL Law. 

 

To the extent required, we may also transfer your personal data to third parties in connection with reorganization, restructuring, merger, acquisition, or transfer of assets provided they agree to treat your personal data in a manner consistent with the applicable law and requirements. 

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the PDPL. We will also obtain your consent where applicable and ensure contractual terms on sharing personal data with the third party is established. 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 mentioned in “9. Purposes for Which We Will Use Your Personal Data”, and in accordance with our instructions.

 

Please refer to “19. Appendix”

14. Data Security

We have implemented suitable technical measures, administrative controls, and legal safeguards to:

  • Safeguard your Personal Data from accidental loss, unauthorized access, misuse, alteration, or disclosure (such as access control, network security, and communication security protocols).

  • Address any suspected Personal Data breaches promptly and thoroughly, in accordance with legal requirements. Should such a breach occur, we will notify you and SDAIA as mandated by the KSA PDPL.

To ensure effective protection of your Personal Data we have established various internal documents, for instance the following policies: Data Protection Policy, Information Classification Policy, Corporate Information Security Policy and Acceptable Use Policy.

15. Social Media

SNB Capital operates channels, pages and accounts on some social media sites to inform, assist and engage with customers. SNB Capital monitors and records comments and posts made on these channels in order to improve its products and services.

Please note that you must not communicate to SNB Capital through such social media sites the following information:

  • confidential personal data, including any information regarding your financial situation, bank account details, transactions, etc.

  • sensitive data.

  • excessive, inappropriate, offensive or insulting information towards individuals.

SNB Capital is not responsible for any information posted on those sites other than the information posted by its employees on its behalf.

16. Your Use of Our Website

We use 'cookies' to monitor how people use our site. A cookie is a piece of information that is stored on your computer's hard drive and it records how you have used a website. This helps us to understand how our customers use our website so we can develop and improve the site. For more information about our use of cookies please refer to our Cookie Policy.

17. Your Rights Regarding Processing of Your Personal Data

Under PDPL, you have the following rights in relation to your Personal Data: 

  • Right to Be Informed: You are entitled to be informed how we collect your personal data, what legal basis for collection and processing your Personal Data is, how such data is processed, stored, destroyed, and to whom it will be disclosed. You can access all details through this Privacy Notice or contact us using the below mentioned information.  

  • Right of Access to Your Personal Data: You are entitled to request access to your Personal Data in a readable and clear format (if technically feasible) by sending an email to us. 

  • Right to Request Access to Your Personal Data: You are entitled to request access to your Personal Data held by us in a readable and clear format consistent with the content of records. 

  • Right to Request Correction of Your Personal Data: You are entitled to request correction of your Personal Data that you believe is inaccurate, incorrect or incomplete, by sending an email to us.  Such data will be reviewed and updated within [please specify the number of days]. In addition, you will be notified via [please specify the means of notification] after your Personal Data will be updated. 

  • Right to Request Destruction of Your Personal Data: You are entitled to request destruction of your Personal Data in certain circumstances, for instance if your Personal Data is no longer necessary to achieve the purpose for which it was collected. 

  • Right to Withdraw Your Consent for Processing Your Personal Data: You are entitled to withdraw your consent for processing your Personal Data (if such a consent was given by you) at any time unless there are legal bases that require otherwise. You may withdraw your consent by sending an email, calling us or visiting us with the relevant request as per the details outlined in the section “Contact Details” or “Personal Data Protection Officer” of this Privacy Notice.

  • Right to Claim Compensation: You are entitled to claim compensation for material or moral damage if you are harmed as a result of any violation of the PDPL and its Implementing Regulations.

Unless otherwise stipulated by the law, you will not be required to pay any fees in return for exercising this right. In case of submitting a request for exercising this right, you will receive a response within 30 days of the request receiving date. 

You may exercise any of your rights by sending a request to our customer care team by telephone or email, specified in section 1 of this Privacy Notice.

18. Complaint or Objection Filing Method

If you have any complaints regarding our processing of your Personal Data, for example if you cannot exercise any of your rights related to the Personal Data, or if you object to processing of your Personal Data, you may send a complaint to us using the following contact details:

[Please specify the name of the SNB department or division involved in receiving and processing complaints, its contact details, and the period specified for processing such complaints.]

If you are dissatisfied with how we process your complaints or if we fail to respond to your complaint within 30 days (after we receive it), then you may file a complaint to Saudi Data & AI Authority (SDAIA). Please see below the details of SDAIA:

Kingdom of Saudi Arabia, Riyadh 

Saudi Data & AI Authority Website: sdaia.gov.sa 

National Data Governance Platform “DGP”: dgp.sdaia.gov.sa 

19. Appendix

Government Entities: 

In a number of instances, we may be required by law, regulation or instruction to provide your personal data to government-authorized agencies. To do this, we will supply your personal data to such agencies who will carry out, amongst other things, checks on you.

 

External third parties 

External third parties include:

  • Organizations that provide us with business support services. For example, account service and administration companies, back-up and server hosting, IT software and maintenance and platforms, document storage and management services.

  • Anyone that SNB Capital reasonably believes to be acting on your behalf with authority to do so, such as payment recipients, beneficiaries of your account, nominees, intermediaries, correspondent and agent banks, clearing houses, clearing or settlement systems, market counterparties, upstream withholding agents, swap or trade repositories, stock exchanges or companies in which you have an interest in securities (where such securities are held by us for you), a debt charity, power of attorney or your professional advisors.

  • Credit reference/information agencies and bureaus as SNB Capital chooses from time to time for the purposes of obtaining or providing credit references and other information (e.g. for our commercial operations and to assess your ability to meet your commitments). 

  • Any party, including but not limited to SNB Capital’s professional advisors, for the purpose of enforcing or preserving SNB Capital’s rights against you when it is necessary for our legitimate interests and/or for the establishment, exercise or defense of legal claims. 

  • Third parties who have introduced you to us (e.g. an intermediary or broker) in order for them to manage their records about you, to ensure that the type of business that they refer to us is appropriate and to help us to resolve any complaint made by you and/or any dispute between you and us (e.g. to help us to ensure that the intermediary or broker is fulfilling the terms of their contract with us).

  • Market research organizations who we engage to assist us in developing and improving our products and services. 

  • Legal, supervisory, regulatory, governmental and quasi-governmental bodies, fraud prevention agencies, tax authorities, our professional advisors and/or the courts (e.g. to obtain legal advice or for fraud prevention purposes) and/or when we have a legal obligation to do so across the different jurisdictions.

  • Any person or entity that is to provide, or has provided, any security of guarantee (and their professional advisors) in respect of your agreement with us and their professional advisors. 

  • Any entity/third party used for recovery or collection of receivables to SNB Capital from delinquent or defaulted customers.

  • Any entity (and their professional advisors) that provides funding to us or members of SNB Capital, any entity that provides us with debt or equity finance and any potential purchasers of any part of our business. Any party to a transaction acquiring an interest in, or assuming risk in, or in connection with, your banking relationship with SNB Capital.

  • Any person or entity that provides services to you through SNB group as an intermediary, including investment management or insurance services and including in relation to additional products and services. 

 

Internal Third Parties

We may share your personal data with other SNB Capital affiliates across the different jurisdictions so that they can provide you with relevant products and services. This type of processing is necessary to enable us to take steps at your request prior to you entering into a contract with a company within SNB Capital’s group.
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SNB Capital is a Saudi Joint Stock Company with a paid up capital of SR1,000 million and is authorised by the Capital Market Authority of the Kingdom of Saudi Arabia with a license number 37-06046 granted by Capital Market Authority to carry out dealing, as principal and agent, and underwriting, managing, arranging, advising and custody, with respect to securities. SNB Capital Company, CR1010231474, the registered office is at King Saud Road, Regional Building P.O. Box 22216, 11495 Riyadh, Kingdom of Saudi Arabia. +966 11 874 7106

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