Data Privacy Statement
Bahrain Mumtalakat Holding Co. B.S.C.(c) (“Mumtalakat”, “we”, “us”, and “our”) has created this privacy statement to demonstrate its commitment to data privacy. Your right to data privacy and data security is a primary concern.
This privacy statement sets out the basis on which any information we collect from you, or that is provided about you to us, will be processed by us and the ways in which we process your personal data and your rights in relation to such data processing.
We intend to give you as much control as reasonably possible over your personal data (i.e., information that can be used to identify you, such as your name, email address, telephone numbers, postal address, etc. or which relates to you).
Information Gathering and Usage
Why personal data is collected and used?
There are times when we may need to collect and process personal data from you in order to manage our relationship with you. Set out below is a list of the purposes for which we could use your personal data:
- Operating our website: When you use our website, we collect online identifying information through the use of cookies and analytics tools to allow us to improve our website. This may include information on your usage of our website (e.g. user movement including time spent on each page, etc.) to help us identify usability issues and improvements, and information on your device to ensure we make available the best version of the site suited to your device.
- Managing and promoting events: We may collect information from you when we and/or our subsidiaries organize events to which you are invited, to enable us to better service your needs during your attendance at such events. We may take photographs at our events and it is possible that such photographs will include your image. We take such photographs for use in marketing and informational materials and we may upload these photographs to our website and/or as part of press releases, media campaigns or social media posts.
- Assisting our guests and visitors, monitoring attendance, and surveillance: If you are invited to our offices, or other business trip that we may help organise, we may collect some of your personal information, including your name and a copy of your passport or other identification, to assist you, if needed, in obtaining a visa to Bahrain or the country to which you need to travel to. We may also collect some of your personal information to be able to provide you with access to our premises and an office space during your visit. We maintain a logbook of all visitors that come to our premises and may register some of your personal information therein. We also have CCTV cameras installed in our offices and such footage is processed for the safety of all our visitors, employees, property, and to support any incident investigation.
- Exchanges with you regarding investment opportunities: We may collect information about you, including your contact details, to exchange with you or contact you in relation to investment opportunities, especially if you act as an asset manager, or work for a company in which we may invest or with which we are considering having a business relationship.
- Managing our relationships with our service providers: If you work for one of our actual, past or potential service providers, we may record your contact details, to be able to exchange with you about the services provided by your company and more generally to manage our contract/relationship with your company, as well as for business continuity purposes.
- Complying with our due diligence requirements: We may conduct verifications, including due diligence/ background checks, about some of our contacts, in order to comply with our internal requirements or the requirements of authorities or other companies with whom we interact. In that context, we may need to obtain from you information which allows for your identification and/or which relates to your past activities and/or other certificates.
- Employment considerations: We may collect and process personal data from you for employment and hiring purposes at Mumtalakat or any of Mumtalakat’s portfolio companies, which may include, but is not limited to, your personal details, the submission of CVs and related documents. We may share your personal data with such Mumtalakat portfolio companies for their consideration of your employment and with recruitment agencies to support with the hiring process.
- Compliance with legal or regulatory obligations: We collect information in relation to compliance with our legal and regulatory reporting obligations. This may notably include, if you work or own shares in a company with which we are considering having a business relationship, verifications for anti-money laundering and/or sanctions compliance.
Failure to provide your personal data may mean that we may not be able to communicate with you or have a business relationship with you.
We do not perform any regular automated decision-making activities, including profiling activities, where your personal data is processed by automated means, except as described above in relation to the use of cookies.
We will only process your personal data for the above stated purposes if and to the extent the applicable law provides a lawful basis for us to do so and in particular:
- if you have consented to us doing so;
- if we need it to perform the contract we have entered into with you;
- if we need it to comply with a legal obligation; or
if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests include furthering the business of Mumtalakat, exchanges regarding business opportunities or our relationship, administrative or operational processes within Mumtalakat, or promotion of our activities and/or events.
With whom may personal data be shared?
We may share the personal data that you provide us to our service providers, when they assist us with the activities for which we process your personal data. This may include the provision of your personal data to IT service providers, law firms, professional advisors, recruitment agencies, and other service providers we may deal with from time to time. We may also provide your personal data to any successor, or potential successor, to all or part of our business (or otherwise as necessary in connection with an investment or transaction related to our business) or our subsidiaries and portfolio companies, as necessary. We may also have reporting obligations and other legal and/or regulatory requirements that may require us to disclose your personal data to regulators and governmental authorities.
Links to third-party websites
Our website may contain links to other third-party websites. However, once you have used these links to leave our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this privacy statement. You should exercise caution and consider the privacy statement applicable to the third-party website in question.
Your Rights
We rely on you to provide accurate, complete, and current personal data to us.
- Access. You may contact us at any time to request access to the personal information we hold about you. We will confirm whether we are processing your personal data, and provide you with details about this processing, including the source from which we obtained the data, recipients of the data, categories of personal data concerned and the reasons for our processing.
- Rectification. You can ask us to correct or complete your personal data by contacting us at any time. To the extent practicable, we will inform anyone who has received your personal data of any corrections we make to it.
- Erasure or Blocking. You may ask to have your personal data deleted, removed, or blocked. We will try to do so promptly, and, to the extent practicable, we will inform anyone who has received your personal data of your request. However, we must keep track of certain information for legal compliance and back-up or archiving purposes, so we may not be able to fully delete your information where the law and/or our internal policies require so.
Object. If you believe that the processing of your personal data may cause material or moral damages to you or others, you may send us a request to object to the processing of your personal data.
For any of the requests listed above, please contact us. We will make reasonable efforts to respond promptly and at the latest within the deadlines imposed by applicable laws and regulations. Our response to such requests may be limited to information under our direct control.
Security Measures
We limit access to personal data that we collect about you to our employees and third-party service providers, who we reasonably believe need to have access to your information. We have security measures in place to help protect against the loss, misuse and alteration of your information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we ensure that our systems adhere to market security standard so as to help safeguard against such occurrences.
Contact Details
If you would like to get in touch with us with regards to your personal data, please contact us at:
Bahrain Mumtalakat Holding Co. B.S.C.(c)
Office 401 Building 551
Road 4612 Manama/Sea Front 346
Kingdom of Bahrain
or by email at: legalaffairs@mumtalakat.bh
Changes in this Privacy Statement
We reserve the right to modify and update this privacy statement from time to time and posting the same on Mumtalakat’s website will be considered as notice of such modification or update. We will indicate at the top of this privacy statement when it was last updated.