Website Visitors

Like most website operators, Ajyad collects non-personally identifiable information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Ajyad's purpose in collecting non-personally identifiable information is to better understand how Ajyad's visitors use its website.

Gathering of Personal Data

Certain visitors to Ajyad's websites choose to interact with Ajyad in ways that require Ajyad to gather personal data. The amount and type of information that Ajyad gathers depends on the nature of the interaction. For example, we ask visitors who sign up for services through our channels to provide an email address and contact number for validation and verification.

Biometrics

We allow customers to login to our mobile app through smartphone or device biometrics, such as Trusted Devices, which can be a device registered facial recognition. We do not store the actual biometric information, but we depend on device-stored validation to verify your identity. This feature is available if customers opt-in to enable it and is not enabled by default.

For new customers wishing to enroll through our mobile app, we require them to use their device camera or the installed cameras to capture photos of their national ID to retrieve data and information required to open an account as part of the Know Your Customer (KYC) process mandated by the Central Bank of Bahrain (CBB). To verify the user, we also take photos and videos and match them with the photos in the supplied IDs. Matching is performed automatically.

The document capturing session supports the identification of potential fraud. The Firm and its verification partner perform verifications and checks of new applications for quality and security purposes. The identity verification process could be triggered for services or transactions requiring advanced authentication or verification of user identity.

Information We Collect

In order for you to utilize the services offered by us, we need to collect and process personal and financial information, such as the following:

• Contact Information: including name, maiden name and surname, title, home address, telephone numbers, and personal email address(es);
• Identity Information: including date and place of birth, citizenship, country of residence, government-issued documentation (for example, national identification number (CPR), driving license information), gender, civil status, beneficiaries and dependents;
• Employment Information
• Financial Information: including bank account details, payroll records, financial history and activity, income information (i.e. source and monthly average);
• Voice or Image Recordings: Biometric data (liveliness videos and images)

We may also request the submission of certain documents identifying with the information mentioned above.

How Information Is Collected

We collect personal data from the following sources:

• Personal data received and collected via the Channels
• Personal data we receive directly and voluntarily from you
• Personal data we obtain from third parties such as the Benefit Credit Reference Bureau, and any third party financial service provider appointed by us.
• Personal data collected from publicly available sources, such as any information available online

How We Use Your Information

We collect and use your information for the following purposes:

• To provide our services to you and allow you to use our mobile application
• To assess customers' creditworthiness to provide services
• To improve our services and resolve customer issues
• To comply with the legal and regulatory requirements
• To comply with laws that require us to verify the identity of our customers
• To detect and prevent fraud or other financial crime
• For customer onboarding and registration, screening customer name, account recovery and KYC (Know-Your-Customer)
• For personalized and enhanced customer experiences

Information We Collect Automatically

We may also automatically collect information about you when you access or use the Site or transact business with Us, including:

• Transaction Information: We may collect information about the transaction, such as product, service or transaction details, and the date and location of the transaction.
• Log Information: We may obtain information about your use of our channels, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to this Site.
• Device Information: We may collect information about the computer or mobile device you use to access Our Services, such as the hardware model, operating system and version, unique device identifiers, mobile network information, and browsing behavior.
• Location Information: We may collect information about the precise location of your device when you consent to the collection of this information. We may also collect information about your approximate location each time you access this Site.
• Information Collected by Cookies and other Tracking Technologies: We may use cookies, web beacons, and other tracking technologies to collect information about you and your interaction with this Site, including information about your browsing behavior, purchase behavior, and other engagement with the Services. Most web browsers are set to accept cookies by default, but you can usually change your browser settings to remove or reject cookies.

We do not collect, process or store sensitive information identified in the Personal Data Protection Law, without explicit consent or in compliance with Central Bank of Bahrain (CBB) regulations.

Customer Profiling

Customer profiling is the practice of analyzing and categorizing customer data to create a profile of their interests, preferences, and behavior. We may use customer profiling to improve our products and services, personalize your experience, and provide you with relevant offers and promotions. We may also share this information with third-party service providers who help us analyze and interpret customer data. Customer profiles are handled with utmost privacy similar to customer financial transaction data. We will use aggregated data and anonymized data where possible to protect your privacy. If you have any questions or concerns about our customer profiling practices, please contact us.

Document Verification

Additionally, we use face data (Selfie) and liveness videos and photos as part of our regulatory requirements during onboarding/registration to confirm your identification documents. This includes taking a picture of your face based on some gestures requested such as "Wink with your left/right eye" or "Smile".

We may also ask you to scan your legal documents for this registration. Once you take a picture and scan your documents, we will compare the picture to the one found in the scanned legal documents to verify that this is the same user. This verification process ensures that you are the legitimate user. The data used for this verification process is neither stored nor shared with any third parties.

Data Storage and Sharing

Any information collected will be stored for a period of time necessary to provide you with the services. We may also retain the information for a longer period, but in no doubt shall such period exceed any maximum timeframe in the relevant regulations or laws of the Kingdom of Bahrain. Your data remains confidential and secure within our systems. Additionally, your personal information will not be shared with any third party except as provided in this Privacy Policy or unless required by any governmental, legal or regulatory authority.

We may share your personal data with:

1. government authorities;
2. companies within our corporate group and our affiliates;
3. any licensed third party service provider for the purpose of providing our services to you;
4. third party service providers who support the provision of our services, including lawyers and legal consultants, auditors, IT support services and other professional service providers;
5. credit reference agencies, including the Bahrain Credit Reference Bureau;
6. a third party who may acquire our business and/or assets, or a portion thereof;
7. select third parties who may wish to market their products or services to you; and
8. any third party where we consider that it is necessary to protect, defend or enforce our rights under any agreement governing our relationship with you.

When applicable, we will implement appropriate measures to ensure that your personal data remains protected and secure when it is transferred outside of Bahrain, in accordance with applicable laws.

Data Security

We implement robust security measures to protect your data from unauthorized access, alternation, or disclosure.

Marketing

We may use your personal data for direct marketing purposes, including informing you about our promotions and features through our channels. You may ask us to stop any marketing communication by contacting us at any time through email via compliants@emyaa.com.

Withdrawal of Consent

You have the right to withdraw your consent to our use of your personal data by contacting us at any time. However, as such data is integral to us providing you with our services, any consent withdrawal will be deemed as a request for termination of the services and accordingly subsequent consequences shall be applied.

Right of Access, Correction, Erasure and Objection

By contacting us, you may:

1. Request access to your personal data in order to receive a copy of the personal data we hold about you.
2. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data
3. the right to restrict processing - you can ask use to restrict the processing of your personal data;
4. the right to object to processing - you can object to the processing of your personal data and direct marketing;
5. the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
6. Request correction of your personal data where it contains any incomplete, inaccurate or outdated information about you.
7. the right to erasure - you can ask us to erase your personal data;
8. Object to processing causing material or moral harm.
9. the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting http://www.pdp.gov.bh/en/regulations.html

You may exercise any of your rights in relation to your personal data by written notice to us or contacting us by submitting a letter to our Compliance Officer through emailing compliants@emyaa.com.

We will review your request and respond within the appropriate timeframes in accordance with the Personal Data Protection Law.

Changes to the Privacy Policy

We hold the right to periodically update or alter this Privacy Policy. In case of significant modifications, we will provide notification through appropriate notification channels. Your continued utilization of the eMYAA mobile application post these changes denotes your acceptance of the revised Privacy Policy.