Abwab – Privacy Policy

Last updated: 2 September 2024

1. Introduction

This Privacy Policy ("Policy") sets out how Company ABOUAB AL-MATKAR For Artificial Intelligence and other companies within the Abwab Group (“Abwab”, "we", "us" or "our") treats your data when you:

1. register or visit our Site;  
2. engage with us to use the Services;
3. consent to the processing of your Information by any Abwab Group Company as part of the provision of the Services for a Client.

This Policy explains how we will use that Information, who we might share it with, and what steps we will take to make sure it stays private and secure.

This Policy continues to apply even if your agreement with Abwab for the Services or other products ends.

This Policy may be updated from time to time and our Site will indicate when the Policy has been updated. You may access the current version of this Policy at any time by clicking on the 'Privacy Policy' link at the footer on our Site. You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page. If we have provided you with separate or further information about how we collect and use your Personal Data for a particular product or service, those terms will also apply. If you interact with us in a different context, separate terms might apply to that interaction. Where we provide you with other terms, those terms will always take precedence over this Policy.

There may be times when links on our Site take you to a third party's website which is not managed or connected to Abwab. When this happens, that third party's own privacy policy, which may be different to this Policy, will apply.

2. Definitions and interpretation

In this Policy the following capitalised terms have the meaning assigned to them below unless expressly stated otherwise:

"Abwab Group" means Abwab and:

1. any company from time to time which directly or indirectly owns or controls the voting rights attached to not less than 50% of the issued ordinary share capital of Abwab, or controls directly or indirectly the appointment of a majority of the board of management of Abwab; and  
2. any company from time to time in which it directly or indirectly owns or controls the voting rights attached to not less than 50% of the issued ordinary share capital, or controls directly or indirectly the appointment of a majority of the board of management,

and references to "Abwab Group company" shall be construed accordingly.

"Banking Partner" means any bank or other financial institution with which Abwab has a relationship with regards the provision of the Services, including loan processing automation and origination services.

"Client" means the person, business, corporate entity or any other entity who engages or retains Abwab for the provision of the Services, including a Banking Partner.

"Cookies" means small blocks of data that are stored on the device (computer or mobile device) you use to access our Site.

"Distributor" means the intermediary or agent which enables third-party access to the Services, which may include for example, payment gateways or other enterprise application services.

"End-user" means a customer or prospective customer of any Client who maintains account(s) with financial services providers and who (i) grants Abwab the right to process their Information or (ii) whose information is provided by the Client to Abwab to enable the provision of the Services.

"Information" means Personal Data and Usage Information, including any information you provide to us or grant us access to, whether directly provided to us or indirectly provided through any Service Providers.

"PDPL" means the Personal Data Protection Law (issued pursuant to Royal Decree No. M/19 of 9/2/1443 H) as amended from time to time and any related legislation.

"Personal Data" shall have the meaning given to it in the PDPL.

"Portal" means application dashboards, widgets, website, portals or any other applications where a Client and/or End-user may access and utilise the Services, including through a Service Provider, Distributor, or Client.

"Services" means the services and/or products offered by Abwab to our Clients, including loan processing automation.

"Service Providers" means third party companies and individuals engaged by Abwab to:

1. facilitate the Services;
2. provide Information to any Abwab Group Company; or
3. provide or perform the Services on Abwab's behalf or assist us in analysing how the Services are used.

"Site" means Abwab's website at https://abwab.ai, attached domains and other web and mobile-based applications ("app").

"Usage Information" means information which is collected automatically and is generated by your use of the Services, access to the Site, or from the Abwab Service infrastructure itself through or by any device (for example, we may capture the duration of your visit to a particular page of our Site).

"User" means the person who is using the Site and/or Portal (i.e. "you") and/or who is the subject of the Information we collect. For example, a user may be a Client, or the employee of a Client, an End-user or their appointed representative of the Services; a Banking Partner, or an employee of a Banking Partner, or a Distributor, or an employee of a Distributor.

In this Policy:

1. any references to singular include plural (and vice versa);
2. the expression "including" or "shall include" means "including without limitation" (with related words being construed accordingly); and
3. words importing persons shall include natural persons, bodies corporate, unincorporated associations and partnerships (whether or not any of them have separate legal personality).

3. What data we collect about you

Abwab is primarily engaged by, and offers services relating to, corporate entities. As such those instructors are not data subjects. However, as part of such instructions personal information may be provided to us (e.g., personal information relating to any of our corporate clients' or prospective clients' officers or personnel, any opponent or vendor or purchaser or personal information relating to their legal advisors or personnel, as relevant or similar).

We may collect personal information from you in the course of our business, including through your use of our Site, when you contact or request information from us, when you engage our Services or as a result of your relationship with one or more of our staff or Clients.

We may collect, use, store and transfer different kinds of data about you which we may be grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details, bank statements, or other such bank information.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.  
• Usage Data includes information about how you interact with and use our Site and Services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not Personal Data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

When you sign up as a Client of Abwab, we may collect the following Information about you. This Information helps us to verify who you say you are. This will include Information, such as:

• your name, date and place of birth;
• contact details, such as your home address, work address, email and phone number;
• details about your place of work, your role at the Client, the Client’s company incorporation details, group structure, including ultimate beneficial ownership details of the Client;
• information about your identity, such as a copy of your ID document (for example: passport / national ID); and
• any details that you provide us through the Abwab chat feature on our Site, during the integration process, or Information we collect or generate about you when you get in touch with us, including any details that are submitted to us via webform, email, the Abwab portal or any other digital or paper mechanism.

We may also get Information about you and the Client from external sources to help us verify your identity and manage our business risk. This may include engaging with credit reference or fraud prevention agencies and Know Your Customer (“KYC”) and Anti-money laundering (“AML”) service providers to fulfil our legal duties.

When you use the Services as an End-user, we may collect the following Information about you. This Information helps us to provide the Services and will include Information, such as:

• your name and banking credentials required to access your financial services provider account which you intend to connect using Abwab;
• the Information which is available from one or more account(s) held by you with a financial service provider, to which you have provided Abwab consent to access and use to develop its Services and train its models. Depending on the extent that such information is made available, in whole or in part, by the respective financial services provider, this may include the following data: (i) account details (including account name, account number, type, IBAN, currency, last four digit card number, credit limit, payment due date and next payment due amount); (ii) balance details (including balance and currency); and (iii) transaction history (including payment amount, description, currency and timestamp); and
• any details that you provide us through the Abwab chat feature on our Site, or Information we collect or generate about you when you get in touch with us, including any details that are submitted to us via webform, email, the Abwab portal or any other digital or paper mechanism.

By choosing to use the Services or as a result of your access to our Site, we may also collect Information concerning:

• payments to and from your connected financial services provider account(s) and your savings activity;
• details about services from us and our partners that you express interest in;
• details about how you use and interact with our Site or the Services;
• the mobile network and operating system that you use so that we can analyse how our Site and the Services work and fix any issues; and
• your location if you've authorised tracking, so we can help protect you against fraud.

4. How we use your Information

Abwab collects and uses your Information for various purposes, and will always have a lawful basis for doing so, especially in compliance with the PDPL. We may need to process your Personal Data for the performance of an agreement we have with you, to enter into an agreement with you, to enable us to comply with the law, or we may use your Personal Data for our legitimate interests, or those of a third party (for example, to help product development, to manage our business risk, financial affairs and to protect our staff, or for security and maintenance).

We may also use your Information to:

• develop, operate, provide, maintain, and improve the Services, now and in the future;
• keep you up-to-date on the latest Abwab Service announcements, system enhancements, special offers, and other information;
• provide and receive information, support, feedback and assistance related to the Services;
• train our models on the data you provide us through the Site or through any other means.
• enable you to create a personal profile, access the application dashboard and view protected content;
• analyse usage trends and the preferences of our Users and to conduct questionnaires and surveys, in order to improve the Services (your completion of these questionnaires will always be voluntary);
• where you are a Client, or work for a Client (i) contact you for administrative purposes, such as customer support; (ii) send communications, including updates on promotions and events, relating to products and services offered by us; (iii) personalise content and advertising to your preferences; and (iv) protect, investigate, and deter against fraudulent, unauthorised, or illegal activity.

If you participate in an Abwab activity or forum on our Site, the Information that you provide will be made visible to others.

5. Your rights in relation to your Personal Data

You have a number of rights in relation to the Personal Data that we hold about you. These rights include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you. Once we have received a request from you, we will tell you about what Personal Data we hold in our databases, including available details about the origin of that data, the purposes of our processing and the categories of data concerned, the parties involved in the data collection and any data recipients (including where we transfer your Personal Data outside of the the Kingdom of Saudi Arabia. We will also tell you how long we will store your Personal Data (or the criteria used to determine that period), and your ability to ask us to rectify, erase or restrict our processing of your Personal Data. If you would like to obtain access to the Personal Data we hold on you, please send us a request in writing using the contact details below, together with a clearly legible copy of a valid official ID document (e.g., passport, ID card, driving licence) (known as the Right to be Informed and your Right of Access);
• in certain circumstances, the right to withdraw your consent to our processing of your Personal Data. Please note, we may still be entitled to process your Personal Data if we have another legitimate reason for doing so and your withdrawal of consent will not affect the lawfulness of processing taken place previously (known as the Right to Withdraw Consent);
• in some circumstances, the right to receive copies of your Personal Data electronically and/or request that we transmit the Personal Data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided to us (known as the Right to Data Portability);
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete, the right to request that we restrict our processing of your Personal Data (in certain circumstances) and the right to object to the processing of your Personal Data (in certain circumstances) (known as the Right to Rectify, Restrict and Object);
• the right to request that we erase or destroy your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally required to retain it (known as the Right to be Forgotten); and
• the right to file a complaint with the relevant authority (for example, in the Kingdom of Saudi Arabia, you may lodge a complaint with the Saudi Authority for Data and Artificial Intelligence ("SDAIA") if you think that any of your rights have been infringed by us.

Where you have accessed the Site through a Client website or application (“Developer Application”), the products and/or services provided to you by the Developer Application will be governed by a separate agreement between you and the provider of the Developer Application (“Developer Terms”). Abwab has no responsibility for the products and services provided to you by or through the Developer Application and Abwab will not be liable to you for any harm, damage or loss arising from your use of the products and services provided by or through the Developer Application.

6. What we expect from you

You are responsible for making sure the Information that you give us is accurate and up to date. And you must tell us if anything changes, as soon as possible. If we ask you for any Information and you do not provide it to us, we may stop providing the Services to you.

If you give us any information about another person connected to your account, you must tell them what Personal Data you have given us, and make sure that they are informed of the contents of this Policy and agree that we can use their information as set out in this Policy. You must also tell them how they can see what Personal Data we have about them and how to request the correction of any mistakes.

7. Unsubscribing and opting out

Strictly with your permission, we may use your Information for marketing purposes. Each promotional email you receive from Abwab or any of our affiliated third parties will include instructions on how you can unsubscribe from that category of mailing or from receiving emails from that third party. You may also unsubscribe from Abwab's promotional emails by sending an email, including your name and email address to the contact details below.

8. Profiling, Usage Information and location data

We may analyse and evaluate your Information in an automated manner so as to identify significant characteristics or to predict insights and to create profiles. These may be used for business-related checks, product development and management:

• when providing you with the Services, we may make decisions about you by automated means. For example, we use technology that helps us to identify the level of risk involved in User account activity (i.e. for credit, fraud and financial crime reasons). We may also use information received by third party providers to identify if someone else is using your Abwab account without your permission.
• you have a right to certain information about how we make these decisions. We ensure that a suitable contact person is available if you wish to express a view on any automated individual decision, where such opportunity to express a view is required by law. Please contact us using the contact details below for more information.
• in some instances, Abwab may collect non-personal (aggregate or demographic) data through Cookies, web logs, and web beacons. This Information may include, but is not limited to, information such as your computer's internet protocol address (e.g. IP address), browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
• when you access our Site with a device, the Information may also include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of internet browser you use, unique device identifiers and other diagnostic data.
• this information allows us to better understand and improve the usability, performance, and effectiveness of our Site and to correct any problems that may occur. Please read the Cookies section below for more information. We may also collect and store your location data when you access our Site via a mobile device or computer. You can enable or disable location services when you use our Site at any time through your device settings.

9. Sharing your Personal Data

We will never sell or rent your Personal Data to third parties for marketing purposes. We may share and transfer your Personal Data within the Abwab Group and with our affiliated companies, Service Providers and any third parties engaged by us where:

• we need to for the purposes of providing you with Services that you have requested (i.e. application development and providing Client and End-user support);
• we have a public or legal duty to do so (i.e. to assist with detecting fraud, regulatory reporting, litigation or defending our legal rights);
• we have a legitimate reason for doing so (i.e. to manage risk, verify your identity, or assess your suitability for products and the Services); or
• we have asked you for your permission to share it, and you have agreed.

We only share your Personal Data to the extent that the other party reasonably needs it to complete or utilise the requested product or transaction, or to perform their function. All of our affiliated companies, Service Providers and any third parties engaged by us are not permitted to use your Personal Data except for the specific purposes, as agreed with Abwab.

On occasion we may transfer and disclose your Information in other cases including:

• in response to subpoenas, court orders, legal process or according to the requirements of applicable laws. We will only share such Information if required to do so, if we in good faith believe it is necessary, or if it is otherwise advisable to cooperate with law enforcement or other governmental agencies;
• to establish or exercise our legal rights or defend against legal claims;
• to investigate, prevent, or take action against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Abwab's terms of service, or as otherwise that we believe in good faith is required by applicable law;
• when there is a sale or transfer of all or part of Abwab's business or assets (which could include any merger, financing, acquisition, or bankruptcy); or
• we may also share aggregated and/or anonymised data with others, such as our financial institution partners, for their own uses, or to meet our reporting obligations, or to indicate our Users' interests, habits, and usage patterns. For example, we may share such information publicly to show trends about the general use of the Services. However, you will not be able to be individually identified from this information.

10.  Cross border transfers of your Personal Data

Our Site is hosted in the Kingdom of Saudi Arabia but can be accessed by any Abwab affiliate worldwide. Accordingly, any Information collected through the Site may be transferred to, and stored at, a destination outside of the country or jurisdiction in which it was collected, including locations which may not have the same level of protection for your Personal Data.

Depending on where you access the Services or our Site, our Portal is hosted on cloud Infrastructure in the country of origin e.g. the Kingdom of Saudi Arabia. All Personal Data is stored in an encrypted and segregated manner and access is strictly limited to such Abwab employees who need to access it to fulfil a service or instruction to you.

In some cases, we may need to transfer your Information outside of the country or jurisdiction in which it was collected. We may need to transfer your Information in this way to perform our agreement with you, to perform the Services, to fulfil a legal obligation, to protect the public interest and/or for our legitimate business interests, for example in the context of an outsourcing or business arrangement with our Service Providers and affiliates.

Whenever we transfer your Information outside of the country or jurisdiction in which it was collected we will ensure that it is protected by us in a manner that is consistent and permissible under applicable data protection rules, especially the PDPL.

Depending on the kind of product or Abwab Service that is used, your Personal Data may also be disclosed to third parties domiciled in jurisdictions which are deemed not to have an appropriate level of data protection. If data is transferred to such a country, we take appropriate measures so that your Personal Data continues to receive the appropriate protection.

11. Security of your Personal Data

Abwab is committed to protecting the Personal Data you share with us or that is provided by our Clients on your behalf. We rely on a combination of industry-standard security technologies, procedures, and organisational measures to help protect your Personal Data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your Personal Data transmitted, stored or otherwise processed by us.

We advise that you take every precaution to protect your Personal Data when you are accessing our Site, Portal and using the Services. For example, we recommend that you change your passwords regularly, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser.

12. Cookies

Abwab uses technologies such as Cookies and web beacons, which allow us to make your visit to our Portal easier, more efficient and more valuable by providing you with a customised experience and recognising you when you return.

A Cookie cannot read Personal Data off your hard disk or read Cookie files created by other websites. The only Personal Data a Cookie can contain is information you supply yourself. Accepting the Cookies used on our Portal may give us access to Usage Information about your browsing behaviour, which we may use to personalise your experience and track your User traffic patterns, and to merge this information when you register. We do this in order to determine the usefulness of our Portal information to our Users and to see how effective our navigational structure is in helping Users reach that information.

In addition, Abwab uses web beacons in conjunction with Cookies to understand User behaviour. Web beacons are simply a convenient way of gathering basic statistics and managing Cookies and do not give away any extra information from your computer. Turning off your browser's Cookies will prevent web beacons from tracking your specific activity.

If you prefer not to receive Cookies while browsing our Portal you can set your browser to warn you before it accepts Cookies or refuse the Cookie when your browser alerts you to its presence. You may browse most of our Portal without accepting Cookies, however some functionality may be lost by disabling Cookies on your computer. Certain features of the Portal, particularly those which require a login and password, require Cookies and cannot be used when you have disabled Cookies in your browser.

We use the following Cookies:

• Strictly necessary Cookies. These are Cookies that are required for the operation of our website. These essential Cookies are always enabled because our website won’t work properly without them. They include, for example, Cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. You can switch off these Cookies in your browser settings but you may then not be able to access all or parts of our website.  
• Analytical or performance Cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality Cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting Cookies. These Cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

13. Linked websites and services

Our Site, Portal and the Services may provide links or directly connect with other third party websites, Developer Applications and services (such as those of our Clients) which are outside of our control and are not covered by this Policy. Abwab bears no responsibility for the information collected or used by any third party website or application, and you release us from any liability for the conduct of these third parties. We encourage you to review the privacy policies and notices of any third party website that you access, including the privacy notice of the application through which you access the Services.

14. Service Providers

Abwab may engage third party Service Providers from time to time. These Service Providers may have access to your Personal Data only to the extent necessary to perform the tasks assigned to them by us. All Service Providers engaged by Abwab are legally required to maintain the confidentiality of your Personal Data, have in place systems and controls to protect against any loss or damage to your Personal Data, and must not disclose or use your Personal Data for any other purpose other than as they are instructed.

15. Children's privacy

Our Site is not intended for use by individuals under the age of 18 ("Child" or "Children") without parent or guardian supervision. We do not knowingly collect Personal Data from Children. If you become aware that a Child has provided us with Personal Data, please contact us immediately. If we become aware that we have collected Personal Data from a Child without parental or guardian consent, we will take steps to remove that Information from our servers.

16. How long we will keep your Personal Data

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting or reporting requirements, especially as required by the PDPL.

On occasion, we may retain your Personal Data for a longer period, and even after you stop using the Services, in order to: (i) to respond to enquiries and complaints; (ii) to comply with laws and regulations; (iii) in accordance with our internal policies and procedures; or (iv) to protect our interests.

17. Contact us

Should you have any privacy-related questions or comments related to this Policy, please send an email to privacy@abwab.ai. You must always send an email to contact us, but you can also contact us at the relevant address below:

If you access or receive the Services or consent to the processing of your Data in the Kingdom of Saudi Arabia - the Data Controller shall be Establishment ABOUAB AL-BAYANAT For Information Technology, 2699 Mohammad Bin Abdulaziz Al Dughaithir, 6874 Al Malqa Dist.