Introduction

Beban W.L.L. (“Beban”, “we”, “us”, or “our”) is a Crowdfunding Platform licensed by the Central Bank of Bahrain as an Ancillary Service Provider. In our endeavors to ensure the safety of your personal and sensitive information. Beban ensures compliance with Bahrain’s Data Protection Law (30/2018).

This privacy policy statement serves to demonstrate the means through which all data processed by Beban is collected, used, stored and protected. The statement further identifies the extent to which your data will be processed and the third parties we may share your data with.

Note that accessing any electronic services or mobile applications provided or developed by us, the terms and conditions provided in this statement are considered agreed upon. These terms are to be updated periodically, therefore you may wish to refer to them before engaging in any offered services.

 

Definitions

To help you navigate this statement with ease, this section aims to clarify the definitions and some distinctions between certain phrases as well as make you aware of who handles your data.

 

Personal Data vs Sensitive Data

Personal Data refers to data that can be used to directly or indirectly to identify you. The most popular example of such data is an individual’s ID number. Other methods of identification involve considering a person’s certain attributes, these can be physical, physiological, intellectual, social, and even economic.

As for your Sensitive Data, this would refer to any information that would personal facts about you. It applies to data that can uncover a person’s gender, racial or ethnic origin, personal political opinions, religious and union affiliation, existing criminal record or any medical information or data related to a person’s marital status.

 

Processing

Where this document refers to processing, it refers to activities that include the data’s collection, organisation, classification, storage, modification, or amendment. Such activities can be within a single action or an array of actions. Further, the actions include the retrieval of the data for the purposes of publishing, broadcasting, transmitting, sharing, integrating, blocking, or deletion.

 

Who handles your data?

 

Data Manager

The data manager is involved in the decision-making of the purpose and means in which your personal data will be processed. In the event where the Applicable Law mandates the processing, he/she will be personally responsible for the processing.

 

Data Processor

For the purposes of this document, this refers to the individual who process the data for the Data Manager or on his/her behalf. This, however, does not include the individual who are under the supervision of the Data Manager or the Data Processor.

 

Data Privacy Officer

The individual handling all matters concerning the privacy of your personal data and ensuring that the organisation is in accordance with the guidelines in the relevant data protection laws. He/she is also involved with Beban’s external relations and communications.

 

The means through which Beban collects your personal information

Beban respects your privacy and believes that personal information should remain private. Therefore, our collection of personal data is kept to the minimum necessary level as required strictly to provide our services as per the guidelines set out by the applicable laws. All personal data that is collected from you is essential, the transaction would not operate without it.

The sources where Beban collects personal data from are:

• You, the User. Through various requested application forms, this is the best way for Beban to collect the required information;
• Beban’s website and mobile applications;
• Beban’s offices and their subsidiaries and/or affiliates. This is to ensure a widened oversight of your personal data;
• Correspondence between yourself and Beban;
• Governmental authorities and regulators such as the Central Bank of Bahrain, to the extent allowed by the Applicable Law;
• Events and marketing campaigns;
• Data processors, ancillary service providers, contractors, vendors and any other third parties;

Furthermore, to better understand our clients, our website makes note of your interactions such as what links you click on and what you access the most. This allows us to update what is displayed on our website and customize our services to the needs of our clients.

 

Information collected by Beban

The following non-exhaustive list states the type of data we collect in order to best provide our services in accordance with the Applicable Law.

Information we collect from Individuals:   Name Phone Number Address of Residence ID/CPR Number Passport Number Email Address Phone Number Date of Birth Employment and Salary Information Credit Information	Information we collect from Corporates Entities: Name Commercial Registration Number Registered Address Incorporation Information VAT Registration Number Shareholder Information Management Information Credit Information Turnover and Sales Net Profit Net Worth including Assets and Liabilities
Information collected in regards to investments made: Nature of Investments Investment amounts Investor’s banking information	Information collected from Website and Application Usage: Time Spent Links accessed
Information collected from cookies: IP Address Device Type Device identification number Browser type

 

How we store your data

Beban ensures the highest level of standards are applied in order to process, store and protect your information. Your personal information will be maintained within the Kingdom of Bahrain and shall only be transferred in compliance with the Bahrain Data Protection Law.

Beban will only retain your information for as long as necessary or required by law for business or regulatory purposes. The retention period of your information may depend on our contractual obligation, rules and regulations, business operations, financial records or any other reasons.

 

How we protect the data you trust us with

Any data stored anywhere is at risk of unauthorized access, amendment, disclosure, destruction as well as the risk of accidental loss. As the Data Manager of the Personal Data we have taken reasonable and appropriate measures to mitigate these risks which include data encryption, multi-factor authentication, and complex access processes whether on a network or application scope. All access to databases is strictly controlled and rigorously monitored.

In order to minimize in-transit risks, Beban limits all communication involving Personal Data to essential communication with key parties only. Communication of the latter nature are shared strictly when needed and even then, the Data is protected by confidentiality obligations.

However, the security of data cannot be wholly guaranteed as threats are constantly evolving and developing. Our duty is to take all reasonable steps to protect Personal Data.  Should any breaches occur, we undertake to report them immediately according to procedures proscribed by the Personal Data Protection Law and under the Rulebook of the Central Bank of Bahrain.

 

What the data is processed for

Your Personal Data is processed whenever we need to:

• Take measures to provide you with a requested service
• Maintain the contractual obligations between yourself and Beban
• Meet regulatory guidelines and reporting
• Prevent AML, CFT, and fraud
• Develop our services to better suit your needs
• Research and statistical analysis
• Communicating key campaigns, events and updates from Beban.
• Engage in auditory and quality controls activities

 

Beban retains the data for as long as it may require and makes sure to meet all regulatory concerns in that regard.

 

Who we share your Personal Data with

Your Personal Data will not be shared with third parties unless you explicitly request us to do so. However, two cases exist as exceptions: sharing data to comply with legal and regulatory requirements, and sharing data to satisfy Beban’s contractual obligations.

Such recipients of your data may include, but are not limited to:

• Government and regulatory authorities
• Law enforcement authorities (courts/police)
• Sharing within the Beban internal network
• Banks involved in corresponding transactions
• Service providers required by Beban such as consultants, auditors, and solicitors
• Data processors, ancillary service providers, contractors, agents, business partners and other vendors
• Customer service providers

 

Should the need arise to share your data with third parties outside of Bahrain, this will be done in compliance with the regulations and guidelines outlined by Data Protection Authority and the Central Bank of Bahrain.

 

Your Rights

This section provides an overview of the rights you may have under the Applicable Law.  This section is not intended to serve as legal advice. Please consult a lawyer or refer to the Personal Data Protection Law for more information.

 

The right to enquire:

You have the right to request information on how your Personal Data is handled by Beban and for what purposes.

 

The right to object:

You have the right to object to your Personal Data being processed if the processing causes substantial harm to yourself or other parties or if you have reasonable grounds to believe that the processing would result in such harm. However, the law grants Beban the right to process the Personal Data in spite of the objection under certain circumstances.

 

The right to demand rectification, blocking, or erasure:

If you suspect that Beban is processing your Personal Data in a manner that contradicts the Applicable Law, you may submit an application for Beban to rectify, block, or erase your data from our records.

 

The right to withdraw consent:

You may withdraw consent to use your Personal Data at any time. However, please note that this will only apply to the future use of your Personal Data and will not alter the past use of Personal Data. Furthermore, should you choose to withdraw consent, services provided to you by Beban may be subject to discontinuation.

 

The right to complain:

Should you suspect that Beban has violated the Personal Data Protection Law, you have the right to make a complaint detailing your concerns to the Bahrain Personal Data Protection Authority. Alternatively, you can contact us on support@beban.me.

 

We appreciate you taking the time to read the privacy policy, we recommend you visiting this page occasionally to see if we have updated our Privacy Policy.. If you would like a notification whenever an update is made please contact us on support@beban.me.