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Privacy Notices

Customer Privacy Notice

First Issued: 18 May 2018
Revised Version: 22 September 2023

National Bank of Kuwait (International) PLC ("we", "us", and "ours" or "NBKI") is a company registered in England & Wales with Company Number 02773743 and registered with the UK Information Commissioner’s Office (ICO) with registration number Z6471287.

This Privacy Notice is prepared for customers of NBKI and explains who we are, how we collect, share and use customers' personal information, and how you can exercise your privacy rights. If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.

What does NBKI do?

NBKI is a bank incorporated in the UK which mainly services clients of its Kuwaiti parent company when those clients want banking services in the UK. Corporate clients will generally have some nexus with the MENA region. NBKI is headquartered in the United Kingdom, but its parent, National Bank of Kuwait S.A.K.P., has branches, subsidiaries and representative offices in a number of countries, including most of the Gulf Cooperation Council (GCC) countries. View the list of our current group companies. Our banking services include current and deposit accounts, FX services, property finance, trade finance and letters of credit and guarantees for corporate customers. Our Treasury department is also active in institutional banking, including accepting and making institutional deposits.

More information about NBKI.

What personal information does NBKI collect and why?

NBKI is the ‘data controller’ of your personal information it collects and processes as set out in this Privacy Notice. This means we are responsible for how we hold and use your personal information about you. We are required to notify you of the information in this Privacy Notice and why we process your data. 

The personal information that we may collect about you broadly falls into the following categories:

Information that you provide directly

Types of Personal Information    Why We Collect it
Name, date of birth and contact details such as address, telephone number and email. Also, details of your nationality, marital and financial status (including bank statements)   For the purpose of processing applications for banking products and services and to provide and develop those products and services to you (for private customers) or your employer (for corporate customers) and to communicate with you in connection with those products and services. 
Personal data you may provide in communications   Where we are corresponding with you, you may provide personal data in that correspondence such as in connection with an enquiry or complaint.
Age   To verify we are legally permitted to provide banking products and services to you.
Employment information including your salary   To verify information provided as part of your application for banking products.
Information such as copies of passports, driving licenses, or other government-issued IDs, passport numbers, signatures, tax identification numbers and utility bills, source of funds and source of wealth information, information about any high political, military or judicial or similar office you may hold that could make you a Politically Exposed Person   For identification purposes and to prevent fraud in connection with accounts, to comply with anti-money laundering requirements or similar legal obligations we have.
We may also collect, when necessary death certificates, details of next of kin/executors and Probate   To attend to matters of Probate and closing of the account.
Telephone calls/recording   We record telephone calls to monitor communications. It is also a regulatory/legal requirement. In addition, we have a legitimate interest to improve our systems and provide training to our staff.
Information about your nominees, family members and associates   To provide the services to you.
Payment data   To provide the services to you.

 

In addition to the above, as a bank we are legally required to process all or some of information above to comply with any anti-money laundering regulations. If we ask you to provide any other personal information not described above, then the personal information we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect your personal information for example in application forms or an agreement.

Information that we collect automatically

If you use our Website or use electronic devices to access our products and services, we may also collect certain information automatically from your device, though we do this in a very limited way. More detail about how we collect information on our Website is set out in our Website Privacy Notice.

Some of this information may be collected online using cookies and similar tracking technology, as explained further in our Cookies Notice, which you can access in the same location as our Website Privacy Notice described above.

Information that we obtain from third-party sources

From time to time, we may receive personal information about you from third-party sources. These include credit reference agencies, World Checking services, other data bases of Politically Exposed Persons, open internet searches to see if there is adverse information in the public domain, information provided by external intelligence suppliers, Syntectics Solutions Limited immigration searches, searches of the Home Office immigration database and other banks who provide references on you. These third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us. 

We also collect personal information about you which is available in the public domain for example in press reports.

The types of information we collect from third parties includes:

Types of Personal Information    Why We Collect it
Criminal records and proceedings checks, immigration status checks and World Checking searches   To comply with anti-money laundering and other account opening and maintenance requirements.
Account and loans information   To provide and/or develop our products and services to you, for internal analytics and credit portfolio management and for the purpose of detection and prevention of fraud.
Information to check creditworthiness such as financial history, income and outgoings, credit history and court judgements   To carry out checks to assess creditworthiness for credit facilities you have applied for or for which you propose to stand as guarantor, for internal analytics and credit portfolio management.
CCTV footage   If you visit our premises or any of our cash machines, we may record CCTV footage for security purposes.
Net worth assessments   To assess whether you are a high net worth individual as defined in FCA or other regulations, so that we can, if you wish, obtain from you a declaration to that effect, which will exempt us from having to comply with certain regulatory steps when offering certain products.
Information in the public domain   We generally conduct open internet searches on potential and existing customers as part of "know your customer". For example, we may obtain information freely available from the UK Companies House Website or the Land Registry. Information such as directorships, accounts, and share holdings.
Information about claims and proceedings (or potential claims and proceedings) by or against you   To identify, exercise and defend contractual and other legal rights.

 

How will we use your personal information?

In accordance with the UK Data Protection laws, we must ensure that we use your personal information as described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. We will use your personal information upon one or more of the following conditions such as processing an application, providing a service or payment transaction. 

  • Providing services under a contract: we use your personal information to the extent necessary for us to provide the products and services to you on the terms agreed between us. This also covers anything you ask us to do prior to providing a product or service, such as processing an application or payment transaction.
  • Meeting a legal obligation: we use your personal information where necessary to comply with any legal obligation imposed upon us. For example, processing your personal information for "know your customer" checks or for tax reporting.
  • Legitimate interests: for any other reasons described in this Privacy Notice, we use your personal information on the basis of legitimate interests. This means that, on balance, we consider that it is necessary to use your data in the described way for a legitimate reason. We are required to balance your interests, rights, and freedoms as an individual against the legitimate interest we are trying to pursue. If we can achieve the same result without processing your personal information, we will adopt that approach. It is our intention to give full and proper consideration to your interests when relying upon this condition to process your personal information.
  • Consent: In limited circumstances, we may use your personal information where you have provided your consent for us to do so. Where you are asked to provide consent, we will provide further details of the reason and use of your personal information when requesting such consent.

If you fail to provide a personal information when requested, we may not be able to provide the service to you or perform the contract with you. We may also be prevented from performing our legal obligation such as know your customer checks. These circumstances may prevent us from being able to offer, or continue to offer, you the services or product.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "How to contact us."

Who does NBKI share my personal information with?

We may disclose your personal information to the following categories of recipients:

  • to our group companies. View the list of our current group companies.
    We benefit from a centralised IT system, provided by our parent company, based in Kuwait. It allows us to access larger, more sophisticated systems to process your personal information. In order to protect your personal information in accordance with the UK's Data Protection laws we have put in place an agreement with our parent company through a set of standard contractual clauses. In respect of corporate customers, Group will have access to the personal details of individuals associated with the corporate, to enable relationship officers in Kuwait to access a consolidated view of the customer. It is not for used for marketing purpose. Access is restricted and can only be viewed if the corporate customer has an account with Group. 
  • to third-party services providers and partners who provide data processing services to us, or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. This may include IT providers, credit check providers, and payment companies. For example, where you have a Visa card with us, we share your personal information with Visa Europe Limited to allow payment transactions or ATM withdrawals to take place. Please see our Appendix on our Website for further details. 
  • to any competent law enforcement body, regulatory, government agency, court or other third-party where we believe disclosure is necessary (i) as a matter of applicable law or regulation including anti-bribery and corruption regulations and anti-money laundering laws, (ii) to exercise, establish or defend our legal rights, (iii) for fraud prevention purposes (iv) to protect your vital interests or those of any other person.
  • to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice.
  • to any other person with your consent to the disclosure.

How does NBKI keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include:

  • physical access control systems
  • a physical security presence
  • logical access controls (such as passwords)
  • perimeter security systems (such as firewalls)
  • vulnerability management

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have Data Protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our servers are located in the UK, and our group companies and third-party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process in accordance with UK Data Protection law.

We have implemented similar appropriate safeguards with our third-party service providers and partners.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). This includes our specific obligations under the FCA rules. 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We will keep transaction records for a minimum of seven years from the date of the relevant transaction, other information may be held for at least five years after the termination of our services. 

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 review. We do not use automated decision-making.

Your Data Protection rights

You have the following Data Protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
  • You have the right to opt-out of marketing communications we send you at any time. However, please note that we do not currently engage in marketing communications. If we ever changed our practice and began issuing marketing communications you could exercise your opt-out right by contacting us using the contact details provided under the “How to contact us” heading below.
  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a Data Protection authority about our collection and use of your personal information. For more information, please contact your local Data Protection authority. The Data Protection authority in the UK is the Information Commissioner’s Office (ICO).

We respond to all requests we receive from individuals wishing to exercise their Data Protection rights in accordance with applicable Data Protection laws. If you wish to exercise any of the above rights please contact the Data Protection Officer at the details listed below.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. This may be by posting a notice on the Website or notifying you. We encourage you to review this Notice to be informed of how NBKI is processing your personal information. 

You can see when this Privacy Notice was last updated by checking the date displayed at the top of this Privacy Notice.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact our Data Protection Officer ("DPO") using the following details: DataProtection@nbki.com. OR

National Bank of Kuwait (International) PLC
13 George Street
London W1U 3QJ

If you have concerns about our use of your personal information, please contact the DPO, but in the event you are not satisfied please contact the ICO, the UK Supervisory authority for Data Protection issues. Their address is:

ICO
Wycliffe House
Water Lane
Wilmslow, SK9 5AF

If you need any of this information in large print, please let us know. You can speak to us by visiting our branch, contacting your Relationship Manager, or giving us a call on +44 (0) 20 7224 2277. 

National Bank of Kuwait (International) PLC. Registered in England & Wales with Company Number 02773743. Our registered office is NBK House, 13 George Street, London, W1U 3QJ, United Kingdom. Authorised by the Prudential Regulation Authority ("PRA") and regulated by the Financial Conduct Authority and the PRA (firm reference number 171532).

Website Privacy Notice

First Issued: 18 May 2018
Revised Version: 9 August 2023

National Bank of Kuwait (International) PLC ("we", "us", and "ours" or "NBKI") respects your right to privacy. NBKI is a company registered in England & Wales with Company Number 02773743 and registered with the UK Information Commissioner's Office (ICO) with registration number Z6471287.

This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice only applies to personal information that we collect through the UK pages on the Website www.nbk.com ("Website") Please see our other Privacy Notices how we process personal information that we collect when you use our services or interact with us through other means. These other notices are all contained in the section headed "Privacy Notices" which is located at the foot of the UK web pages.

NBKI is the controller of information that we process for the purposes described in this Privacy Notice.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the end of this Privacy Notice.

What does NBKI do?

NBKI is a bank incorporated in the UK which predominantly services clients of its Kuwaiti parent company when those clients want banking services in the UK or France. Corporate clients will generally have some nexus with the MENA region. NBKI is headquartered in the United Kingdom, but its parent, National Bank of Kuwait S.A.K.P., has branches, subsidiaries and representative offices in a number of countries, including most of the Gulf Cooperation Council (GCC) countries. Our banking services include current and deposit accounts, FX services, property finance, trade finance and letters of credit and guarantees for corporate customers.

More information about NBKI.

What personal information does NBKI collect and why?

The personal information that we may collect about you broadly falls into the following categories:

Information that you provide voluntarily

Generally, our Website is not designed to collect information from customers and other visitors. It is designed to communicate information about our services and for customers to obtain key information they need to know, for example about our charges, the deposit protection scheme, the terms and conditions of accounts etc. For this reason, we will not in most circumstances be asking you to input information or to register with us. The exceptions to this are:

  • Where you wish to sign up as a new user using the new user registration form for online banking
  • If you contact us through any email addresses on our Website and provide us with any personal information we will process that information

Information that we collect automatically

When you visit our Website, we may collect certain information automatically from your device. In some countries, including the United Kingdom and countries in the European Economic Area, this information may be considered personal information under applicable Data Protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.

Some of this information may be collected using cookies and similar tracking technology, as explained further in our Cookies Notice, which is also on this Website in the section headed "Privacy Notices".

Information that we obtain from third-party sources

We do not receive information about you from third parties via our Website.

Who does NBKI share my personal information with?

We may disclose your personal information to the following categories of recipients:

  • to our group companies, third-party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. View the list of our current group companies. A list of our current service providers and partners is shown in the Appendix on our Website
  • to any competent law enforcement body, regulatory, government agency, court or other third-party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person
  • to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice
  • to any other person with your consent to the disclosure

Legal basis for processing personal information 

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

Our Cookie Notice is also on this Website and describes what cookies we use and why. When you first access the UK section of the Website, you will be presented with a pop-up banner directing you to the Cookie Notice. 

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "How to contact us".

How does NBKI keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have Data Protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Specifically, our servers are located in the UK, and our group companies and third-party service providers and partners operate around the world. This means that when we collect your personal information, we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process in accordance with UK Data Protection law.

We have implemented similar appropriate safeguards with our third-party service providers.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. The only exception to not processing backup archives may be where it becomes necessary to retrieve that archived information. 

Your Data Protection rights

You have the following Data Protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the "How to contact us".
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the "How to contact us".
  • You have the right to opt-out of marketing communications we send you at any time. We do not currently send marketing communications so you will not need to exercise this right.
  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a Data Protection authority about our collection and use of your personal information. For more information, please contact your local Data Protection authority. The Data Protection authority in the UK is the Information Commissioner’s Office (ICO).

We respond to all requests we receive from individuals wishing to exercise their Data Protection rights in accordance with applicable Data Protection laws.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. This may be by posting a notice on the Website or notifying you. We encourage you to review this Notice to be informed of how NBKI is processing your personal information. 

You can see when this Privacy Notice was last updated by checking the "revised version" date displayed at the top of this Privacy Notice.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact our Data Protection Officer using the following details: DataProtection@nbki.com OR

National Bank of Kuwait (International) PLC
13 George Street
London, W1U 3QJ

If you have concerns about our use of your personal information, please contact the DPO, but in the event you are not satisfied please contact the ICO, the UK Supervisory authority for Data Protection issues. Their address is:

ICO
Wycliffe House
Water Lane
Wilmslow, SK9 5AF 

If you need any of this information in large print, please let us know. You can speak to us by visiting our branch, contacting your Relationship Manager, or giving us a call on +44 (0) 20 7224 2277 

National Bank of Kuwait (International) PLC. Registered in England & Wales with Company Number 02773743. Our registered office is NBK House, 13 George Street, London, W1U 3QJ, United Kingdom. Authorised by the Prudential Regulation Authority ('PRA') and regulated by the Financial Conduct Authority and the PRA (firm reference number 171532).

First Issued: 18 May 2018
Revised Version: 9 August 2023

This Notice explains how National Bank of Kuwait (International) PLC ("we", "us", and "ours" or "NBKI") is a company registered in England & Wales with Company Number 02773743 and registered with the UK Information Commissioner’s Office (ICO) with registration number Z6471287.

NBKI uses a limited number of cookies when you visit the UK sections of our Website at www.nbk.com ("Website"). It explains what these cookies are and why we use them. Although this Notice relates generally to the Website of National Bank of Kuwait S.A.K.P. it is only intended to meet the legal obligation to inform visitors of cookies that are used on the UK pages of the Website.

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a Website. Cookies are widely used by Website owners in order to make their Websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the Website owner (in this case, National Bank of Kuwait S.A.K.P.) are called "first party cookies". Cookies set by parties other than the Website owner are called "third-party cookies". Third-party cookies enable third-party features or functionality to be provided on or through the Website (e.g. advertising, interactive content and analytics). The parties that set these third-party cookies can recognise your computer both when it visits the Website in question and also when it visits certain other Websites.

Why do we use cookies?

We use a limited number of cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to provide Website functionality, or to track the use of our Website. This is described in more detail in the table below.

Types of cookie Who serves these cookies How to refuse

Essential Website cookies

These cookies are strictly necessary to provide you with services available through our Websites and to use some of its features, such as access to secure areas.

National Bank of Kuwait S.A.K.P. Because these cookies are strictly necessary to deliver the Websites to you, you cannot refuse them.

Performance and functionality cookies

These cookies are used to enhance the performance and functionality of our Websites Without these cookies, certain functionality (like videos) may become unavailable.

Various - available upon request To refuse these cookies, please follow the instructions below under the heading "How can I control cookies?"

Analytics and customisation cookies

These cookies collect information that is used in aggregate form to help us understand how our Website is being used. This does not enable us to engage in targeted marketing (and we do not engage in marketing anyway).

Google Analytics To refuse these cookies, please follow the instructions below under the heading "How can I control cookies?"

 

What about other tracking technologies, like web beacons?

Cookies are not the only way to recognise or track visitors to a Website. Some Websites use similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These tiny graphics files that contain a unique identifier enable Website owners to recognise when someone has visited their Website or opened an e-mail sent to them. This allows Website owners, for example, to monitor the traffic patterns of users from one page to another within the Website, to deliver or communicate with cookies. We do not use web beacons or other tracking technologies. 

Do you use Flash cookies or Local Shared Objects?

"Flash Cookies" (also known as Local Shared Objects or "LSOs") are used by some Website owners to, among other things, collect and store information about your use of services, fraud prevention and for other site operations. We do not use Flash cookies or Local Shared Objects.

Do you use social networking cookies?

These cookies are used to enable you to share pages and content that you find interesting on our Website through third-party social networking and other Websites. We do not use these sort of cookies.

Do your cookies serve targeted advertising?

We do not engage in targeted marketing and we do not use cookies that would enable us to engage in such activities.

Links to other Websites

Our Website contains links to other Websites. If you access those other Websites they may use cookies. Please read any Cookie Notices on those Websites if you wish to know what cookies are being used.

How can I control cookies?

You have the right to decide whether to accept or reject cookies and you can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Website though your access to some functionality and areas of our Website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information.

How often will you update this Cookie Notice?

We may update this Cookie Notice from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Notice regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Notice indicates when it was last updated.

Where can I get further information?

If you have any questions about our use of cookies or other technologies, please email our Data Protection Officer ("DPO") at DataProtection@nbki.com OR

National Bank of Kuwait (International) PLC
13 George Street
London, W1U 3QJ

If you have concerns about our use of your personal information please contact the DPO, but in the event you are not satisfied please contact the ICO, the UK Supervisory authority for Data Protection issues. Their address is:

ICO
Wycliffe House
Water Lane
Wilmslow, SK9 5AF

Contact Privacy Notice

Date: 1 March 2021
Last Updated: 9 August 2023

National Bank of Kuwait (International) PLC ("we", "us", and "our" or "NBKI") respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about our contacts, and how our contacts can exercise their privacy rights. If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the end of this Privacy Notice.

NBKI is the controller of information that we process for the purposes described in this Privacy Notice.

What does NBKI do?

NBKI is a bank incorporated in the UK which mainly services clients of its Kuwaiti parent company when those clients want banking services in the UK. Corporate clients will generally have some nexus with the MENA region. NBKI is headquartered in the United Kingdom, but its parent, National Bank of Kuwait S.A.K.P., has branches, subsidiaries and representative offices in a number of countries, including most of the Gulf Cooperation Council (GCC) countries. View the list of our current group companies. Our banking services include current and deposit accounts, FX services, property finance, trade finance and letters of credit and guarantees for corporate customers. Our Treasury department is also active in institutional banking, including accepting and making institutional deposits.

What personal information does NBKI collect and why?

The personal information that we may collect about you broadly falls into the following categories:

Information that you provide

You may provide us information directly which may include:

Types of Personal Information Why We Collect it
Identification and business and personal contact details (name, address, telephone number and email address) To establish and manage our relationship with our customers, service providers, distributors and other partners.
Financial information (bank account details, payment card)
Employment details (employer, job title)
Telephone calls/recording We record telephone calls to monitor communications. It is also a regulatory/legal requirement. In addition, we have a legitimate interest to improve our systems and provide training to our staff.

 

In addition correspondence with you may contain certain personal information that we exchange in the ordinary course of business such as to schedule meetings and calls and manage services we provide to you (or your employer) or you (or your employer) provide to us. 

If we ask you to provide any other personal information not described above, then the personal information we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect your personal information.

Information that we obtain from third-party sources

From time to time, we may receive personal information about you from third-party sources (including from your employer and on occasion other suppliers and partners), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.

Who does NBKI share my personal information with?

We may disclose your personal information to the following categories of recipients:

  • to our group companies, third-party services providers and partners who provide data processing services to us, or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. Please see our Appendix on our Website for further details. 
  • to any competent law enforcement body, regulatory, government agency, court or other third-party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
  • to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
  • to any other person with your consent to the disclosure.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your Data Protection interests or fundamental rights and freedoms.

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. Mostly, however, we process contacts information for our legitimate business interests in the context of providing or receiving services to customer or from our service providers or in the case of partners, for the purpose of the collaboration or partnership.

If we collect and use your personal information in reliance on anything other than our legitimate interests, we will make clear to you at the relevant time. For example, if we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "How to contact us" heading at the end of this Notice.

How does NBKI keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

International data transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have Data Protection laws that are different to the laws of your country.

NBKI's group companies are based outside of the UK and the EEA.

We benefit from a centralised IT systems, provided by our parent company, based in Kuwait. It allows us to access larger, more sophisticated systems to process your personal information. In order to protect your personal information in accordance with the UK's Data Protection laws we have put in place an agreement with our parent company through a set of standard contractual clauses for personal data transfers.

We may also use third parties or partners who are based outside the UK. As with our group companies, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice. These include implementing standard contractual clauses for personal data transfers with these parties.

We have implemented similar appropriate safeguards with our third-party service providers and partners.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to receive services from you (or your employer), to provide services to our customers, to collaborate with our partners or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

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 review. We do not use automated decision-making.

Your Data Protection rights

You have the following Data Protection rights:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the "How to contact us" at the end of this Notice.
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the "How to contact us" at the end of this Notice.
  • You have the right to opt-out of marketing communications we send you at any time. However, please note that we do not currently engage in marketing communications. If we ever changed our practice and began issuing marketing communications you could exercise your opt-out right by contacting us using the contact details provided under the "How to contact us" at the end of this Notice.
  • Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the have the right to complain to a Data Protection authority about our collection and use of your personal information. For more information, please contact your local Data Protection authority. The Data Protection authority in the UK is the Information Commissioner’s Office (ICO). 

We respond to all requests we receive from individuals wishing to exercise their Data Protection rights in accordance with applicable Data Protection laws.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. This may be by posting a notice on the Website or notifying you. We encourage you to review this Notice to be informed of how NBKI is processing your personal information. 

You can see when this Privacy Notice was last updated by checking the "last updated" date displayed at the top of this Privacy Notice. 

How to contact us

If you have any questions or concerns about our use of your personal information, please contact our Data Protection Officer using the following details: DataProtection@nbki.com. OR

National Bank of Kuwait (International) PLC
13 George Street
London, W1U 3QJ.

Vendors and Third Parties

List of the main vendors and other third parties who may be passed personal data by NBKI. This list does not include other companies within the National Bank of Kuwait Group.

Vendor/Third Party Service Provided Location
ADP Payroll and HR Services UK, France and Spain
Evry Debit card processing Norway
OneTrust GDPR Governance system hosting Germany
Digital Print Management Cheque book printing UK
Grant Thornton Internal audit services UK and France
Wincanton/Restore Technology Record archiving UK
Syntectics Solutions Immigration Act UK