OLT PRIVACY POLICY

This Privacy Policy (the “Privacy Policy”) tells you how we, OLT Investment International, collect, use, and share ( Process) your personal data when you use our website, mobile and PC applications 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.

This Policy also describes how we transfer and process your personal data in accordance with a Service Level Agreement between OLT and our parent company, EFG Holding S.A.E (“EFG Holding”).  

 

Who are we? 

The controllers of your personal data are listed in the Annex to this privacy policy.

These controllers are referred to as ‘we’, ‘our’ and ‘us’ in this Policy. We are committed to protecting your privacy and personal data in accordance with the Bahrain Personal Data Protection Law (No. 30, 2018) and its Executive Decisions. We take seriously our responsibility to hold your personal data securely and confidentially. 

 

What personal data do we process about you?

 

• Name
• Account details and related contact information
• Postal and physical address
• Telephone or fax number
• Email address and other identifying addresses for electronic communications
• Date of birth
• GPS Location to allow us to personalize your experience based on your location
• Camera Selfie will be captured to verify your identity and help prevent fraud
• Gallery Access to allow you to easily upload other required documents during registration
• Employment details, source of funds and net worth ,
• Details from passports and other government or state issued forms of personal identification
• Telephonic or electronic recordings
• Browser and device information
• App usage data (features used, time spent in app)
• Information collected through cookies, pixel tags, google tags and other technologies
• Demographic information
• Survey responses and similar information which reveals views and preferences

 

We and our third-party service providers collect the above information in a variety of ways. This includes from you directly and:

 

• Through your browser and/ or your electronic device: Certain information/personal data is collected by most browsers or automatically through devices, including, but not limited to, your Media Access Control (MAC) address, your computer type (Windows or Mac), your screen resolution, your operating system name and version, your device manufacturer and model, the language selected on your browser or device, your internet browser type, the version and the name of the services/applications you use. We also collect your IP address, which is automatically assigned to a computer by an Internet Service Provider. An IP address will be identified and logged automatically in our server log files whenever you access any of our Services, along with the time of the visit and the page(s) that were visited. We use IP addresses for the purposes of, among other purposes, calculating usage levels, diagnosing server problems, and for administrative purposes. We also derive approximate location from IP addresses for the foregoing purposes, and in order to analyze the location from which you are using our Services
• Via e-mail: If you correspond with us via e-mail, we retain a copy of such correspondence for internal purposes. Information collected via e-mail is also used to provide a record of communications between you and us, in order to comply with any applicable legal and/or regulatory requirements;
• By way of using cookies and similar tracking technologies: Please refer to the ‘Cookies and Similar Technologies’ section; and
• From third parties: Please refer to the ‘Do We Collect Personal Data About You From Third Parties?’ section

 

Do we collect personal data about you from third parties?

We also collect your personal data from third parties:

 

• Entities within the Company’s group (the “Group”), whose identities can be found in the link which appears in the 'Who Do We Share Your Personal Data With?' section below; and
  

• Publicly accessible sources, including publicly available online profiles and databases, for the purposes of establishing and verifying your identity, to derive your contact details in order to supplement the contact information we have about you, and to liaise with you in relation to our products and services using third party cookies and similar tracking technologies, as is set out under the ‘Cookies And Similar Technologies’ section.

 

How do we use your personal data?

 

We collect and use your personal data for the following purposes:

 

to execute a contractual arrangement with you or to take steps linked to executing a contractual arrangement with you;

 

subject to the execution of a contractual arrangement with you, and subject to the terms and conditions of that contractual arrangement, to establish an account for you on our Services;

 

to pursue our legitimate interests which do not override your interests or fundamental rights and freedom, such as:

• operating and administering our Services;
• providing our products and services to you and/or our clients and to communicate with you and/or our clients about such products and services;
• improving and developing products and services we provide;
• providing information to you about our and/or our Group’s services and products and/or any additional products and services that we think may be of interest to you and/or our clients. This information may be provided to you in the form of a digital advertisement and campaigns or via e-mail or via Short Message Service (SMS);
• identifying which products or services we think you are interested in by using cookies or similar tracking technologies on our Services which track and analyse how you use our Services;
• keeping a record of your communication with us;
• administrative, assessment, and analysis purposes;
• verifying your identity;
• monitoring and analyzing the use of our products, services, and Services for system administration, operation, testing and support purposes;
• managing our information technology and ensuring the security of our Services and systems;
• establishing, exercising, and/or defending legal claims or rights, and/or assisting our clients or others with the foregoing;
• investigating and responding to complaints or incidents relating to us or our business, maintaining the Services’ quality, and training our staff to deal with complaints and disputes;
• in relation to any proposed merger or acquisition of any part of our business,
• verifying compliance with and enforcing our terms and conditions or other contractual terms; and

 

 

to comply with applicable laws prevailing the Kingdom of Bahrain or in any other jurisdiction where we (or any of our affiliates) may operate; and

 

to serve the purposes which are set out under the ‘Cookies and Similar Technologies’ section. For the avoidance of doubt, we obtain your consent for the use of non-essential cookies, and you have the right to withdraw your consent at any time. By not providing your consent or withdrawing your consent, certain aspects or features of our Services may not be available to you. The withdrawal of your consent does not affect the lawfulness of processing your personal data which was collected based on your original consent prior to the withdrawal thereof.

 

In order for us to provide you with certain services, including but not limited to brokerage 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 information is mandatory.

 

If the relevant 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 information 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 are also used which are similar to cookies.  This can include pixel tags and tracking URLs. All these technologies are together referred to in this Policy as “Cookies”.

 

The types of Cookies that we use on our website, and the purposes for which they are used, are set out below:

 

• Strictly necessary cookies: These cookies are essential in order to enable you to move around our website and use its features, such as accessing secure areas of our website. Without these cookies, any services on our Site you wish to access cannot be provided.

 

• Analytical/performance cookies:These cookies collect information about how you and other visitors use our website, for instance which pages you go to most often, and if you get error messages from web pages. We use data from these cookies to help test designs and to ensure a consistent look and feel is maintained on your visit to the website. All information these cookies collect is aggregated. It is only used to improve how a website works. We use Google Analytics, for example, to anonymously track website usage and activity.

 

• Functionality cookies: These cookies allow our website to remember choices you make (such as your username, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They are also used to provide services you have asked for such as watching a video or commenting. Additionally, these Cookies can be used to allow an optional service to function. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

 

• Targeting cookies: These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

 

• Social media cookies: These cookies allow you to share what you’ve been doing on our website on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.

 

• Pixel tags: Also known as a clear GIF or web beacon. These are invisible tags placed on certain pages of our website but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, registering when a particular device visits a particular page. They are used to, among other things, track the actions of users of our services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of our services and response rates. If you turn off cookies, the pixel tag will simply detect an anonymous website visit.

 

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:

 

• Preventative Measures: We use these measures to proactively prevent threats from reaching your personal data. This includes using advanced security software, firewalls, data encryption, and regular security assessments;
• Detective Measures: We use these measures to focus on identifying and responding to security incidents if they occur. This includes continuous system monitoring, brand protection measures, and incident response plans; and
• Physical Security Measures: We use these measures to protect the physical infrastructure that houses your personal data. This includes restricted access, environmental controls, and security cameras.

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 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 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 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 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 OLT, and (ii) research material, including market and/or product analysis/information. If you wish to withdraw your consent, please contact us using the details in Annex  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 Kingdom of Bahrain and the European Economic Area (EEA).

 

 

We also share your personal data with:

 

service providers, who provide a service to us or you, including those listed here (the “Service Providers”);

 

the Service Providers’ service providers, delegates, and agents; and entities within EFG Holding Group for the following purposes:

 

to enable you to receive the services provided by our affiliate entities which may cover different financial services or be in different jurisdictions to those that we cover;

to allow us to improve the services that we provide across the EFG Holding; and

to allow us to produce analytical reports reflecting the services provided throughout the EFG group.

We also disclose your personal data to:

• regulators, exchanges, auditors, courts, the police, or other law enforcement agencies where we are legally obliged to do so;
• to other persons where disclosure is required by law or to enable products and services to be provided to you or our clients; and
• our professional service providers (e.g., legal advisors, accountants, auditors, insurers and tax advisors) where relevant.

If it becomes relevant, we will share your personal data with a potential buyer and their advisers in connection with any proposed purchase, merger or acquisition of any part of our business.

 

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 Bahrain and/or the European Economic Area (EEA), to countries where the level of protection of personal data might not be deemed adequate by the European Commission and/or competent Bahraini Data Protection Authority. In particular, your personal data may be transferred to EFG Holding or, subject to the terms of this Policy, to our outsourced service providers located overseas. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organization, contractual or other lawful means.

 

The location of EFG Holding is Egypt.

The locations of our third-party service providers can be found here.

 

In our sole discretion we, or SAXO or EFG Holding may appoint third party sub-processors. Where a third-party sub-processor is so appointed, e.g., by way of a cloud computing agreement, we shall, with respect to such data protection obligations:

 

• ensure that the third party is subject to, and contractually bound by, at least the same obligations as the process and/or the sub-processor (as applicable); and
• the processor and/or the sub-processor (as applicable) will remain fully liable to the processor and/or us (as applicable) for all acts and omissions of the third party.

We only permit your personal data to be processed by persons who are bound by enforceable obligations of confidentiality, and we take steps to ensure such persons only act on the sub-processor’s instructions in relation to the processing.

 

 

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:

 

Right of access: You have the right to access your personal data and to be informed of how it is being processed;

Right to rectification: You have the right to have your personal data rectified if it is inaccurate or incomplete;

Right to erasure: You have the right to have your personal data erased in certain circumstances, such as if it is no longer necessary for the purpose for which it was collected or if you withdraw your consent to processing;

Right to restriction of processing: You have the right to restrict the processing of your personal data in certain circumstances, such as if you contest the accuracy of the personal data or if you object to processing;

Right to object to processing: You have the right to object to the processing of your personal data for certain purposes, such as direct marketing; and

Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to have it transmitted to another controller.

 

To exercise any of these rights, please contact us using the details in Annex 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 PDPL. 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  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 Policy

This Policy was last updated in June 2024. We reserve the right to revise this Policy at any time by posting a revised Policy and, if we consider it necessary, we will notify you of changes. 

 

How can you contact us?
If you have any questions about this Policy or would like to make any requests as described in this Policy, please contact us using the details in the Annex to this Policy.

 

Annex

Personal Data Controllers

 

Name	address	DPO/Contact details
OLT	MJ Tower, Office 51, 3rd Floor , Building 870, Block 436, Road 3618, Seef District, Manama, Bahrain	Group Data Protection Officer privacy@oltinvestment.com