| Privacy Commitment |
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Zenj Exchnage Co WLL (ZENJEX) is committed to protecting consumer privacy and upholding the Kingdom of Bahrain’s rules,
regulations and guidelines during and of your interactions with us including but not limited to visits to our website and recognizes our
responsibility to hold your information secure and confidential. You can visit our website without telling us who you are or revealing any
information about yourself. However, if you give us any personal information about yourself or others we promise to treat it securely, fairly and
lawfully. Any information collected, stored or processed through any of our channels online or offline will be done so in accordance with all
applicable laws and regulations and Kingdom of Bahrain’s (Bahrain) Personal Data Protection Law.
When we ask you for personal information through any interaction or online it will only be in response to you using, inquiring or
being open to receive updates and information that may lead you to use one of our products or services. Therefore we may use personal
information you provide for the purpose of providing more relevant content to you.
This Privacy policy sets out the basis upon which any personal data we collect from you, or you provided to us, will be processed by us.
Please read this policy carefully to understand how your personal information will be treated. By submitting your personal details to us you
are deemed as agreeing to us using them in line in accordance with the terms and conditions in this policy. This policy may be changed from
time to time so please read it periodically.
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| Our contact details |
If you have any questions or want more details about how we use your personal data, please let us know. You can contact us:
For requests relating to exercising your rights under data protection laws, please contact Mr. Amor Rocio (Data Protection Officer and DMLRO) on the following channels:
• Via email at: compliance@zenjex.com
• Via online form at: https://zenjex.com/ContactUs.aspx/
• Via telephone at: +973 17217008
• Via post at: ZENJ EXCHANGE CO WLL,P.O. BOX: 236, Manama, Kingdom of Bahrain
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| The personal data we collect |
We collect a range of personal data directly from you and, in some instances, from third parties. We have listed the kinds of personal data below so that you can understand what we hold.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes name, username or identifier, CPR number, photograph, signature, passport, national ID card and date of birth.
• Contact Data includes address, email address and telephone numbers.
• Financial Data includes bank account and mobile wallet number or any other financial account.
• Transaction Data includes details about payments to and from you, other details of products, services you have purchased from us or one of our partners or affiliates.
• Technical Data includes internet protocol (IP) address, cookies, your login data, browser type and version and other technology on the devices you use to access
our or our affiliates or partners digital channels.
• Profile Data includes your username and password, your interests, preferences, and feedback and survey responses.
• Usage Data includes information about how you use our website, APP, digital platforms, products, and services.
• Marketing and Communications Data includes information we receive through our communication with you, your preferences in receiving marketing from us and our third parties and your
communication preferences.
• Sensitive Personal Data that requires a particularly high level of care when processing due to its sensitivity. The sensitive data we process includes fingerprint information,
criminal records, health and medical information and information pertaining to political exposure.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated data could be derived
from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. |
| How we collect your personal data
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We use different methods to collect data from and about you including through:
• Direct interactions: You may give us your Identity, Contact, Profile, Sensitive Personal Data, Financial and Transaction Data by filling in forms or by corresponding with us by post, phone, interaction during promotions events surveys and email or otherwise.
This includes personal data you provide when you:
o apply for our services;
o apply for one of our job positions;
o visit our offices or branches;
o create an account on our online services;
o subscribe to our service or publications;
o request marketing to be sent to you;
o enter a competition, promotion or survey, interaction during an event; or
o give us feedback or contact us.
• Automated technologies or interactions:
As you interact with our website, APP or other digital channels we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources:
We will receive personal data about you from various third parties and public sources as set out below:
o Technical Data from analytics providers such as Google Analytics, Google AdWords and Facebook.
o Identity, Contact, Transaction and Marketing and Communications Data from advertising networks and agencies in Bahrain.
o Identity, Contact and Marketing and Communication Data from wholesale customers, corporates and organisations we work with to sponsor events to sign-up new customers.
o Identity Data from beneficiaries collecting payouts sent by you through one of our branches.
o Identity and Contact Data from publicly available sources such as public websites and search engines.
o Identity, Contact and Profile Data from recruitment agencies referring potential candidates.
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| How we use your personal data |
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• Where we collect your explicit consent.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you.
You have the right to withdraw consent to marketing at any time by contacting us.
We will use personal information for the purpose(s) for which we tell you that it has been collected, and for other legitimate purposes as permitted by data protection and other relevant laws.
If you provide information when transferring money, purchasing or selling foreign currency or any other goods or services from ZENJEX,
you agree that we may use the personal information for the purposes of:
1. ensuring that content from the Website is presented in the most effective manner for you and for your computer;
2. complying with your order;
3. Where we have your consent, we will keep you informed by email or text message of similar products or services to those which you used;
4. providing you with email alerts whatsapp or phone alerts and updates which you have registered for or consented to;
5. allowing you to participate in interactive features of our service, when you choose to do so;
6. complying with our legal and regulatory obligations; and
7. notifying you about changes to our service;
8. complying with our legal and regulatory obligations (including fraud prevention, anti-money laundering and sanction screening). This includes checking the information you provide to us against information from against information from our Point of Sale applications and AML/CTF applications.
We will not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our online and APP users. You agree that we may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal information we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
We use your information for the following purposes:
To provide a requested service or carry out a contract with you
• collecting payment, processing and fulfilling your order and otherwise providing you with the information and services you request from us;
• when we partner with other organisations to provide a particular service (these partners will be identified to you at the time of the provision of the relevant service
e.g. when you access ZENJEX services through their digital channels);
• providing service messages, including messages notifying you about changes to services or changes to our terms, conditions and policies;
• enforcing any contract entered into between you and us for the provision of our services.
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Where we have your consent
• contacting you (including by phone, whatsapp, email or SMS) with marketing messages according to your marketing preferences.
• contacting you via email with short surveys, according to your survey preferences;
• when you are using a mobile device (such as mobile phone, tablet or wearable device), we may use your precise geo-location to provide you with
location-based services and provide you with targeted advertisements. You can control your geo-location settings within the app settings or your mobile device settings;
• enabling us and third-party websites to display relevant and targeted advertisements, based on previous behaviour, purchases, or any other relevant information;
• sending you an e-receipt if you confirm you would like one;
• where you have consented, collecting your marketing preferences and sharing these with a partner.
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| Purposes for which we will use your personal data |
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We have set out below, in a table format, a description of all the ways we plan to use your personal data, and
which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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| Purpose |
Lawful Basis |
To provide you with products and services you have requested
- To set up your accounts and customer profile to be able to use our products and services.
- To provide customer support relating to products and services you hold with us in person, at
our branches, via our call centers or through our applications and online.
- To advise you where we believe that you may be interested in products and services related
to those you already hold.
- To seek consent when we require it from you and to manage your consents and preferences, including where you
decide to withdraw consent.
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- Contractual obligation.
- Legitimate Interest.
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To promote our business
- To directly market our products and services to you in relation to products you already hold with us.
- To directly market our products and services to you if you have an expressed an interest in our products.
- To withhold from promoting products and services to you where you have opted-out of direct marketing.
- To develop our general advertising campaigns based on our macro customer analysis, both via social
media and conventional media methods.
- To manage our website and social media accounts to promote our business and engage with you online,
including responding to your queries.
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- Contractual obligation.
- Legitimate Interest.
- Consent
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To manage our business
- To identify corporates, vendors and strategic business alliances which Bahrain Financing Company could work with.
- To process payments for vendors and corporates that we work with as per the contracts in place.
- To provide management reporting to our senior management and the Board of Directors.
- To comply with rules and regulations set out by the government and regulators, including the Central
Bank of Bahrain, such as performing KYC and other needed checks.
- To exercise our rights as set out in contracts and agreements.
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- Contractual obligation.
- Legitimate Interest.
- Legal requirement.
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To comply with national and international law
- To comply with applicable regulations and laws
- To process due diligence on all clients and future clients.
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- Contractual obligation.
- Legal requirement.
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To manage security, risk and crime prevention
- To defend our interests via civil and criminal legal action.
- To support internal and external audits of our business.
- To implement physical security measures at our premises, for example using CCTV.
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- Contractual obligation.
- Legitimate Interest.
- Legal requirement.
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To carry out standard business functions
- To recruit employees to the business where you have applied to work for us.
- To manage our technology and IT systems to deliver our business requirements.
- To store, archive and destroy documentation in line with retention laws and requirements.
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- Contractual obligation.
- Legitimate Interest.
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Who we share personal data with
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We may share your personal data with the parties set out below for the purposes set out in the table above:
- Banking and financial services providers:
- Banks and financial services companies and payment companies involved in processing payments made by you using our services.
- Government and regulatory bodies:
- The Central Bank of Bahrain (CBB) and other governmental bodies and departments where required to by law or an instruction of theirs including to comply with applicable regulations.
- The Police, FID or the courts in the event that we wish to take legal action.
- Communications providers:
- Marketing agencies, social media platforms and communications firms who operate our website and social media channels on our behalf.
- Telecommunications firms who we use to contact you about your accounts and products and services you hold with us.
- Telecommunications firms who may send direct marketing messages to you on our behalf.
- Technology providers:
- Third party companies providing us with IT systems, application or IT support to maintain our systems.
- Ancillary service providers:
- Storage companies for archiving and destruction of your personal data once we have no need to retain it following delivery of products and services to you.
- External legal counsel in the event that we wish to take legal action.
- Our consultants who support us with our business.
- Our external auditors for auditing purposes.
- Recruitment agencies who support us with identifying and referring potential candidates.
- Other service providers required in order to fulfil our business operations.
- International Banks and service providers:
- Many of our external third parties are based outside Bahrain so their processing of your personal data
will involve a transfer of data outside Bahrain.
- Whenever we transfer your personal data out of Bahrain, we ensure a similar degree of protection is
afforded through contracts.
- The personal data provided is only to enable them to fulfil your requirement of the service your contracted
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to
process your personal data for specified purposes and in accordance with our instructions. Any third party disclosure is done
ONLY under contract to insure that our partners affiliates or otherwise relationship and access to information is governed by contract
that protects your confidentiality and privacy in accordance with PDPL.
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How we protect and retain your personal data
We treat the security of all data held by Zenj Exchange Co WLL with the utmost importance and that includes your personal data.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed
in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors
and other third parties who have a business need to know. They will only process your personal data on our instructions and they are
subject to a duty of confidentiality.Data is retained for as long as reasonably necessary to fulfil the purposes we collected it for,
including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements and the regulatory minimum
of 10 years. In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information. We have
put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach
where we are legally required to do so.
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Your rights and how to exercise them
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you would like to
exercise any of the rights below, you can do so by filling out this form or by contacting us using the details in the “Our Contact Details”
section above.
- Be informed of processing of your personal data
- Be notified of processing of your personal data
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Object to decisions based on solely automated processing
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
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No fee usually required
You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a
reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your
request in these circumstances.
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What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal
data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who
has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
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Time limit to respond
We try to respond to all legitimate requests within 15 calendar days. Occasionally it could take us longer than a month if your
request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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Complaints to the Data Protection Authority
Further to the rights that we comply with above, you also have the right to submit a formal written complaint to the relevant Data
Protection Authority if you have reason to believe that we have not complied with the data protection laws.
For information on how to submit a complaint to the Data Protection Authority, please contact the Authority directly.
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IP Addresses and Cookies
We may collect statistical data about our users’ browsing actions and patterns which do not identify the individual.
We collect this data by using a “Cookie” file, Cookies are small pieces of
information that are stored on and retrieved from
your computer by websites for record-keeping purposes. The cookies used by this website will not contain any personal identifiable
information about you.
In the event that we have links to other websites on our site these third party websites have their own
privacy policies, including cookies therefore we urge you to review them as we have no control over a
third party service provider.
Some cookies are deleted when you close down your browser. These are known as session cookies. Others remain on your device until
they expire or you delete them from your cache.
These are known as persistent cookies and enable us to remember things about you as a
returning visitor.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them,
visit www.allaboutcookies.org. Alternatively, you can search the internet for other independent information on cookies.
It is usually possible to stop your browser accepting cookies, or to stop it accepting cookies from a particular website.
You’ll still be able to use most of our online services, but some things might not work as you may expect if you do not allow us to store and access these cookies on your device.
Enabling us to customise your online experience based upon your individual circumstances, existing product holdings or activities
during previous visits to this website. If you do not allow cookies to be stored and accessed on your device, we won’t be able to tailor
your experience.
These cookies make our online services easier to use and help us to understand how people use our websites.
All modern browsers allow you to change your cookie settings. You can usually find these settings in the ‘options’ or ‘preferences’
menu of your browser. To understand these settings, the following links may be helpful, or you can use the ‘Help’ option in your browser
for more details.
- Cookie settings in Internet Explorer
- Cookie settings in Firefox
- Cookie settings in Chrome
- Cookie settings in Safari web and iOS
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How we use Cookies
If you delete cookies relating to this website we will not remember things about you, including your cookie preferences,
and you will be treated as a first-time visitor the next time you visit the site.
We use cookies (and other similar technologies) to:
- Provide products and services that you request and to provide a secure online environment
- Manage our marketing relationships
- Give you a better online experience and track website performance
- Help us make our website more relevant to you
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Links to Other Websites
Within our website we may have links to third party websites and if you decide to follow those links, Zenj Exchnage Co WLL will not be responsible
for the privacy practices or the content of those Web sites. They will have their own privacy policies, including cookies, and we urge you to
review them.
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Changes To Our Privacy Statement
This privacy policy may be updated from time to time so you may wish to check it each time you submit personal information on our website.
The date of the most recent revisions will appear on this page.
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Glossary
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Our lawful bases
Data protection laws applicable to Zenj Exchange Co WLL set out a number of requirements for legitimate processing of your personal data;
these are often known as lawful bases for processing. These lawful bases are:
- Contractual obligation – processing of personal data in order to implement a contract to which you are a party or,
upon your request, to conclude a contract;
- Legal requirement – processing of personal data to implement an obligation prescribed by the Law or implementation
of a court order from a competent Court or the Public Prosecution;
- Protection of your vital interests – processing of personal data to save your life;
- Legitimate interests – processing personal data where we have a legitimate interest
to do so in order to run our business.We may use this basis where it does not conflict
with your rights and freedoms set out in ‘Your legal rights’ below.
- Consent – processing personal data where you have given us written, explicit, and
clear consent to processing for a specific purpose issued based on your free will or
based on the free will of your guardian, executor or custodian.
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Your legal rights
Under the data protection laws applicable to Zenj Exchange Co WLL, You have the right to:
Right to be informed if we collect and use of your personal data or if this is done by a third party,
on our behalf. We do this by letting you know this within this Privacy Notice.
Right to be notified of processing of your personal data, especially as to whether or
not we are processing your personal data or if this is done by a third party, on our behalf.
Request access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate
data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is
no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where
you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully
or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply
with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party)
and there is something about your particular situation which makes you want to object to processing on this ground as you feel it
impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for
direct marketing purposes, or if the processing causes harm or distress to you or others. In some cases, we may demonstrate that
we have compelling legitimate grounds to process your information which override your rights and freedoms.
Object to decisions based on solely automated processing and request that another method be used to evaluate
you were a decision
has been taken solely based on automated processing of your personal data.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing
of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a
third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you initially provided consent for us to use or where we used
the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However,
this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your
consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time
you withdraw your consent.
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