Data Privacy Notice
Habib Bank Zurich plc (‘Bank’, ‘we’, ‘us’) respects your right to privacy. This Privacy Notice explains who we are, how we collect, share, and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies solely to personal information we collect when you interact with our services or visit our website at www.habibbank.com.
If you have any questions or concerns about our use of your personal information, please contact us using the details at the bottom of this Privacy Notice.
We recommend reading this Privacy Notice to ensure you are fully informed.
What We Do?
Habib Bank Zurich plc’s registered office is at Habib House, 42 Moorgate, London, EC2R 6JJ. We are a company registered in England and Wales under company number 08864609. We are a financial services company authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority, with financial services register No. 627671. We are also registered with the Information Commissioner’s Office (ICO) under registration number ZA134540 and act as the data controller when processing your data.
For more information, please refer to the ‘About Us’ section on our website at www.habibbank.com.
What Personal Information Do We Collect And why?
We collect and process your personal information to fulfill our legal, statutory, and contractual obligations and to provide you with our products and services. Depending on the products and services we offer, we collect the following personal information:
- Name
- Date of Birth
- Address
- Contact details (email, telephone number)
- Identification number (National Insurance number, tax identification number, passport number, driver’s license number)
- Information required for identity checks and credit history checks
- Copy of identification documents
- Criminal records for lending decisions, fraud prevention, and meeting legal obligations
- Information relating to financial circumstances and anti-money laundering compliance
- Current and previous countries of residence/citizenship
Type Of Personal Information
| Why We Collect It? |
1 – Administration Of Products & Services
| |
| To operate and administer our products and services, including dealing with your complaints and fixing our mistakes |
| We use your contact details, location data (for fraud prevention and, if consented, mobile location services), and IP address for security purposes. We may share this information with third-party service providers, such as subcontractors, payment processors, and regulators, to fulfill our contract with you and meet legal obligations. | |
2 – Administration Of Payments | |
| To administer payments to and from you |
| We collect payment details, location data for fraud prevention, and your IP address for security purposes. We may share this information with third-party payment providers to process payments to you. | |
3 – Credit And Client On-Boarding Decisions | |
| To make credit decisions and account on-boarding decisions about you (including new applications for credit or requests to increase credit limits) |
| For this purpose, we share information with credit reference and fraud prevention agencies. The information could then be used as follows: a) The credit reference or fraud prevention agency may add details of our search and your credit application to the records they hold about you, regardless of whether your application proceeds b) We, the credit reference and fraud prevention agency may link your financial records to those of anyone you are financially linked to – this means that each other’s information (including information already held by us or the credit reference agency) will be considered in all future credit applications by either or both of you, until one of you successfully files a ‘disassociation’ at the credit reference agencies c) We may add details of how your agreements or accounts operate with us to the credit reference or fraud prevention agency’s records, including any defaults, failures to adhere to the terms of your agreement, and any failure to notify us of a change of address when a payment is overdue d) The credit reference or fraud prevention agency may share any of that information with other companies unrelated to us for credit checking and fraud prevention purposes, as outlined above e) The credit reference or fraud prevention agency will also use the information for statistical analysis regarding credit, insurance, and fraud on an anonymous basis We use your information in this manner because it is necessary to fulfil our contract to provide credit-related products and services to you, and to meet our legal obligations. When credit reference agencies receive a search from us, they will place a search footprint on your credit file that may be visible to other lenders and companies unrelated to us (for example, other banks and credit providers). Further information on how your information is used by credit reference agencies and fraud prevention agencies can be found at Experian | |
4 – Legal Obligations | |
| To comply with our legal obligations, to prevent financial crimes including fraud and money laundering |
| We will provide information to, and receive information from, third parties where necessary to meet our legal obligations. This includes credit reference agencies, fraud prevention agencies, the police, other law enforcement and government agencies, other banks, and regulators. Fraud prevention agencies may use your information as outlined in Section 3 above. | |
5 – Financial Management And Debt Recovery | |
| For financial management and debt recovery purposes |
| We will give information to, and receive information from, third-parties where it is necessary to recover debts due by you to us, for example, other banks, debt recovery agents, credit reference agencies and sheriff officer or bailiff services. This might include passing personal information about you to a third-party who we have transferred your debt to, and who will then contact you directly to collect that debt. If your debt is transferred to a third-party you will be advised of the identity of that third-party. We use your information in this way because it is necessary to perform our contract with you, to exercise our legal rights, and because it is fair and reasonable for us to do so. | |
6 – Third-Party Introducers | |
| To enable payments to third-parties who may have introduced you to us |
| We use your information in this way because it is in our interests to do so to provide you with the products and services that best suit you We give this information to, and receive information from, third-party independent financial advisers and mortgage brokers who have introduced you to us | |
7 – Marketing | |
| To market products and services to you from us |
8 – Business Customers – Personal Information Requirements | |
For business customers, we will use personal information about key individuals in the business, so we can operate and administer the products and services which we provide to the business – to do this we will use:
Personal information on key individuals is obtained directly from the key individual, from the business to which the key individual is linked with, from the key individual’s dealings with any member of our Group, and from fraud prevention and credit reference agencies. Such information may include special categories of personal information, such as information relating to health or criminal convictions. | |
How Do We Collect Your Personal Information?
Data You Give Us:
- When you apply for our products and services
- When you fill out an application on paper, on our website, or provide information through documents
- When you speak to us on the phone or visit us in branch
- When you use our website and mobile apps
- Through emails and letters
- During financial reviews and interviews
- In customer surveys
Data We Collect When You Use Our Products and Services or Those of Other Members of Our Group:
- The amount, frequency, type, location, origin, and recipients of transactions
- Payment and transaction data
- The profile you create to identify yourself when you connect to our internet, mobile, and telephone services
Data from Third Parties We Work With:
- Credit reference agencies
- Fraud prevention agencies
- Public information sources (e.g., companies house, search engines)
- Government and law enforcement agencies
- Individuals who know you, including joint account holders and those you are financially linked to
We may also collect personal information through call recordings or CCTV monitoring. Calls are recorded for regulatory purposes, training, quality assurance, staff and customer safety, and resolving queries. CCTV is used on our premises for security and safety.
Information We Collect Automatically
We may also collect certain information automatically from your device. In some countries, including those in the European Economic Area, this may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include your IP address, device type, unique device identification numbers, browser type, broad geographic location (e.g., country or city-level), and other technical information. We may also collect details about how your device has interacted with our website, including the pages accessed and links clicked.
This information helps us understand our website visitors, their origin, and the content they find most relevant. We use this data for internal analysis and to improve the quality and relevance of our website. Some of this information may be collected using cookies and similar tracking technologies, as outlined in our Cookie Notice.
In general, we will use the personal information we collect only for the purposes described in this Privacy Notice or for purposes we explain at the time we collect your personal information. However, we may also use it for other purposes permitted by applicable data protection laws, such as archiving, research, or statistical analysis.
Who Do We Share Your Personal Information With?
We may disclose your personal information to the following categories of recipients:
- Our group companies, third-party service providers, and partners who process data for us (e.g., to support website delivery, enhance security, or provide functionality)
- Group companies, including our parent in Switzerland, and subsidiaries in Canada, Hong Kong, South Africa, Kenya, Pakistan, and the UAE
- Property surveyors, lawyers, audit firms, debt collection agencies, credit reference agencies, and fraud prevention agencies
- Competent law enforcement bodies, regulatory agencies, courts, or other third parties when required by law, to protect our legal rights, or to protect your vital interests
- A potential buyer (and its agents and advisers) in connection with a proposed business transaction, ensuring that they use your information only for purposes disclosed in this Privacy Notice
- Any other third party with your consent
Legal Basis for Processing Personal Information
Our legal basis for collecting and using personal information will depend on the specific context. Generally, we collect personal information when:
- We have your consent
- We need the information to comply with legal obligations
- It is necessary for performing a contract with you
- The processing is in our legitimate interests and not overridden by your data protection interests or rights
Legitimate interests include providing services, undertaking anti-fraud checks, improving services, fulfilling legal or accounting obligations, and marketing our products. In some cases, we may be legally required to collect personal information to protect your vital interests, such as in medical emergencies.
Special Protection For Sensitive Data
We will only use sensitive personal information (e.g., health status, racial origin, political beliefs) in specific circumstances, such as:
- Legal obligations
- Protection of vital interests (e.g., health emergencies)
- Substantial public interest or crime prevention
- Explicit consent from you
Cookies And Similar Tracking Technology
We use cookies and similar tracking technologies to collect and process your personal information. For more details on the types of cookies we use, their purpose, and how to manage them, please refer to our Cookie Notice on the website.
How Do We Keep Your Personal Information Secure?
We implement appropriate technical and organisational measures to protect your personal information. These measures aim to ensure a level of security that matches the risk associated with processing your data, including strong access controls and encryption of data in transit.
International Data Transfers
Your personal information may be transferred to and processed in countries outside of your residence. These countries may have different data protection laws.
Our website servers are located in Switzerland, and our group companies and third-party service providers operate globally. We have implemented safeguards, such as EU model clauses, to ensure that your personal information is protected in line with European data protection laws.
Data Retention
We retain personal information as long as we have a legitimate business need to do so, such as to provide services or comply with legal obligations. Once we no longer have a business need, we will either delete, anonymise, or securely store your data until it can be deleted.
Automated Decision-Making
In certain cases, we may make automated decisions about you based on your personal information (e.g., when processing online applications for fixed-rate bonds). These decisions may significantly affect you, but we ensure safeguards are in place, including manual reviews.
You have the right to contest an automated decision and request a human review. Please contact us for more information.
Your Data Protection Rights
You have the following rights regarding your personal information:
- Access, correction, update, or deletion of your data
- Objection to processing, restriction of processing, or request for data portability
- Opt-out of marketing communications at any time, by following the opt-out instructions in emails or by contacting us directly
- Withdraw consent where applicable, without affecting prior processing based on consent
If you wish to exercise any of your data protection rights, please contact us.
You also have the right to file a complaint with a data protection authority regarding our collection and use of your personal information.
Updates to This Privacy Notice
We may update this Privacy Notice in response to legal, technical, or business developments. Any updates will be communicated appropriately.
How to Contact Us?
If you have any questions or concerns about the use of your personal information, please contact us at: dp.uk@habibbank.com.
