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Privacy Notices

First issued: 18 May 2018
Revised Version: Not applicable

This Notice explains how National Bank of Kuwait (International) PLC "we", "us", and "ours" or “NBKI”) uses a limited number of cookies when you visit the UK and France 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 or France 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 Websites to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us 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. You can, however, block or delete them by changing your browser settings, as described below under the heading "How can I control cookies?".
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 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 are tiny graphics files that contain a unique identifier that 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 privacy notices on those websites if you wish to know what cookies are being used.

How can I control cookies?
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 at DataProtection@nbki.com.

Website Privacy Notice

First issued: 18 May 2018
Revised Version: Not applicable

National Bank of Kuwait (International) PLC "we", "us", and "ours" or “NBKI”) respects your right to privacy. 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 or France 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 and France web pages.

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.

Quick links
We recommend that you read this Privacy Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link below to jump to that section.

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.

For more information about NBKI, please see the “About” section on the Website.

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:

     
    • There is a link to a new user registration form for online banking which you submit to us online so that we can set you up with online banking.
    • You can subscribe to a newsletter which will then be emailed to you periodically until you unsubscribe
    • We provide email contact addresses on our website and if you use those to supply us with any personal information we will process that information accordingly as a data controller
       
  • Information that we collect automatically
    When you visit our Website, we may collect certain information automatically from your device. In some countries, including 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. A list of our current group companies is available here: https://www.nbk.com/nbk-group/about-nbk-group/our-network.html. A list of our current service providers and partners is appended to this Notice;
  • 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. Given the fact that the only personal information collected about you on our website is that which you send to us or which is collected automatically via cookies, and given that you are able to disable cookies if you wish and are deemed to consent to their use if you proceed on our website without disabling them, we regard any information collected as obtained with your consent.

Our Cookie Notice is also on this website and describes what cookies we use and why. When you first go on the UK section of the NBK website there will be a pop up banner directing you to the Cookie Notice. If you continue to use the website you will be deemed to accept our use of cookies.

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 Website servers are located in the UK and France, and our group companies and third party service providers and partners operate in the following countries: https://www.nbk.com/nbk-group/about-nbk-group/our-network.html. 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 European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union 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, but we do not 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). In France the data protection authority is Commission National Informatique et Libertés (CNIL).

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. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection 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.

How to contact us
If you have any questions or concerns about our use of your personal information, please contact our Data Protection Officer on: DataProtection@NBKI.com.

Customer Privacy Notice

First issued: 18 May 2018
Revised Version: Not applicable

National Bank of Kuwait (International) PLC "we", "us", and "ours" or “NBKI”) respects your right to privacy. 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. 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 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. A list of our group companies can be found at https://www.nbk.com/nbk-group/about-nbk-group/our-network.html. 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.

For more information about NBKI, please see the “About” section of our website at https://www.nbk.com/london/About.html.

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
    We ask you to provide certain information voluntarily. The types of information we ask you to provide, and the reasons why we ask you to provide it, include:

     
    Types of personal information Why we collect it
    Name and contact details such as
    address, telephone number and
    email
    For the purpose of processing
    applications for banking products
    and services and to provide 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
    Information such as copies of
    passports, driving licenses, or
    other government-issued IDs,
    passport numbers, signatures, tax
    identification numbers and utility
    bills
    For identification purposes and to
    prevent fraud in connection with
    accounts and to comply with antimoney
    laundering requirements.


    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 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 details 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 (including credit reference agencies, World Checking services, other banks who provide references on you), 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.

    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 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 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 about claims and proceedings (or potential claims and proceedings) by or against you To identify, exercise and defend contractual and other legal rights


In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information 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 data protection laws.

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. A list of our current group companies is available here https://www.nbk.com/nbk-group/about-nbk-group/our-network.html. A list of third party services providers is appended to this Notice.
  • 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.

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 from third parties (such as to comply with anti-money laundering or immigration laws and fraud prevention) or may otherwise need the personal information to protect your vital interests or those of another person.

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).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

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 below.

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 France, 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 European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.

Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

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.

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.
  • In addition, if you are a resident of the European Union, 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” 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). In France the data protection authority is Commission National Informatique et Libertés (CNIL).

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. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

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 using the following details: DataProtection@nbki.com.

Contacts Privacy Notice

First issued: 23 May 2018
Revised Version: Not applicable

National Bank of Kuwait (International) PLC "we", "us", and "ours" or “NBKI”) respects your right to privacy. 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. 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 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. A list of our group companies can be found at https://www.nbk.com/nbk-group/about-nbk-group/our-network.html. 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.

For more information about NBKI, please see the “About” section of our website at https://www.nbk.com/london/About.html.

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
    We ask you to provide certain information voluntarily. The types of information we ask you to provide, and the reasons why we ask you to provide it, include:

     
    Types of personal information Why we collect it
    • Identification and contact details (name, address, telephone number and email address)
    • Financial information (bank account details, payment card)
    • Employment details (employer, job title)
    To establish and manage our relationship with our customers, service providers, distributors and other partners

    In addition we may correspond with you and that may contain certain
    personal data 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;
  • 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.

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.

Specifically, our servers are located in the UK and France, 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 European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.

Our Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

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” heading below.
  • 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 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). In France the data protection authority is Commission National Informatique et Libertés (CNIL).

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. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

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 using the following details: DataProtection@nbki.com.

Appendix

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
HR services
United Kingdom,
France and Spain
Evry Debit Card Processing Norway
OneTrust GDPR Governance system hosting Germany
Digital Print Management Cheque Book Printing United Kingdom
BDO LLP Internal audit services United Kingdom and France
Wincanton/Restore Technology Record archiving United Kingdom
SAB2i SEPA payment processing France