This privacy policy (the “Privacy Policy”) tells you how EFG Holding S.A.E. and its subsidiaries (collectively, the “Company,” “we,” “our,” or “us”) process personal data we collect about you when you use our websites, when you use our mobile apps, and when you interact with us (collectively, the “Services”). This Privacy Policy also describes the manner by way of which we use cookies and employ similar tracking technologies. Additionally, this Privacy Policy sets out your personal data protection rights, including your right to object to some of the data processing which we carry out.
WHO ARE WE?
The controllers of your personal data are listed under Annex 1 of this Privacy Policy.
We are committed to protecting your privacy and your personal data.
WHAT PERSONAL DATA DO WE PROCESS ABOUT YOU?
We collect the following personal data you provide during your use of the Services:
Your name, your date of birth, your gender, data which appears on your government or state issued identification documents (e.g. passport and national ID), the selfie which you provide during the on-boarding process, your phone number, your fax number, your residential address, your postal address, your GPS (Global Positioning System) location, your e-mail address, your demographic information, your bank account, your payment card details, information about your income, information about your account balances, your account details (including your username and your password) in respect of the accounts used to access our website and/or our mobile app, your browser or your device information, information about how you access and/or use our Services, information collected via the employment of cookies, pixel tags, google tags, tracking URLs, and other similar tracking technologies, telephonic or electronic recordings, and survey responses and similar information which reveal your views and preferences.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We and our third-party service providers collect the above information in a variety of ways. This includes from you directly and:
DO WE COLLECT PERSONAL DATA ABOUT YOU FROM THIRD PARTIES?
We also collect your personal data from third parties, such as:
HOW DO WE USE YOUR PERSONAL DATA?
We collect and use your personal data for the following purposes:
In order for us to provide you with certain services, including, but not limited to, the Services, securities brokerage services, and research services, which require us to process your personal data, due to regulatory and legal requirements (for example KYC and AML), the provision of personal data is mandatory.
If the relevant personal data is not provided to us, then we will not be able to provide you with the full range of our services, meaning that our services may only be offered with a limited scope or not at all. All other provision of your personal data is optional.
COOKIES AND SIMILAR TECHNOLOGIES
Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page. Other tracking technologies, which are similar to cookies, are also employed and used by us. Other similar technologies can include pixel tags, google tags, and tracking URLs. All these tracking technologies shall be collectively referred to as the “Cookies”.
The types of Cookies that we use on our Services, and the purposes for which they are used, are set out below:
If you wish to disable Cookies (save for Strictly Necessary Cookies), you can opt to disable the same by choosing “No, I Disagree” when given the option, via the Cookies consent management tool on our Services or you may rely on your browser’s settings to disable all Cookies. You can choose “Yes, I Agree” to accepting all Cookies. You can also accept or decline certain Cookie categories (save for Strictly Necessary Cookies) via the Cookies consent management tool on our Services. Where you delete or disable Cookies, certain features of our Services may not be able to function.
To find out more about Cookies please visit: www.allaboutcookies.org or see www.youronlinechoices.eu which contains further information about behavioral advertising and online privacy.
SECURITY
We take the security of your personal data very seriously. We have implemented a number of security measures to protect your personal data from unauthorized access, use, disclosure, alteration, or destruction. These measures include:
We regularly review and update our security measures to ensure that they are effective in protecting your personal data. If we know or have reason to believe that your personal data has been compromised, we will immediately notify you and take steps to mitigate the impact of the breach.
FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We only keep your personal data for as long as is necessary to fulfil the purposes for which it has been collected. When determining the appropriate retention period, we consider factors such as the risks of the processing, our contractual, legal and regulatory obligations, internal data retention policies, and our legitimate business interests as described in this Privacy Policy.
Where we process data for: (i) registration purposes, (ii) support purposes, or (iii) in order to customize your experience on our Services, we keep this personal data for the duration of the period where you are a user and for an additional five-year period from when you cease to be a user, for anti-money laundry (AML) & compliance purposes, unless a longer retention period is required by applicable laws.
Where we process personal data for marketing/research purposes we will do so unless we receive a request from you to cease such action. We will hold a record of such personal data for five years from when you request us to cease such action.
Where we process personal data for the security of the Services, we hold this personal data for a maximum period of one year.
WHO DO WE SHARE YOUR PERSONAL DATA WITH?
By virtue of acknowledging, agreeing, and declaring to be bound by this Privacy Policy, you hereby consent to receive (i) marketing materials and offers related to the products and services provided by the Group, and (ii) research material, including market and/or product analysis/information, from the Group. If you wish to withdraw your consent, please contact us using the details in Annex 1 to this Privacy Policy.
Where we send direct marketing materials to you, we send your personal data to third parties with whom we have contracted to provide these materials to you on our behalf and in our name. These third parties may be located inside or outside of the European Economic Area (EEA).
We also share your personal data with:
We also disclose your personal data to:
For the avoidance of doubt, please note that Service Providers do not use/disclose your personal data for marketing purposes or for any other purposes. Personal data received by Service Providers are used by the same for the purposes of performing their designated functions.
WHERE IS YOUR PERSONAL DATA TRANSFERRED?
When we share your personal data with the parties listed above, it involves transferring your personal data outside of the European Economic Area (EEA) to countries where the level of protection of personal data has not been deemed adequate by the European Commission.
The locations of the companies which form part of the Group can be found here.
The locations of our third-party service providers can be found here.
Where information is transferred outside the European Economic Area (EEA) to a country that is not subject to an adequacy decision by the European Commission, personal data is adequately protected by the standard data protection clauses (as approved by the European Commission) or other appropriate transfer mechanisms (e.g., EU-US Privacy Shield, binding corporate rules).
WHAT ARE YOUR RIGHTS IN RELATION TO THE PERSONAL DATA WE PROCESS ABOUT YOU?
You have the following rights in relation to your personal data:
To exercise any of these rights, please contact us using the details in Annex 1 to this Privacy Policy.
We are entitled to decline your request to exercise your data subject rights if it is not permitted by applicable laws, if it is unreasonably repetitive, or if it would violate the rights of others.
Your request will be answered promptly and within 30 days unless we are legally entitled to an extension of time. If we are unable to grant your request, we will provide you with an explanation.
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 applicable laws to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the General Data Protection Regulation (GDPR) and Member State data protection laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.
If you have any concerns about how we handle your personal data, we encourage you to contact us using the details in Annex 1 to this Privacy Policy. Please also note that you have the right to lodge a complaint with your local data protection authority if you believe we have not addressed your concerns adequately.
AMENDMENTS TO THIS PRIVACY POLICY
This Privacy Policy was last updated in May 2024. We reserve the right to revise this Privacy Policy at any time by posting a revised version and, if we consider it necessary, we will notify you of changes.
HOW CAN YOU CONTACT US?
If you have any questions about this Privacy Policy or would like to make any requests as described in this Privacy Policy, please contact us using the details in Annex 1 to this Privacy Policy.
Annex 1
Personal Data Controllers
# |
Data Controller |
Address |
Jurisdiction |
DPO/Contact Details |
1 |
EFG Holding S.A.E. |
Building No. B129, Phase 3, Smart Village, Km 28 Cairo Alexandria Desert Road, 6 October 12577, Egypt |
Egypt |
Group Data Protection Officer EFGHermes_DataProtection@efg-hermes.com |
2 |
EFG Hermes International Securities Brokerage S.A.E. |
Building No. B129, Phase 3, Smart Village, Km 28 Cairo Alexandria Desert Road, 6 October 12577, Egypt |
Egypt |
|
3 |
EFG Hermes Promoting & Underwriting S.A.E. |
Building No. B129, Phase 3, Smart Village, Km 28 Cairo Alexandria Desert Road, 6 October 12577, Egypt |
Egypt |
|
4 |
EFG-Hermes UAE Limited |
Office 301, Level 3, The Exchange ,DIFC P.O. Box 30727 - DIFC, Dubai, UAE |
UAE |
|
5 |
EFG Hermes UAE LLC |
106, The offices 3, One Central, DWTC, P.O. Box 112736, Dubai, UAE |
UAE |
|
6 |
EFG Hermes KSA |
PO Box 300189 Third Floor, Sky Towers Northern Tower , Riyadh 11372 Kingdom of Saudi Arabia |
KSA |
|
7 |
OLT Investment International Company (B.S.C) |
Office #31, Level 5, MJ Tower 2, Bldg. 943 Block 436, Road 3620, Seef District, Manama, Bahrain |
Bahrain |
|
8 |
EFG-Hermes Pakistan Limited |
Office # 904, 9th Floor, Emerald Tower Plot No. G-19, Block-5, Clifton, Karachi, Pakistan. |
Pakistan
|
|
9 |
EFG Hermes IFA Financial Brokerage
|
Kuwait Stock Exchange Building 4th floor Safat, 13087 Kuwait
|
Kuwait |
|
10 |
EFG Hermes Kenya Limited |
8th Floor, Orbit Place, Westlands Road, P.O. BOX 349 00623, Nairobi | Kenya |
Kenya |
|
11 |
EFG Hermes Nigeria |
Postsquare building (7th floor) 1/3 Ologun Agbaje Street off Adeola Odeku |
Nigeria |
EFG Holding S.A.E. is regulated by the Financial Regulatory Authority.
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