Hamdan is a reputed organisation providing diverse financial services. Working with some of the largest banks and non-banking financial companies, Hamdan has established one of the largest remittance networks in the industry. Hamdan Exchange LLC ("Hamdan") is the data controller (the person who determines, individually or jointly, the purposes for which and the way the personal data is to be processed) of Personal Data collected in Oman, its branches and digital channels. We are located at Regency Business Centre – 3, Grand Hamad Street, Address.
Hamdan respects your privacy and is committed to maintaining the confidentiality and security of the Personal Data of its existing, prospective and former customers and beneficiaries ("Data Subjects" or "you"). This Privacy Statement informs you about how we process Personal Data, how we look after it and tells you about your rights with respect to your Personal Data. Hamdan encourages you to review this Privacy Statement and become familiar with it.
3.1 What does Personal Data mean?
Personal Data is data which identifies an individual or which can be used in combination with other data to identify an individual, such as name, address, telephone number and e-mail address.
Hamdan collects Personal Data from Data Subjects mainly through its branches, websites, and third parties or publicly available sources. For more information on these sources of Personal Data, please refer to the sections below.
Where Hamdan needs to collect Personal Data by law or under the terms of a contract we have with you, and you fail to provide that Personal Data, Hamdan may not be able to fulfil
our contractual obligations (e.g. a money remittance) and we may have to cancel the services you requested.
3.2 Personal Data collected by Hamdan
To provide the services requested by Hamdan customers, Hamdan collects the following Personal Data through its network of branches and Online Money Transfer platforms (OMT):
o Full Name (sender and recipient of the transaction)
o Address (sender and recipient of the transaction)
o Nationality (sender and recipient of the transaction)
o Telephone, including mobile (sender and recipient of the transaction)
o Relationship between sender and recipient of the transaction
o E-mail
o Age
o Gender
o Birth Place
o Employer details
o Origin of the financial resources
o Financial background
o Identification document (e.g. National ID, ID, Passport with valid visa etc. as permitted by Oman regulation)
o Bank Statements
o Transaction amounts
o Bank account details
o Credit / Debit card numbers
o Marketing & other Contact Preferences
As a financial institution, Hamdan has certain obligations with regards to identity verification, fraud prevention and other similar security purposes. To ensure compliance with those obligations, certain of the Personal Data described above may be collected from, or verified against, third party sources such as government agencies and consumer reporting agencies. For identity verification purposes, senders and recipients of money transfers may be required to produce valid identification or consent to verification by other means before releasing funds.
3.3 Personal Data collected by Hamdan websites
At its websites, Hamdan collects aggregated user data (i.e. information that cannot be used to identify you), Personal Data that Data Subjects voluntarily provided, and Personal Data collected using cookies (as explained in the next section).
3.3.1 Definition and usage of cookies
A cookie is a small piece of information that is stored on your device (such as your computer) and which records the way that you use a website so that, when you revisit that website, Hamdan can provide tailored options based on the information that has been collected from your last visit. Cookies can also be used to analyse traffic and, in some cases, to provide you with tailored advertising and marketing.
Following are the broad categories of cookies used on Hamdan websites:
o Essential cookies: These cookies make Hamdan website operation work and therefore they cannot be turned off or rejected. These cookies do not gather any information about you and do not have the ability to remember how you have used our website.
o Performance cookies: Hamdan use these cookies to help analyse how its website is used and to improve its performance. For example, Hamdan use them to understand where visitors to the Hamdan site are based, how many people visit the website and which sections of the website are the most used;
o Functionality Cookies: These cookies allow Hamdan website to remember if you have previously visited the Hamdan site or the choices you made (e.g. language preferences) to provide a more personalised online experience.
o Third-Party cookies: These cookies collect information from your device and perform tasks that analyse behaviour and collect other information, such as demographics. These cookies may be used to provide you with personalised advertising.
3.3.2 Third Party Marketing Cookies and Social Advertising
Hamdan has relationships with online advertisers and social media networks. These partners use cookies and similar technologies for marketing purposes and may serve you with targeted advertising about Hamdan services while you are on their website or mobile applications.
3.4 Personal Data collected by Hamdan through Social Media
Hamdan may process anonymized data derived from Data Subjects' publicly available social media resources for statistical purposes. Although anonymized may be derived from your Personal Data, it is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. We may also process Personal Data derived from publicly available social media resources that Data Subjects make available when interacting with us including: Facebook, Twitter, YouTube, LinkedIn, Instagram, Google+, Pinterest, Weibo and WeChat. Such Personal Data may include but is not limited to:
o Public Social Media Profile Name
o E-mail
o Mobile number
o Region
o Hamdan related posts (e.g. Mentions and Hashtags)
o Complaints/queries.
Personal Data will be processed by Hamdan only if and to the extent that at least one of the
following applies:
Compliance with Legal Obligations
Hamdan may process Data Subjects Personal Data when necessary to comply with a legal obligation, e.g. Anti-Money Laundering screening and reporting requirements and where required to comply with court order or judicial proceedings.
Necessary to achieve legitimate purposes
Hamdan may process Data Subjects Personal Data in pursuance of its legitimate business purposes where such processing is necessary, and our interests are not overridden by the privacy rights of the Data Subjects. E.g., our legitimate business interests may include communication with our customers in relation to requested transactions, pursuit of customer care initiatives, internal record keeping purposes and fraud prevention.
Consent
In certain scenarios, Hamdan may rely on Data Subjects consent to process their Personal Data for a specific purpose. For example, Hamdan follows an implied consent methodology when you have a continued relationship with us (soft opt-in), but we provide an opportunity to object to sending direct e-marketing materials in every communication.
Contract
Hamdan may process Personal Data as required to ensure we comply with our contractual obligations towards Data Subjects.
Hamdan generally uses Personal Data from Data Subjects for the purpose of providing a service. This may include the following:
o Authorising and processing Data Subjects' transactions, including effecting and administering money transfers and ensuring proper payment to the designated recipient of funds.
o Monitoring and improving our services including websites/mobile apps and its content.
o Sending information to Data Subjects about Hamdan products and services.
o Customer care initiatives to improve Hamdan services.
o Meeting legal, regulatory, self-regulatory, risk management, fraud prevention and security requirements, which may include (among other measures) verifying the identity of the sender and recipient of funds and checking identities against money laundering, terrorist financing or similar watch lists established by regulatory agencies or similar bodies. For identity verification purposes, senders and recipients of money transfers may be required to produce valid identification or consent to verification by other means before releasing funds.
o Maintaining business and transaction records for reasonable periods, and generally managing and administering Hamdan business.
o Meeting insurance, audit and processing requirements.
o Otherwise as permitted or required by law.
In order to carry out the processing activities established in this Privacy Statement, Hamdan may disclose Personal Data relating to its Data Subjects to:
o Data Processors: Hamdan may share Personal Data with third-party service providers ("Data Processors"), including affiliates of Hamdan performing services on Hamdan behalf, for example: information technology, data hosting, marketing, customer care, fraud prevention, etc. subject to relevant regulation. Hamdan takes steps to ensure that Personal Data that is processed by Data Processors is protected and not used or disclosed for purposes other than as directed by Hamdan.
o Third Party Data Controllers and Joint Controllers: Hamdan may share Personal Data with third parties acting independently from Hamdan as may be required in connection with the services provided to Data Subjects, for example: any intermediary banks or other financial institutions involved in the transaction of Hamdan services.
o Successors: if Hamdan is purchased by/sold to a third party, Personal Data held by Hamdan will be transferred to the successor entity.
o Relevant Authorities: Hamdan may disclose Data Subjects' Personal Data as necessary to meet legal and regulatory requirements. This may include disclosure of Personal Data to government authorities, for example, in compliance with suspicious activity reporting requirements under anti-terrorism, anti-money laundering and similar laws and regulations.
In connection with providing services to its customers, Hamdan may transfer Personal Data to destinations outside Oman in accordance with our legitimate business purposes and where permitted under law. When transferring Personal Data outside Oman, Hamdan ensures that security measures and appropriate safeguards are put in place to protect the Personal Data and to ensure that all transfers comply with applicable data protection law.
Data Subjects have certain rights with respect to their Personal Data. In summary, these are:
o To be informed: Data Subjects have the right to receive certain information about how their Personal Data is processed. Therefore, we are providing you with this Privacy Statement.
o Access: Data Subjects have the right to access and receive a copy of their Personal Data.
Data Subjects are also entitled to lodge a complaint with the Data Protection regulatory authority, the Ministry of Transport and Communications (MoTC). We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so please contact us in the first instance. For more information on your rights, please contact us using the details below.
If you wish to exercise any of your rights, or if you have any queries or suggestions about this Privacy Statement, you can contact Hamdan and our Data Protection Officer at: [email protected]
Hamdan employs a strict policy against sending unsolicited communications. Please note that Hamdan will continue to send administrative communications (i.e. Transaction Notifications) if you opt out from Marketing/Customer Care communications. Hamdan may also contact Data Subjects in response to their inquiries, to provide services at the Data Subjects request and to manage their requirements.
Hamdan employs a strict policy against sending unsolicited communications. Please note that Hamdan will continue to send administrative communications (i.e. Transaction Notifications) if you opt out from Marketing/Customer Care communications. Hamdan may also contact Data Subjects in response to their inquiries, to provide services at the Data Subjects request and to manage their requirements.
Hamdan websites and emails may contain links to various other websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy Statement of every website you visit.
Hamdan takes all reasonable steps to ensure that all Personal Data collected through its branches and websites is treated securely and in accordance with this Privacy Statement and strict data protection standards.
In general, the period for which Hamdan retains Data Subjects Personal Data is aligned with Hamdans data retention obligations under anti-money laundering laws. In all cases, Hamdan only retains Personal Data for as long as is necessary for the purposes described in this Privacy Statement. When determining the appropriate retention periods, Hamdan will consider different factors, including: contractual obligations and rights; our legal obligations (for example, anti-money laundering laws); statute of limitations under applicable law; potential disputes; guidelines issued by relevant data protection authorities; and Hamdans legitimate business interests. Hamdan securely erases Personal Data once it is no longer needed.
Data Subjects may want to discontinue receiving marketing information from Hamdan. While this may mean that Data Subjects will not receive product or service information of interest to them, Hamdan respects Data Subject's wishes not to be informed directly of these promotions or product introductions.
You may inform Hamdan at any time that you want to opt-out of these communications by following the opt-out links on any marketing message sent to you or by contacting us.
Hamdan reviews and updates this Privacy Statement from time to time. We encourage Data Subjects to periodically review this Privacy Statement to make sure they are aware of the latest version. If we make any material changes, we will bring this to your attention.