Privacy policy

I - OWNERSHIP.

In compliance with the provisions of Law No. 30 of 2018 with respect to Personal Data Protection Law of Bahrain (hereinafter PDPL), we hereby inform you that the personal data communicated will be incorporated into a database owned and operated by GLOBAL EXCHANGE BAHRAIN FOREIGN EXCHANGE SERVICES W.L.L (hereinafter Global Exchange), which has the following details:

Company: GLOBAL EXCHANGE BAHRAIN FOREIGN EXCHANGE SERVICES W.L.L.

CR nº: 70073

Tax Identification Number: 220013853500002.

Registered and Postal Address: Flat/Shop No. 2553, Building 200, Road/Street 2403, Muharraq, Block 224, Bahrain.

Contact form: our ARCO contact form

II - CONTACT.

For any matter related to the processing of personal data by Global Exchange, please contact our Data Protection Officer through the following contact form.

III - PERSONAL DATA.

Global Exchange will collect the following data:

1. EXCHANGE OF CURRENCY AND SERVICES: Data provided for the provision of Global Exchange services. The services will be identified at the time of data collection and registration.

Data collected: Name, surname, identity document, voice and image recording, contact address, address, e-mail address, contact telephone and other necessary data according to the service requested, and that will be exclusively necessary to register for the services of Global Exchange.

Purpose: The registration of data subjects for the provision of services and to establish and maintain business relationships; to perform due diligence processes on all clients; and, to comply with applicable regulations and laws.

Legitimation: The existing legal or contractual relationship necessary for the provision of the service and the legitimate interest for the development of commercial relations.

Storage periods: The data will be kept for the time necessary for the purpose of the processing, and once this is completed it will be available to the public administration, judges and courts, for the legal periods established addressing and defending possible responsibilities arising from the processing.

2. SALES CONTACT: In response to inquiries and contact requests received by any means, Global Exchange services, as well as the maintenance of business relationships:

Data collected: Name, telephone, e-mail and inquiry

Purpose: Answer to requests for information that the data subject has made by any means with regards to Global Exchange products and services, and establish and maintain business relationships.

Legitimation: Based on the provision of consent, Global Exchange is entitled to process the data of the data subject provided through the contact request, and in accordance with the legitimate interest for the development and maintenance of commercial relations.

Storage periods: The data will be kept until the moment in which the data subject requests the cancellation or deletion of his data and once deleted, they will be kept at the disposal of the public administration, judges and courts, for the legal periods established for the attention and defence of the possible responsibilities arising from the processing.

3. CV OR EMPLOYMENT: Sending of CVs through the website or through any means to Global Exchange.

Data collected: Professional area, name, surname, telephone, e-mail, CV, cover letter and any other personal data associated with the CV or professional profile.

Purpose: To manage the data subject's candidacy for the published selection processes or for other vacant positions according to his/her professional profile that may arise in the future within the activities of Global Exchange.

Storage periods: The data will be kept until the data subject is allocated a job or until he/she asks us to delete them. It will therefore be kept for the time necessary for the purpose of the processing, and once this is completed it will be available to the public administration, judges and courts, for the legal periods established addressing and defending possible responsibilities arising from the processing.

Legitimation: Provision of the consent of the data subject.

Addressees: The data provided and derived from the selection process may be transferred to third companies identified by the data subject for the request of references that may be necessary for the selection of the candidate.

4. PROMOTIONAL MATERIAL or NEWSLETTERS: The sending of information, news, notices, reminders and promotions that could be of interest to the data subject, relating to the activities of Global Exchange.

Data collected: E-mail address, name and surname.

Purpose: The registration of data subjects for the submission of information, news and promotions, and to establish and maintain business relationships.

Legitimation: Provision of the data subject's consent to Global Exchange for registration in promotional services, and legitimate interest for the development of commercial relations.

Storage periods: The data will be kept until the moment in which the data subject requests the cancellation or deletion of their data and once deleted it will be kept at the disposal of the public administration, judges and courts, for the legal periods established addressing and defending the possible responsibilities arising from the processing.

5. CLIENTS/SUPPLIERS: Professional personal data provided by Clients/Suppliers for the provision of services and management of the legal or contractual relationship.

Data collected: Name, surname, identity document, voice and image recording, professional contact address, e-mail address, contact telephone no. & other necessary data according to the service requested.

Purpose: The management of the contractual relationship of the service; to perform due diligence processes on all clients; and, to comply with applicable regulations and laws.

Legitimation: The existing legal or contractual relationship necessary for the provision of the service.

Storage periods: The data will be kept for the time necessary for the purpose of the processing or deletion, and once completed or deleted it may be kept for a period of six years at the disposal of the public administration, judges and courts, addressing and defending possible responsibilities arising from the processing.

6. ACCESS CONTROL AND SECURITY: Data collected by video surveillance cameras:

Data collected: Images, voice and video recording.

Purpose: To control access to and management of the internal security of Global Exchange facilities.

Legitimation: Legitimate interest in guaranteeing the security of the facilities on the part of the owner, justifying the fact that the images are necessarily captured when accessing these facilities.

Storage periods: The data will be maintained and kept for a minimum period of one month, unless it was necessary to keep it for a longer period due to being convenient to clarify any infraction or illicit act detected.

IV - TRANSFERS OR COMMUNICATIONS OF DATA.

Your personal data will not be transferred to any third party without a legal basis that legitimates this transfer (legal relationship, court or administrative order, etc.).

Whenever we transfer your personal data out of the EEA and/or Bahrain (particularly iCloud service providers such as AWS), we ensure a similar degree of protection is afforded to it by signing the corresponding Data Processor contracts and verifying that they meet sufficient guarantees to implement appropriate technical and organisational measures, so that the processing is carried out in accordance with the requirements of the PDPL.

For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries and Model contracts.

V - EXERCISE OF RIGHTS.

The Data Subject has recognised his/her rights to the access, rectification, suppression, limitation, opposition and portability of his/her data. Similarly, he/she is protected by the right to withdraw his/her consent to the processing by Global Exchange. He/she also has the right to lodge a complaint with the supervisory authority.

At any time, the data subject may exercise his/her rights by sending a communication, attaching a document that accredits his/her identity and expressly indicating the right he/she wishes to exercise, to Global Exchange at the postal address indicated above or by sending a message through our contact form.

Global Exchange is obliged to comply with the regulations on the prevention of money laundering and the financing of terrorism. Compliance with this policy may result in the application of certain restrictions on the exercise of your rights.

VI - TECHNICAL AND ORGANISATIONAL SECURITY MEASURES.

In compliance with current regulations, Global Exchange has adopted the necessary technical and organisational measures to maintain the level of security required for the personal data processed. It is also equipped with the necessary mechanisms at its disposal to prevent, as far as possible, unauthorised access.

For example:

• We work to protect the security of your personal information during transmission by using Secure Sockets Layer (SSL) software, which encrypts the information you enter.

• We have physical, electronic, and procedural security systems in place for the collection, storage, and disclosure of customer personal information. Our security procedures mean that we may occasionally ask you for proof of identity before providing you with confidential information.

VII - DATA PROVIDED.

The data collected through the different means are strictly necessary to meet your request, which the Data Subject voluntarily communicates. The refusal to provide data qualified as mandatory will result in the failure to provide or the impossibility of accessing the service for which they were requested. Data may also be provided on a voluntary basis in order to ensure that services can be provided in an optimal manner. Likewise, in those cases in which the data of third parties is provided, the Data Subject undertakes to inform them of the content of this privacy policy.

The Data Subject undertakes to communicate as soon as possible to Global Exchange any modification and rectification of their personal data in order for the information contained in the Global Exchange Activity Records to be updated at all times.

Based on the legitimate interest of Global Exchange, the personal data of the Data Subject may be used for the establishment or maintenance of commercial relations by any means, including electronic means, regarding information of interest in relation to Global Exchange products and services, and the Data Subject may at any time oppose such processing for commercial purposes by sending a written communication to the postal address indicated, or by sending a message through our contact form.

GLOBAL EXCHANGE BAHRAIN FOREIGN EXCHANGE SERVICES W.L.L.; March, 2023.