INTRODUCTION

BLC Bank S.A.L (hereafter “us”, “we”, or “our”) website & electronic banking channels use cookies to enhance your online experience. Our cookies disclaimer is a document that provides information about what cookies are, types of cookies used, how we use them, what user data we track, and for what purpose.

For further information on how we use, store and keep your personal data secure, check our Privacy Notice.

WHAT IS A COOKIE?

When you visit our website & electronic banking channels, a small text file, a cookie is downloaded on your computer or on other device used for browsing (tablet, smart phone, and portable smart device …etc.)

Other technologies might also be used for the same purpose as cookies e.g. web beacons, pixel tags ...etc. This disclaimer also covers such technologies and refers to them as “cookie”.

Cookies play an important part of the web experience today; they are used to keep you logged in to the site, remember your preferences and to track your browsing activity across the web in order to improve your experience.

WHAT DO WE USE COOKIES FOR?

WHICH COOKIES DO WE USE?

WHO HAS ACCESS TO YOUR INFORMATION?

It is important to note that your personal data is held solely by us and is not shared over the website or with any third-party.

We do not and never will use cookies that hold unencrypted personal information allowing a third party to identify or contact you.

SOCIAL MEDIA THIRD PARTY COOKIES

To enrich our website & electronic banking channels content, we include links to third party or other social media websites such as Facebook, Twitter, YouTube, Instagram, LinkedIn, and Pinterest. As a result, when you visit a page with content embedded, you may be presented with cookies from these websites. BLC Bank has no control or liability over these cookies set, so you should check the relevant third party's cookie policy for more information.

HOW TO REFUSE/DELETE COOKIES

Web browsers are generally setup to accept cookies. Nonetheless, you can setup your browser to reject cookies or to alert you when a cookie is placed on your computer. You should know that blocking cookies has a negative impact upon the usability of most websites including ours and will prevent you from accessing our internet banking solutions; the vast majority of cookies are completely harmless and only exist to improve your online experience.

To manage your cookies settings according to your preferences, please refer to your browser’s help for detailed instructions.

CONTACT US

If you have any questions regarding this Cookies disclaimer, you may contact us using the information below:

INTRODUCTION

BLC Bank S.A.L (hereafter “BLC” “we” “us” “our”) is committed to protect and respect the privacy & rights of every Individual (hereafter “you”). We are dedicated to ensure the confidentiality and privacy of data entrusted to us and seek to be transparent when we collect and use your personal data.

We will protect and use your personal data in the most appropriate way as indicated by this “Privacy Notice” and in accordance with the provisions of Law 81/2018 , BDL basic circular no # 146/2018, and EU General Data Protection Regulation 679/2016 (“GDPR”).

We comply also with the Lebanese banking secrecy Law and therefore, maintain confidentiality regarding our customer’s data, which have been entrusted or made accessible to us with respect to the business and /or contractual relationship.

In this Privacy Notice, we describe our policies and practices regarding your personal data and the way we process them; However and for further details you may refer to our Data Protection Policy.

DEFINITIONS

This section aims to provide definitions for terms/expressions that have particular meaning:

WHAT PERSONAL DATA WE PROCESS

In order to address your request, we have to collect and process data about you. The type of personal data we process depends on the services and products requested or agreed upon in each case.

We will ask you to provide us with personal data, when you intend to enter into a business and/or contractual relationship with us, as well as during the course of this relationship. Moreover, during the course of our relationship, you must disclose any changes to your personal data without undue delay.

SOURCES OF PERSONAL DATA

We lawfully obtain data from:

WHY WE PROCESS YOUR PERSONAL DATA AND ON WHAT LEGAL BASIS

We collect and further process your personal data in compliance with the applicable data protection legal framework, for the following reasons:

WHO RECEIVES YOUR PERSONAL DATA

RETENTION PERIOD

AUTOMATED DECISION MAKING (INCLUDING PROFILING)

We may process some of your data by automatic means, in order to evaluate certain personal aspects (profiling), in the following cases:

DIRECT MARKETING

We only use your personal data for direct marketing purposes if:

YOUR PERSONAL DATA RIGHTS

We respect the rights you have under the personal data legal framework, namely the following:

You can exercise any of your rights by referring to any of our branches or by contacting our Data Protection Officer using the details set out in paragraph 15.

It is important to note that the rights set out above are not unconditional and the specific circumstances of the processing being undertaken by BLC determines if these rights may be exercised. Further data concerning these rights and their application can be obtained from the Data Protection Officer.

DATA SECURITY

The Bank commits to take the appropriate and reasonable administrative and technical measures for the safety of the data and their protection from accidental or unlawful loss, misuse, forbidden transmission or access and of any other form of unlawful processing. Although we are fully committed to protect your personal data, security cannot be absolutely guaranteed against threats. In the event that we become aware of a data breach, which may cause you a disadvantage, we will notify you accordingly without undue delay.

Moreover you are responsible for protecting and maintaining protection of any identification, authentication and other security measures regarding our services and products (e.g. PIN numbers, usernames and passwords, mobile devices, card numbers and account numbers), as described in the relevant contracts and/or terms and conditions.

CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice may be updated from time to time and without prior notice, in order to reflect our current practices and/or in accordance with any changes in the applicable legal framework. You will always be able to find the most recent version on BLC website and application.

Any visit you make to the site or application where the notice is published subsequent to its update is considered as your approval to the updated version.

COOKIES

We may sometimes use cookies to enhance your experience when browsing the Bank’s website, or using its electronic banking applications. Please refer to our “Cookies Disclaimer” for more details with respect to the cookies that we use and their purpose.

LINKS TO SOCIAL MEDIA & OTHER WEBSITES

BLC website may contain links to third party websites as well as social media platforms e.g. Facebook, Instagram and LinkedIn. This Privacy Notice applies solely to the data collected by our website and nonetheless, we are not legally responsible for the personal data you might post on these other websites or social media platforms since they are subject to their own terms and conditions and privacy policy and BLC holds no responsibility whatsoever should the confidentiality of such data be breached.

Please make sure you carefully read the terms & conditions related to these websites/platforms before submitting your personal data.

CONTACT US

For any matters arising out of and/or in connection with this Privacy Statement, you can contact our Data Protection Officer (DPO) on the following address:
Email: [email protected]
Tel: 961 1 387000

INTRODUCTION

BLC is committed to conduct its activities in compliance with Banking Secrecy Law and Data Protection obligations. BLC is aiming to protect the Individuals’ personal data by enforcing a Data Protection Policy that provides the highest level of privacy and security regarding collection and use of data.

This policy describes how the Bank may collect, use, protect and disclose Individuals’ personal information. Personal information comprises all the details BLC holds or collects directly or indirectly about Individuals , their transactions, financial information, interactions or dealings with BLC, including information received from third parties and information collected through the use of BLC website and electronic banking services.

LEGAL & REGULATORY FRAMEWORK

The main legal basis establishing data protection requirements at BLC Bank is the provisions of national law no# 81/2018 , General Data Protection Regulation (GDPR), and BDL circular no # 146/2018 that intend to:

BLC will ensure that the data collected, are effectively protected in order to fulfill individuals’ reasonable expectations of privacy by complying with the applicable laws and regulations.

PURPOSE & SCOPE

The purpose of this policy is to set out the principles of data protection that BLC Bank shall follow and to provide a managed framework for fulfilling BLC Bank business needs, accountability and legal responsibilities.

This policy applies to the personal data of individuals, being current and former employees, representatives, shareholders, BOD members, prospective, current and former customers, authorized signatories, beneficial owners, guarantors, advisers, contractors, service providers, partners, payers, payees and security providers. It applies also to personal data gathered in respect of onboarding customers at the outset of any business relationship and after its conclusion.

This policy covers all personal data processed regardless of the mean on which that personal data is stored.

GENERAL DATA PROTECTION PRINCIPLES

BLC will be guided by data protection Principles relating to processing of personal data.

PROCESSING PERSONAL DATA

Personal data may or will be collected, stored, used processed, transferred or disclosed in or outside Lebanon for the following purposes:

PROCESSING SENSITIVE DATA

BLC will only process sensitive personal data where it is strictly necessary to be carried out for a specific purpose. BLC will take special care when processing sensitive personal data because it represents a greater intrusion in individual privacy than when processing non sensitive data, in particular in ensuring the necessity of the Processing and security of the Sensitive Personal Data.Access to a data subject personal Data is limited to authorized persons whose status, duties and responsibilities specifically require or justify access to such data.

REPORTING A PERSONAL DATA BREACH

BLC shall put in place a procedure to be followed by all employees to deal with any suspected personal data breaches. The suspicious case will be reported immediately to the DPO for further investigation and conclusion. A log of personal data breaches will be maintained and submitted periodically to Senior Management.

DISCLOSURE AND TRANSFER OF DATA

BLC may disclose and/or transfer a data subject’s Personal Data both inside and outside Lebanon for the purposes highlighted in this policy and allowed or required by applicable laws and regulations to the following:

DATA SUBJECTS’ RIGHTS AND REQUESTS

Data subjects have rights when it comes to how BLC handle their personal data. These include rights to:

THIRD PARTY AGREEMENTS

BLC must impose direct compliance obligations on data processors by including specific contractual requirements in any agreement with the data processor. BLC will consider the following requirements when dealing with a third party:

ROLES & RESPONSIBILITIES

Board of Directors

Senior Management

Data Protection Officer –DPO

The Head of Compliance is appointed as DPO who shall be entrusted with the duty to perform the following tasks:

Group / Departments Heads

Information Security Department

Legal Department

Audit Department