1 INTRODUCTION
1.1 The terms of this privacy policy read together with the terms and conditions constitutes a legal and binding contract between you and JBP Commercial Brokers, a limited liability company validly existing under the laws of UAE (JCBL) (hereinafter referred to as "Privacy Policy"). The Privacy Policy sets the terms on which JCBL ("we", "us", or "our") collects, uses, maintains, and discloses your personal information when an individual interacts with us through JCBL Platforms[1] and JCBL Services [2] which may include but not be limited to physical paper base or application form, mobile application, websites or through JCBL employees and agents. It also details your rights in respect of JCBL processing your personal information. Throughout this policy, the term “Customer”, "user", “you” or "your" refers to the individual accessing or using JCBL Services, or the company, or other legal entity on behalf of which such individual is accessing or using the JCBL Services, as applicable. We highly prioritize your privacy and are committed not only to safeguarding your personal information but also to help you understand how and why your information is used. By using JCBL Services, you acknowledge your understanding and acceptance of the practices described in this Privacy Policy. Further, by accepting the terms of the Privacy Policy, you are consenting that JCBL may collect and store the Customer Data for the period you subscribe to and/or use the JCBL Services, subject to the limitations set out in these terms. Please note that we may periodically update this Privacy Policy as necessary to reflect changes in our practices or for other operational, legal, or regulatory reasons. The most current version of this policy will always be accessible on JCBL Platforms and JCBL Website. We encourage you to review this policy frequently to stay informed about our most current data protection practices. You should take note that the information and privacy policies of JCBL Partner Institutions (as defined under the T&Cs) or other websites to which hyperlinks are provided, may be different from JCBL's. JCBL cannot guarantee the security of the information, which you transmit to us.
2 SECURITY MEASURES
2.1 At JCBL, we employ security measures to protect Customer Data (hereinafter defined) against unauthorized access, modification, disclosure, or destruction.
2.2 Our physical security measures help safeguard the infrastructure that houses Customer Data, including secure data centers and backup systems. We regularly review our security practices, adapting to technological advancements and industry best practices to continually enhance data security.
2.3 In order to provide a seamless and efficient service, JCBL may need to transfer and process Customer Data to JCBL Partner Institutions as well as other third parties within the UAE or even across geographical borders. Please be assured that during these transfers, we adhere strictly to all applicable data protection laws and industry best practices to maintain the confidentiality and integrity of Customer Data. While we maintain data protection standards, we want to inform you that the legal requirements regarding data protection can change from time to time and differ from one country to another. Despite these changes and differences, we are committed to safeguarding Customer Data. Your use of JCBL Platforms and JCBL Services, and your decision to provide such information, constitutes your consent to the transfer, storage, and processing of Customer Data as laid down in this clause. Where we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw your consent at any time by contacting us using the contact details set out in this Privacy Policy.
Upon receiving such request to withdraw consent by the Customer, JCBL shall endeavor to stop using/processing the Customer Data within a reasonable time
2.4 We recognize that you also play a critical role in data security. We advise you to protect your user credentials and avoid sharing them with others. If you suspect any security breach related to your account, please notify us immediately. While no digital platform can guarantee absolute security, we continuously implement and update administrative, technical, and physical security measures to protect your data to the best of our ability.
2.5 Our employees understand to respect the confidentiality of Customer Data. Only authorized employees of JCBL are permitted access the Customer Data.
3 CUSTOMER DATA WE COLLECT
3.1 During the use of JCBL Platforms and JCBL Services, users will be asked to provide JCBL with certain Customer Data as provided hereinbelow.
3.2Customer Data: Customer Data for the purposes of this Privacy Policy as well as for the purposes of the use of JCBL Services and JCBL Platforms may include but not be limited to your financial information, identification documents like Emirates ID and passport and any other national ID, demographic and personal information including but not limited to name, address, email address and telephone numbers, your financial details including details of financial products you have with other financial institutions, credit and credit bureau information, information of 3rd parties (such as references which may include but not be limited to the contact information of such references your provide), bank account details, income proofs, and credit scores. Customer Data also includes copies of government-issued IDs and documents, including but not limited to identity and address proofs, and other relevant Know Your Customer (KYC) documents, which may be shared or uploaded by you during the application process. Customer Data may also include your data sourced from third parties including but not limited to financial institutions and credit bureaus.
Customer Data may also include Usage, Behavioral, and Demographic Information: We collect a broad range of information about how users interact with our platform and services. This includes usage data, such as the specific areas of the platform users visit, the services they access, their IP address, device information, hardware settings, browser details. We also collect behavioral data, which provides insight into the users' activities on our platform, including system activity and mechanisms such as but not limited to the tracking of referral URLs. To provide a more tailored service, we gather demographic information, which includes non-personal information such as age, gender, occupation, interests, and location. All this information plays a crucial role in analyzing the use of our resources, troubleshooting problems, preventing fraud, and ultimately improving our services.
3.3 By using JCBL Services or accessing JCBL Platforms, you hereby provide your consent to our collection, disclosure, transfer and use and/or processing of Customer Data as described in this Privacy Policy. We may track the collected internet protocol address or mobile device information from user’s interaction or visit to JCBL Platforms and analyze this data for safety and statistical analysis. This information helps us keep JCBL Platforms safe from breaches as well as helps JCBL measure the use of our platform and improve our services. We also want to bring to your attention that this Privacy Policy does not extend to websites owned or managed by third-parties or for data or information disclosed by the user to third-parties including but not limited to JCBL Partner Institutions. Please note, the use of JCBL Services by the Customer indicates the Customer’s consent to our collection, use, processing, transfer and disclosure of Customer Data as described in this Privacy Policy.
3.4 If you provide us with personal information on someone else’s behalf (such as a joint applicant or you authorize an individual who will be permitted to instruct JCBL to take action on your behalf), you must have their permission to do so.
4 USAGE, DISSSEMINATION AND RETENTION OF CUSTOMER DATA
4.1 JCBL utilizes, analyzes and leverages Customer Data as described in this Privacy Policy along with the Terms and Conditions to fulfil a contract, or take steps linked to the Terms and Conditions, to provide JCBL Services and individualize each user’s experience on our platform as well as provide superior and faster service and processing. This pertains to, but is not restricted to, Customer Data expressly provided by the user along with Customer Data sourced from other sources including but not limited to financial institutions, credit bureaus and other relevant entities. Furthermore, we may need to share Customer Data with third parties including but not limited to JCBL Partner Institutions, service providers, business associates, financial institutions, JCBL employees and agents or to comply with legal requirements, in strict adherence to applicable laws and regulations. We hold your data in line with the objectives specified in this Privacy Policy or as the law allows, implementing suitable steps to guarantee data safety.
4.2 JCBL may partner with trusted third-parties to offer vital services on JCBL Platforms. These third parties might be JCBL Partner Institutions, companies or individuals tasked with data storage and hosting services, marketing assistance and customer support.
4.3 JCBL Platforms or use of JCBL Services may feature links to third-party websites or services including but not limited to JCBL Partner Institutions that are not under the direct purview of JCBL. These links are provided for processing your application, but we do not vouch for, assure, or pledge the security of these third-party sites or services. We encourage you to scrutinize the privacy norms and policies of any such third-party sites or services before sharing the Customer Data. Furthermore, use of JCBL Platforms and JCBL Services might necessitate the use of the internet for advertising activities, which could be executed by third-party service providers. These providers could employ internet technologies such as cookies, encoded URLs, and other tracking tools which might gather information, not limited to tracking your interactions, time spent, and pages viewed. JCBL may leverage this compiled and anonymized personal information to generate non-personal, statistical, or aggregated data. This data, could be used for an array of purposes, including but not limited to research, analytics, marketing, and service enhancement and the Customer hereby expressly consents to JCBL for usage of Customer Data for such purposes.
4.4 At JCBL, circumstances may arise where we need to disclose Customer Data during significant business events, including but not limited to mergers or acquisitions. During such events, it may be necessary to transfer Customer Data as part of the proceedings. Be assured, any such actions are always conducted in accordance with applicable data protection laws and with a priority focus on keeping Customer Data secure. In addition, legal obligations may call for the accessibility, retention, and revelation of Customer Data. These actions will be performed by JCBL with an honest attempt to comply with legal mandates, safeguard JCBL’s assets and rights, avert potential misconduct, ensure safety of Customer Data. Further, by accepting the terms of the Privacy Policy, you are consenting that JCBL may collect, process and store Customer Data for as long as it is lawful for us to do so. In making decisions about how long to retain data we take account of the following:
a. The termination date of the relevant contract or business relationship;
b. Any retention period required by law, regulation or internal policy;
c. Any need to preserve records beyond the above periods in order to be able to deal with actual or potential audits, tax matters or legal claims.
5 USER RIGHTS & GENERAL PROVISIONS
5.1 User Rights and Options: As part of our commitment to our users at JCBL, we prioritize your autonomy over Customer Data. This means that you have the ability to view, correct, or delete your information that has been stored with JCBL by informing JCBL in writing or by the use of JCBL Platforms wherever possible. Your providing Customer Data to JCBL is optional in your hands, however, it should be noted that not providing Customer Data or providing incomplete or incorrect Customer Data might limit or restrict certain features and functionalities or may even completely disable the use of JCBL Platforms and JCBL Services. Please note that as part of JCBL using Customer Data to have your application for financial products processed through JCBL Partner Institutions, Customer Data may be shared by JCBL with third parties including but not limited to JCBL Partner Institutions and other third parties like financial institutions, banks, and credit bureaus. Customer Data once shared by JCBL with these third parties may not be possible to be deleted or withdrawn or taken back from such third parties.
5.2 You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract.
5.3 You can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
5.4 These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.
5.5 To exercise any of these rights, or to obtain other information, you can get in touch with us using the details set out below.
5.6 Where we require your personal data to comply with legal or contractual obligations, then providing of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us.
5.7 Communications for Promotion and Marketing: At JCBL, we focus on delivering personalized services, promotions, and experiences. To fulfill this, we might utilize Customer Data to enrich your engagement with our offerings and deliver pertinent promotional or marketing updates. However, we respect your preferences and offer you the ability to opt-out from such communications, either by adhering to the instructions in each communication or by informing JCBL in writing. Please remember that even if you opt-out from promotional communications, essential transactional or administrative messages may still be sent to you from JCBL.
5.8 Age Limitation and User Eligibility: The JCBL Services are purposefully crafted for individuals who meet the legal age requirement for financial product acquisition, as specified by the laws of the United Arab Emirates. We stringently implement measures to prevent the gathering of Customer Data from individuals below this age threshold. In any case where Customer Data is inadvertently collected, we promptly take action to expunge it from our systems. If you are a parent or guardian and become aware that your minor child has shared Customer Data with us, we urge you to notify us in writing at the earliest opportunity.
5.9 Commitment to Customer Satisfaction: At JCBL, your trust is our most valued asset, and we continually strive to nurture this bond. If you encounter any issues, discomfort, or dissatisfaction with our services, representatives' conduct, or Customer Data handling practices, we welcome you to notify us promptly, detailing the nature of your problem, and including all relevant details along with your contact information. These insights enable us to address your concerns promptly and effectively. We encourage you to provide any specific resolution steps you foresee that could help manage your concern effectively. Our team is devoted to thoroughly investigating your complaint and will strive to find a resolution in line with our commitment to protecting Customer Data, customer satisfaction and legal compliance. At JCBL, maintaining high standards of service integrity is our priority.
5.10 User Requirements
(i) You are required to provide accurate and updated Customer Data in order to establish and manage your contractual relationship with JCBL and duly avail JCBL Services. You acknowledge that by providing inaccurate personal data you are restricting JCBL and JCBL Partner Institutions from successfully providing its services.
(ii) You will be liable for any misappropriation of Customer Data, including but not limited to, fraud and identity theft and JCBL is indemnified from any such instances of misappropriation.
(iii) If any part of JCBL Website links you to other websites, those websites do not operate under these terms. JCBL recommends you examine the privacy statements posted on those other websites to understand their procedures for collecting, using, and disclosing personal information.
5.11 Contacting us
If you have any questions, concerns, or complaints regarding this Privacy Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws.
JCBL Platforms include any mode of interaction that you use to interface with JCBL and vice versa or JCBL uses to interface and interact with the JCBL Partner Institutions and vice versa. JCBL Platforms may include but not be limited to mobile applications “JCBL App”, JCBL Website, interface over the phone, SMS, physical interface through in person meetings by JCBL representatives, mail, e-mail and social media platforms including Whatsapp.
