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PRIVACY NOTICE

In this Privacy Notice:

Data Protection Legislation means the EU General Data Protection Regulation 2016/679 ("GDPR"); together with all other applicable and national implementing legislation relating to privacy or data protection; and where we use the terms "personal data", "data subject", "controller", "processor" and "process" (and its derivatives), such terms shall have the meanings given to them in the Data Protection Legislation.

INTRODUCTION

ICICI Bank Limited is committed to keeping your personal data private. We shall process any personal data we collect from you in accordance with Data Protection Legislation and the provisions of this Privacy Notice. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

DATA CONTROLLER

For the purpose of the GDPR, ICICI Bank is the data controller of your information. This means that we are responsible for deciding how we hold and use your personal data. We are required under Data Protection Legislation to notify you of the information contained in this Privacy Notice.

COLLECTING INFORMATION FROM YOU

ICICI Bank will collect and process your personal data you provide us through application forms, our website, face-to-face and electronic communication (including telephone conversations) in order to provide our services to you.

THE KIND OF INFORMATION WE HOLD ABOUT YOU

  • Personal details such as name, date of birth, email address, nationality, gender and phone numbers
  • Current overseas residential address and permanent residential address
  • Transaction details
  • Financial Information
  • Information in the nature of your occupation, education and qualifications, annual income and source of income
  • Address and date of birth proofs like valid passport, driving license, voter identification card, identity proofs such as Aadhaar Card, PAN card issued by government authorities.
  • Overseas address proofs such as address on passport, utility bills, bank statements, national ID cards and photographs
  • IP addresses

Advertising and Marketing

Links

There are links in our website leading to other sites. This guidance does not extend to those sites. We therefore would recommend the reading of the data safeguarding policies of these sites.

Security

All proper and expected technical and organizational security procedures have been taken to shield your personal data and to prevent that no unauthorized persons gain access to the same. These precautions include for example the transfer of all data entered into our internet presence using SSL encryption (128 bit) or the use of a mandatory authentication mechanism for access to your account

LAWFUL GROUNDS FOR USING YOUR INFORMATION

We are permitted to process your personal data in compliance with Data Protection Legislation by relying on one or more of the following lawful grounds:

  • You have explicitly agreed to us processing such information for a specific reason.
  • The processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you.
  • The processing is necessary for compliance with a legal obligation we have.
  • The processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
    1. to provide services to you;
    2. to ensure that our customer accounts are well-managed;
    3. to prevent, detect, investigate and prosecute fraud and alleged fraud, money laundering and other crimes and to verify your identity in order to protect our business and to comply with laws that apply to us and/or where such processing is a contractual requirement of the services or financing you have requested;
    4. to protect our business interests;
    5. to ensure that complaints are investigated;
    6. to evaluate, develop or improve our services; or
    7. to keep our customers informed about relevant services, unless you have indicated at any time that you do not wish us to do so.

PURPOSES OF PROCESSING

Specifically, we and our other group companies may use your information for the following purposes and under the following legal bases:

How we use your information
 Legal basis
To provide and manage your account(s) and our relationship with you
  • Where necessary for the performance of our agreement or to take steps to enter into an agreement with you
  • Where the law requires this
  • Where it's in our legitimate interests to ensure that our customer accounts are well-managed, so that our customers are provided with a high standard of service, to protect our business interests and the interests of our customers
To give you statements and other information about your account or our relationship
  • Where necessary for the performance of our agreement or to take steps to enter into an agreement with you
  • Where the law requires this
To handle enquiries and complaints
  • Where necessary for the performance of our agreement or to take steps to enter into an agreement with you
  • Where the law requires this
  • Where it's in our legitimate interests to ensure that complaints are investigated, for example, so that our customers receive a high standard of service and so that we can prevent complaints from occurring in future
  • In the case of sensitive information, such as medical information, where you have agreed
To provide our services to you
  • Where necessary for the performance of our agreement or to take steps to enter into an agreement with you
  • Where the law requires this

For assessment, testing (including systems tests) and analysis (including credit and/ or behaviour scoring), statistical, market and product analysis and market research.
  • Where the law requires this
  • Where it's in our legitimate interests to develop, build, implement and run business models and systems which protect our business interests and provide our customers with a high standard of service
To evaluate, develop and improve our services to you and other customers
  • Where it’s in our legitimate interests continually to evaluate, develop or improve our products as well as the experiences of users of our sites, so that our customers are provided with a high standard of service
To protect our business interests and to develop our business strategies
  • Where it's in our legitimate interests to protect our people, business and property and to develop our strategies
  • Where necessary for the performance of our agreement or to take steps to enter into an agreement with you
  • Where the law requires this
  • In the case of sensitive information, such as voice biometric information, where you have agreed
To contact you, by post, phone, text, email and other digital methods. This may be:
  • to help you manage your accounts
  • to meet our regulatory obligations
  • to keep you informed about products and services you hold with us and to send you information about products or services (including those of other companies) which may be of interest to you.
  • Where the law requires this
  • Where we have agreed to contact you in our agreement
  • Where the law requires this
  • Where you agree
  • Where it’s in our legitimate interests to share information with our customers about products / services that may be relevant and beneficial to them. Where we send you marketing messages, you can always tell us when you no longer wish to receive them.
To collect any debts owing to us
  • Where it's in our legitimate interests to collect any debts owing to us
  • In the case of sensitive information, such as medical information, where you have agreed
To meet our regulatory compliance and reporting obligations and to prevent, detect, investigate and prosecute fraud and alleged fraud, money laundering and other crimes. We may record your image on CCTV when you visit our premises.
  • Where the law requires this
  • Where it's in our legitimate interests to prevent and investigate fraud, money laundering and other crimes
  • Where such processing is a contractual requirement of the services or financing you have requested
To assess any application you make, including carrying out fraud, money laundering, identity, sanctions screening and any other regulatory checks.
  • Where you have made data public
  • Where such actions are in our legitimate interests, for the protection of our business interests
  • Where the law requires this
  • In the case of sensitive information, such as medical information, where you have agreed
To monitor, record and analyse any communications between you and us, including phone calls
  • Where it’s in our legitimate interests, to check your instructions to us, to prevent and detect fraud and other crime, to analyse, assess and improve our services to customers, and for training, for the enhancement of our customer service provision and protection of our business interests
  • In the case of sensitive information, such as medical information, where you have agreed
To transfer your information to or share it with any third party to whom your account has been or may be transferred following a restructure, sale or acquisition of any group company
  • Where necessary for the performance of our agreement with you
  • Where we have a legitimate interest in restructuring or selling part of our business
To share your information with India or other relevant tax authorities, Reserve Bank of India and other government authorities, credit reference agencies, fraud prevention agencies, and India and overseas regulators and authorities
  • Where the law requires this
  • Where we have a legitimate interest in performing certain credit checks so that we can make responsible business decisions. As a responsible organisation, we need to ensure that we only provide certain products to companies and individuals where the products are appropriate, and that we continue to manage the services we provide, for example if we consider that you may have difficulties making a payment to us.
  • Where we have a legitimate interest in assisting with the prevention and detection of fraud and other crime
  • Where we have a legitimate interest in assisting UK and overseas regulators, who monitor banks to ensure that they comply the law and regulations
  • More detail on our data sharing with these organisations is set out below
To share your information with our partners and service providers
  • Where necessary for the performance of our agreement
  • Where we have a legitimate interest in using third parties to provide some services for us or on our behalf

AUTOMATED DECISION MAKING

If you apply to us for a product, your application may be processed by an automated decision-making process which may carry out credit and affordability assessment checks to determine whether your application will be accepted. Where these automated processes suggest that your application should be rejected, we may manually review your application before making a final decision. We may also use automated processes to decide credit limits.

We may also carry out automated anti-money laundering and sanctions checks. This means that we may automatically decide that you pose a fraud or money laundering risk if the processing reveals your behaviour to be consistent with that of known fraudsters or money launderers, is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk: (i) we may refuse to provide the services you have requested, or we may stop providing existing services to you; and (ii) a record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services or employment to you.

INFORMATION SHARING

We keep all your personal data confidential. However, in order to be able to service your needs to the best of our ability, we may share any information you provide to us with our group companies and their agents, counterparties and support service or data providers, wherever located. If you have provided information to other members of our group, those entities may also share that information with us.

To help us provide services, your data will be processed internally and externally by other third parties. We use third parties for administrative, servicing, monitoring of your data. We will outsource some services to third parties whom we consider capable of performing the required processing activities so that there is no reduction in the service standard provided to you by us.

The recipients or categories of recipients, of your information may be:

  • Any revenue service or tax authority including Income Tax Department, if obliged to do so under applicable regulations.
  • Overseas regulators and authorities in connection with their duties (such as crime prevention).
  • Anyone to whom we may transfer our rights and/or obligations;
  • Any other person or organization after a restructure, sale or acquisition, as long as that person uses your information for the same purposes as it was originally given to us or used by us (or both)
  • Credit reference, identity and address verification organizations who may record and use your information and disclose it to other lenders, financial services organizations and insurers. Your information may be used by those third parties to make assessments in relation to your creditworthiness for debt tracing.
  • Fraud prevention agencies and law enforcement agencies who will use it to prevent fraud and money-laundering and to verify your identity if false or inaccurate information is provided by you and fraud is identified. We, fraud prevention agencies and law enforcement agencies may access and use your information for example, when:
    1. Checking details on applications for credit and credit related or other facilities;
    2. Managing credit and credit related accounts or facilities;
    3. Recovering debt;
    4. Checking details on proposals and claims for all types of insurance
  • Other product and service providers for products and services which you would have agreed to avail or being referred to
  • Service providers as appointed from time to time for operational support to the Bank
  • Courier or postal service providers for the purpose of sending of mails to you as a customer
  • Social media websites for our marketing campaigns where permitted

For further information, please refer to our product specific terms and conditions and application form.

DETAILS OF DATA TRANSFERS OUTSIDE THE EU

As we are a Bank established in India, if you are an EU resident, information about you will be transferred to us and to other parties in countries outside the European Economic Area (particularly India) for any of the purposes described in this Privacy Notice.

You understand and accept that these countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies and private persons, as a result of applicable governmental or regulatory inquiry, court order or other similar process. In addition, a number of countries have agreements with other countries providing for exchange of information for law enforcement, tax and other purposes.

If we transfer your information outside the European Economic Area in (for example because we have to provide such information by law), we will use best endeavours to put in place appropriate safeguards to ensure that your information remains adequately protected.

RETENTION AND DISPOSAL OF DATA AND OUTPUT

We will keep the information we collect about you on our systems or with third parties for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject.

STORAGE OF YOUR PERSONAL DATA AND DATA SECURITY

All information you provide to us is stored in our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know basis. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

OUR COMMUNICATION WITH YOU

We may communicate with you via electronic mail (e-mail). We will never ask you for your password.

When you contact us through any of our communication channels including visiting a local branch or calling the telephone banking service, we will verify your identity by asking you a number of questions based on information known to us about you and the transactions on your account. We may record your calls for training, quality and security purposes.

 

MARKETING INFORMATION

We and other members of our group may use your information from time to time to inform you by letter, telephone, text (or similar) messages, email or other electronic means, about similar services which may be of interest to you or them.

Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will provide this information free of charge unless the request is manifestly unfounded or excessive. We will comply with our legal obligations as regards any individual’s rights as a data subject.

If you would like to contact us in relation to any of the rights set out above please contact us using the following contact details. To protect your privacy and security, we may take reasonable steps to verify your identity before providing you with the details.

dataprivacy@icicibank.com

 

RIGHT TO COMPLAIN TO THE SUPERVISORY AUTHORITY

You have a right to lodge a complaint with the supervisory authority of state of habitual residence.

THIS PRIVACY NOTICE

The content or services mentioned on our website may be changed in future and consequently this Privacy Notice may also change. Any changes we may make to this Privacy Notice in the future will be posted on this page and where appropriate, notified to you by email. We recommend that you re-visit this page regularly and inform us if you do not agree to any term mentioned here.

Anonymous information retrieval

Our Money2India website (www.money2india.com) may be accessed by you anonymously. That means, your personal data (e.g. name or address) will not be collected. We only gather, stock and make use of anonymous information like the name of the Internet provider, the website from where you access our site and the websites you access from our site. All this is collated for reasons that are statistical and calculated to modify our website to serve the needs of our users in an appropriate manner. Your identity as a user will always stay unidentified.

 

 

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