We are Goldman Lampe Private Bank (FZE) (“Bank”) and we provide certain financial services to you (the “Services”).  This privacy policy (“Privacy Policy”) sets out our policies and procedures for collecting, using, maintaining, protecting, processing and disclosing information provided to us by you.
 
In this Privacy Policy, the words “we”, “us”, “our” or any of their derivatives refer to the Bank and its successors and any novatee, assignee, transferee or purchaser of the Bank’s rights and/or obligations hereunder and any reference to the Bank includes a reference to such successor, novatee, assignee, transferee or purchaser. The words “you”, “your”, “yours” or any of their derivatives refer to the person using our Services, operating any account maintained with us, accessing our website or mobile applications (“app” or “apps”), or otherwise providing information to or communicating with us and shall include, as the context may require, successors and assigns (as the case may be).

We collect, use, maintain, protect, process and disclose your personal data in accordance with United Arab Emirates (“UAE”) data protection regulations, such as, but not limited to, the Central Bank Consumer Protection Regulations including the Consumer Protection Regulation and Standards (Circular No. 8 of 2020) (“Consumer Protection Regulation” or “Consumer Protection Standard”),  Federal Decree by Law No. (14) of 2018 (“Banking Law”), and, to the extent applicable, Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data (“UAE Federal Data Protection Law”) together with other applicable laws (collectively referred to as “UAE Data Protection Laws”) as required for the performance of the Services, operating any account maintained with us, accessing the website or mobile apps, or otherwise to enable you to provide information to or communicate with us.  Personal Data is defined by the Consumer Protection Regulation as “any information relating to an identified natural person or identifiable natural person. “Identifiable natural person” is defined as a natural person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to their biological, physical, biometric, physiological, mental, economic, cultural or social identity”. The Banking Law does not define Personal Data, but operate with the concept of banking and credit information, which are not further defined in the law.

As long as you have granted us your express consent to process your Personal Data in relation to providing Services to you, the processing of Personal Data as described below, is legal on the basis of your consent. Consent given can be withdrawn at any time by notifying us using either of the contact methods set out below, except to the extent that withdrawal is not permitted under Applicable Laws.

The withdrawal of consent will take effect within 30 days of receiving your request to withdraw. The request for withdrawal has to be provided to the Data Protection Officer (see contact details below). Withdrawal of consent does not affect the legality of data processed prior to your withdrawal.

We process your Personal Data in accordance with the relevant  UAE Data Protection Laws and any other applicable local or foreign laws, rules, acts, regulations, subsidiary legislation notices, notifications, circulars, licence conditions, directions, requests, requirements, guidelines, directives, codes, information papers, practice notes, demands, guidance and/or decisions of any national, state or local government, any agency, exchange, regulatory or self-regulatory body, law enforcement body, court, central bank or tax revenue authority or any other authority whether in the UAE, or elsewhere, whether having the force of law or not (including any intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions or otherwise), as may be amended from time to time (“Applicable Laws”). We undertake the processing of your Personal Data as required to comply with all Applicable Laws that we are subject to. We also process your Personal Data for the purpose of legitimate interests pursued by us or a third party to whom your Personal Data is made available, except in the circumstances where such interests are overridden by your interests or rights as a data subject under the Applicable Laws. We only process the data required for the stated purpose.

We may use your Personal Data for our business purposes, including the provision of the Services provided to you. This includes, the following purposes (“Purposes”):

• to provide the Services to you, including administering any account you have with us
• to carry out any transactions on your behalf contemplated by the Services;
• to assess and process applications, instructions or requests from you;
• to communicate with you, including providing you with updates on changes to our Services;
• to verify your identity for the purposes of providing Services to you;
• to conduct due diligence checks, screenings or credit checks as may be required by any Applicable Laws or our internal policies and procedures;
• for the specific purpose for which it was volunteered or provided to us;
• to detect and prevent fraud and other unauthorised or illegal activities and protect us or any third parties against negligence, fraud, theft and other illegal activities;
• to understand your needs and preferences;
• to improve the content, appearance and utility of the Services;
• to manage and develop infrastructure and business operations;
• to carry out our obligations and enforce our rights arising from any agreements entered into between you and us, including for billing and collection and the processing of payments;
• to comply with our internal policies and procedures;
• to respond to queries or feedback;
• to address or investigate any complaints, claims or disputes;
• to comply with any Applicable Laws or any request from any relevant governmental or regulatory authority;
• for financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes;
• to seek professional advice, including legal advice;
• to provide you with marketing materials in connection with the services we may provide;
• to fulfil any purpose related to the above purposes or any other purpose in connection with the provision of our Services; or
• any other purposes that are appropriate or authorized by any Applicable Laws.

We will obtain express consent if any of your Personal Data will be used for the purposes of direct marketing, whether by us or via a third party, and you will be offered the option of objecting to any such direct marketing. You may also, at any time, object to receive marketing information from us. If you wish to do so, please click on the “Unsubscribe” option available on all marketing/newsletter emails that you may receive from us or contact our Data Protection Officer (see the contact details provided below).

We collect, use, disclose, transfer and otherwise process Personal Data about you or Personal Data relating to individuals who are connected or associated with you including but not limited to your legal representatives that you provide to us (“Associated Persons”) in accordance with this Privacy Policy.

The Personal Data that we collect or may collect include (without limitation):

• personal contact data including name, telephone number, mobile number, email address, residential address and correspondence address;
• specimen signature(s);
• occupation, education and income levels;
• identification card or passport number, date of birth, place of birth and other information for the verification of identity;
• financial and banking information (e.g. information on net assets, income, expenses, credit history, bank account and banking transactions, securities trading account);
• images and voice recordings of our communications with you;
• tax and insurance information;
• information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets;
• personal opinions made known to us (e.g. your feedback or responses to any surveys);
• browsing history, patterns or other unique information;
• your internet protocol address and information associated with such address;
• criminal record checks;
• any other Personal Data reasonably required in order for us to provide the Services; and
• any other Personal Data permitted by or required to comply with any Applicable Laws and our internal control and compliance policies.

The Personal Data has/or will be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:

• information provided or submitted by you through among others, your dealings and agreements with us (including through our websites and mobile applications), which includes information provided when registering as a user, providing information regarding any account which you may open with us, providing answers to security questions, completing any confirmations, declarations or forms, or through your utilization of any of our Services;
• as applicable, publicly available or publicly accessible information;
• such other written, electronic or verbal communications or documents delivered to us prior to and during the course of our contractual or pre-contractual dealings with you; and
• screening service providers.

As the accuracy of your Personal Data depends largely on the information you provide to us, you should inform us in writing as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data. Any errors or incomplete Personal Data may prevent us providing Services to you.

We intend to keep the Personal Data accurate and up-to-date, and retain the Personal Data no longer than necessary for the above purposes or as required or permitted by any Applicable Law including UAE Data Protection Laws).

We may from time to time disclose and share your Personal Data to  directors, officers, employees, representatives, agents or delegates or any third parties, whether located in UAE, or otherwise, to carry out the Purposes. This includes, disclosing and sharing your Personal Data with the following:

• our subsidiaries and affiliates;
• any of our directors, officers, employees, representatives, agents or delegates;
• any of our shareholders or related corporations, and any of their successors or assigns, and their directors, officers, employees, representatives, agents or delegates;
• our professional advisers, consultants and auditors;
• any sub-contractors which any of our service providers, agents, suppliers, delegates or contractors may appoint from time to time to provide them with services in connection with the Services that we offer to you, and their directors, officers, employees, representatives, agents or delegates;
• anyone who takes over or may take over all or part of our rights or obligations under any agreement we have with you or anyone any agreement we have with you (or any part thereof) is transferred to or may be transferred to;
• any service providers, agents, contractors, delegates, suppliers or third parties which we may appoint from time to time to provide us with services in connection with the Services that we offer to you, and their directors, officers, employees, representatives, agents or delegates;
• any person who we believe in good faith to be your legal advisers or other professionals;
• any relevant governmental or regulatory authority, in so far as we need to do so to keep to any Applicable Laws, or which we in good faith believe that we should keep to; and
• pursuant to a request by any relevant governmental or regulatory authority (regardless of the reason for such request and whether such request is exercised under a court order or otherwise);
• parties which assist us in carrying out the Purposes laid out above in this Privacy Policy; and
• any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any Applicable Laws, provided that:
  • (1) In the case of disclosures under any of the circumstances in (a) to (g), we shall procure that the recipient is subject to the same duty of confidence; and
  • (2) In the case of disclosures under any of the circumstances in (h) and (k), we shall disclose such Personal Data in accordance with the terms of the UAE Data Protections Laws. We shall exercise reasonable caution and diligence to determine the validity and proportionality of any request and where reasonably practicable obtain appropriate written and binding assurances from the recipient of the Personal Data in relation to the disclosures.

With your express consent we may transfer, store, process and/or deal with your Personal Data outside the UAE for one or more of the Purposes set out above. In doing so, we will comply with the UAE Data Protection Laws and other applicable data protection and privacy laws. For example, if we transfer your Personal Data to a country outside the UAE that lacks an adequate level of data protection, as determined by the UAE Data Protection Laws, we will ensure that appropriate safeguards are in place. You can contact our Data Protection Officer using the contact details provided below for further details of the safeguards we put in place. We implement appropriate technical and organisational measures to ensure that any processing of your Personal Data is undertaken securely and in compliance with the UAE Data Protection Laws. This includes encrypting all Personal Data stored outside the UAE, both whilst in transit and also whilst in storage.

Your Personal Data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any other business purposes or to comply with any Applicable Laws. This means that we will normally retain your Personal Data for a period of 6 years following the end of our relationship with you.

Under the UAE Federal Data Protection Law you have a number of key rights as a data subject:

• Right to request access: you may request access to your Personal Data that we hold, or request the rectification of any inaccurate Personal Data or the erasure of Personal Data under certain circumstances. You may also restrict our processing of your Personal Data under certain circumstances.
• Right to object: you have the right to object to the processing of your Personal Data on reasonable grounds and where the processing of your Personal Data is being undertaken in relation to the performance of a task carried out in the public interest or in the exercise of any official authority vested in us or where the processing is necessary for the purposes of our or a third party’s legitimate interests.
• Right to receive Personal Data: you have the right to receive Personal Data you have provided to us in a structured, commonly used and machine-readable format in the circumstances where we have processed your Personal Data in relation to with the services we provided to you and that processing has been carried out by automated means.
• Right to object to automated decision making: in the circumstances where we are undertaking automated decision making in relation to you, you have the right to object to any decision based solely on such automated processing which produces legal consequences or otherwise seriously impacts you. You have the right, in such circumstances to have the decision reviewed manually.

If you would like to exercise any of your rights in relation to your Personal Data or require further information on the scope of any such rights, please contact our Data Protection Officer (see the contact details below).

We use a variety of technologies on our website and mobile applications to collect information that helps us understand how our Services are used so we can refine our services and simplify the user experience. A cookie is a small file of letters and numbers that is stored on your device when you visit a website or use an app. Cookies may expire at the end of a web session or app or persist in order to store your settings and preferences.  A web beacon, also known as a pixel tag, is a tiny transparent image embedded in a website or an email to measure usage and activity.  In some case, a web beacon triggers the placements of a persistent cookie on your computer.

Cookies collect information about users and their visit to the website or use of the app, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or app. We use cookies and other technologies to facilitate your internet sessions and use of our apps, offer you products and/or services according to your preferred settings, track use of our website and apps and to compile statistics about activities carried out on our website and/or through our apps.

You may set up your web browser to block cookies. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies, you may not be able to use certain features and functions of our website.

We also use analytics programs such as Google Analytics for web analytics purposes to manage and improve our website, mobile apps and/or our Services. Accordingly, your Personal Data may be collected for reports such as impression reporting, demographic reporting, interest reporting and to assist with tailoring our online advertising to provide you with a better experience.

We and our third-party vendors and service providers, including Google, use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together, to inform, analyse, optimise, and serve custom ads based on your interests, searches and prior usage patterns when visiting our website, mobile apps, and for other market research analysis purposes such as impression reporting and how your interactions with these ads are related to visits to our website, mobile apps, amongst others. As a consequence, third party vendors and service providers may show our ads on other websites or mobile apps. We neither support nor endorse the goals, causes or statements of these websites or mobile apps which display our ads.

Using the Google Ad Settings, you may control the ads you view, block specific advertisers, learn how ads are selected for you, and opt-out of Google Analytics for Display Advertising. To opt out from any collection or use of information by Google Analytics, please download and install the Google Analytics Opt-Out Browser Add-on or any other available means. By opting out, you will not be subject to online advertising or marketing analysis by Google Analytics and you will no longer receive ads tailored to your browsing patterns and usage preferences.

Our website may contain links to other websites which are not maintained by us. This Privacy Policy only applies to our website, mobile apps, and/or our Services. When visiting these third-party websites, you should read their privacy policies which will apply to your use of these third-party websites.

Our Privacy Policy may change from time to time. If we make a change to this Privacy Policy, we will notify you through our website. By continuing to use our Services after those changes have become effective, you agree to be bound by the revised Privacy Policy.  It is your responsibility to periodically check our website and this Privacy Policy to check for any changes.