Firstly, we are under a legal obligation to let you know what personal information we collect about you, what we use it for and on what basis. You have the right to know what information we hold about you.
But whatever we do with your information, we need a legal basis for doing it. We generally rely on one of three grounds (reasons) for our business processing in line with the purposes outlined in Article 4 of Law No. 30 of 2019 on the issuance of the Personal Data Protection Law (the “Applicable Privacy Law"). Firstly, if you have ordered or take a service from us, we are entitled to process your information so that we can provide that service to you and bill you for it.
Secondly, if we want to collect and use your information for other purposes other than what is stated herein, we may need to ask for your consent (permission) and, if we do, that permission must always be indicated by a positive action from you (such as ticking a box) and be informed. You are also free to withdraw your permission at any time. We tend to need permission when what is proposed is more intrusive (for example, sharing your contact details with other organizations so they can market their own products and services to you).
But we do not always need permission. In some cases, having assessed whether our use would be fair and not override your right to privacy, we may come to the view that it falls within our ‘legitimate interests’ to use the information in a particular way without your permission (for example, to protect our network against cyber-attacks, to block SPAM or to provide you with better customer experience).
This is all set out in detail in this policy, which focuses more on those items that we think are likely to be of most interest to you. As well as covering processing for business purposes, we give you information on circumstances in which we may have to, or can choose to, share your information.
You can request to update the information we hold about you by sending an email to email@example.com. Once we’ve looked at your request, we’ll let you know when you can expect to hear from us.
We’ll always try to help you with your request, but we can refuse if we believe doing so would involve infringement and abuse of your use of your rights, prejudice any intellectual property rights or trade secrets of us and/or a third party or the law prevents us. And even though we have to complete your request free of charge, we are allowed to reject requests if they’re repetitive or you don’t have the right to ask for or the information or the requests made are excessive. If that’s the case, we’ll explain why we believe we don’t have to fulfil the request.
The personal information we collect depends on the products and services you have and how you use them. We’ve explained the different ways we use your personal information below.
We’ll use your personal information to provide you with products and services. This applies when you register for or buy a product or service from us. Or if you register for an online account with us or download and register on one of our apps.
This means we’ll:
If we do this, we still control your personal information and we have strict controls in place to make sure it’s properly protected (Please refer to Section 12 form more details); and
We use the following to provide products and services and manage your account:
We use this information to carry out our contract (or to prepare a contract) and provide products or services to you. If you don’t give us the correct information or ask us to delete it, we might not be able to provide you with the product or service you ordered from us.
If you tell us you have a disability or otherwise need support, we’ll note that you are a vulnerable customer, but only if you give your permission or if we have to for legal or regulatory reasons. For example, if you told us about a disability we need to be aware of when we deliver our services to you, we have to record that information, so we don’t repeatedly ask you about it. We will also record the details of a Power of Attorney we have been asked to log against your account.
We’ll use your personal information if we consider it is in our legitimate business interests so that we can operate as an efficient and effective business. We use your information to:
We’ll use your personal information to send you direct marketing and to better identify products and services that interest you. We do that if you’re one of our customers or if you’ve been in touch with us another way (such as entering a prize promotion or competition).
This means we’ll:
We use the following for marketing and to identify and qualify the products and services you’re eligible to and interested in:
We’ll send you information (about the products and services we provide) by phone, post, email, text message, online banner advertising or a notice using our apps or on your TV. We also use the information we have about you to personalise these messages wherever we can as we believe it is important to make them relevant to you. We do this because we have a legitimate business interest in keeping you up to date with our products and services, making them relevant to you and making sure you manage your spending with us. We also check that you accept that we send you marketing messages by text or email before we do so. You also have the option to opt out by using the unified number 88444
We’ll only use your telecom usage and behavior, browser and some TV records (such as programmes you watch on channels we provide that are produced by other organisations) to better personalise our offers to you.
By signing our terms and conditions you agree we will market to you other organisations’ products and services to you.
If you no longer want to receive a marketing activities from us, you will need to calling us on 124 to submit your request along with your proof of identity, and we will attend your request in due course. We will notify you, with any of the following:
If you’re opted out of a marketing activity, you may still receive service-related messages (e.g. billing, add-on/service activation, credit limit, expiry of term(s) etc..)
What are cookies?
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our service.
Cookies themselves don't hold personal information. They only have a unique alphanumeric identifier that sits on your browser. And in many cases, we won’t be able to link the information we collect by using a cookie back to you. They can, however, enable us to link that information back to you and your personal information, for example, when you log in, or choose to register for a service.
Cookies we use
How can I control cookies?
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
For example, to make a purchase online or sign up to services like mobile application, software and/or online content, you may have cookies enabled on your internet browser. You may choose not to enable cookies, you’ll still be able to browse our website, but it will restrict some of the functionality of our website and what you can do.
We’ll use your personal information to create aggregated and anonymised information. Nobody can identify you from that information and we’ll use it to:
We use the following to generate aggregated and anonymized information.
We have a legitimate interest in generating insights that will help us operate our network and business or would be useful to other organisations.
This means we’ll:
We use the following information to do this.
If we use this information for market research, training, testing, development purposes, defend or bring claims or to create a profile about you, we do so because it is in our legitimate business interests of running an efficient and effective business which can adapt to meet our customers’ needs.
We create a profile about you based on what you have ordered from us and how you use our products and services. This helps us tailor the offers we share with you.
Before we provide you with a product or service (including upgrades or renewals), or sometimes when you use our products and services, we’ll use your personal information and usage together with information we have collected from credit reference agencies, or fraud prevention agencies. We use this information to manage our credit risk and prevent and detect fraud and money laundering. We’ll also use these organisations to confirm your identity. When they get a search from us, a 'footprint' goes on your file which other organisations might see. We might also share the information with other organisations. We do this because it’s in our, and the organisations’, legitimate interests to prevent fraud and money laundering, and to check identities, to protect our business and to keep to laws that apply to us.
Details of the personal information that will be used include your name, address, date of birth, contact details, financial information, employment details and device identifiers, including IP address and other relevant details.
If you give us false or inaccurate information or default on payment which we identify as fraudulent, we may eventually pass that on to fraud prevention agencies. We might also share it with law enforcement agencies, as may the agencies we have shared the information with.
If we, a credit reference or eventual fraud prevention agency, decide that you are a credit, fraud or money laundering risk, we may refuse to provide the services or financing you have asked for, or we may stop providing existing services to you.
The credit reference and eventual fraud prevention agencies will keep a record of any fraud or money laundering risk and this may result in other organisations refusing to provide services, financing or employment to you. If you have any questions about this, please get in touch with us using the contact details found in the 'How to contact us and further details' section below.
We may send credit reference and eventual fraud prevention agencies information about applications, and they keep that information. We might also give them details of your accounts and bills, including how you manage them. This includes telling them about your account balances, what you pay us and if you miss a payment (going back in the past, too). So, if you don't pay your bills on time, credit reference agencies will record that. They, or a fraud prevention agency, might tell others doing similar checks – including organisations trying to trace you or recover money you owe them.
Whenever credit reference and fraud prevention agencies transfer your personal information outside of the Kingdom of Bahrain, they place contractual responsibilities on the organisation receiving it to protect your information to the standard required in the Kingdom of Bahrain. They may also make the organisation receiving the information commit to the conditions aimed at sharing information securely.
To collect debt
If you don’t pay your bills, we might ask a debt-recovery agency to collect what you owe. We’ll give them information about you (such as your contact details) and your account (the amount of the debt) and may choose to sell the debt to another organisation to allow us to receive the amount due.
To prevent and detect crime
We’ll use your personal information to help prevent and detect crime and fraud. We’ll also use it to prevent and detect criminal attacks on our network or against your equipment. We monitor traffic over our network, trace nuisance or malicious calls, and track malware and cyber-attacks.
To do that we use the following information, but only where strictly necessary.
We use this personal information because we have a legitimate interest in protecting our network and business from attacks and to prevent and detect crime and fraud. We also share it with other organisations (such as other communications providers and banks) who have the same legitimate interests. Doing this helps make sure our network works properly and helps protect you from attacks.
If you call the emergency services, we’ll give them information about you and where you are, so they can help. We do this because it is necessary to protect you, or another person, and because it is in our interests to help the emergency services in providing help to you.
We might have to release personal information about you to meet our legal and regulatory obligations.
To law enforcement agencies
Under investigatory powers legislation, we might have to share personal information about you to government and law-enforcement agencies, such as the police, to help detect and stop crime, prosecute offenders and protect national security.
They might ask for the following details.
Details of the products and services you’ve bought and how you use them – including your call, browser (including IP address) and TV records.
We share your personal information when the law says we have to.
We’ll also share personal information about you where we have to legally share it with another person. That might be when a law says we have to share that information or because of a court order.
In limited circumstances, we may also share your information with other public authorities ( i.e. for historical or statistical purposes and/or for scientific researches) in anonymized form. however, we would need to be satisfied that a request for information is lawful and proportionate.. .
For regulatory reasons
We’ll also use your call, browser (including IP address) and TV records to find the best way of routing your communications through the various parts of our network, equipment and systems as required by our regulator.
If you order a phone service, we’ll ask if you want your details included in our directory services such as our Phone Book. If you do, we’ll publish your details and share that information with other providers of directory services.
Sharing your information
We share your personal information with other service providers (subject to an agreement we signed with them) to process personal information on our behalf or to help us provide services to you in the following cases:
We also use them to:
Where we use another organisation, we still control your personal information. When we share your information with other organisations we’ll make sure it’s protected, as far as is reasonably possible.
Also, we may need to transfer your information to other companies or service providers in countries outside the Kingdom of Bahrain which are considered to have sufficient laws when it comes to data protection and privacy. This kind of data transfer may happen if our servers (i.e. where we store data) or our suppliers and service providers are based outside the Kingdom of Bahrain, or if you use our services and products while visiting countries outside this area.
If we send your information to a country that is not considered to have sufficient laws, we will make sure that your information is properly protected. We will always ensure that there is a proper legal agreement that covers the data transfer and reflect the standards set by law to provide sufficient protection to your information.
If there’s a change (or expected change) in who owns us or any of our assets, we might share personal information to the new (or prospective) owner. If we do, they’ll have to keep it confidential.
Protecting your information and how long we keep it
We have strict security measures to protect your personal information. We check your identity when you get in touch with us, and we follow our security procedures and apply suitable technical measures, such as encryption, to protect your information.
We retain your personal information as long as we have an ongoing legitimate business need to do so provided that we have a legal basis to do so, for example to provide services or products to you, or as required or permitted by applicable laws.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.
How to contact us and further details
You can get in touch with our data-protection controller by email firstname.lastname@example.org or write to the address below and mark it for its attention.
stc Bahrain – P.O. Box 21529
Manama, Kingdom of Bahrain
If you want to make a complaint on how we have handled your personal information, please contact our data protection controller who will investigate the matter and report back to you. If you are still not satisfied after our response or believe we are not using your personal information in line with the law, you also have the right to complain to the TRA. http://www.tra.org.bh/
We will notify you of such changes at least 30 days’ in advance.
Legal Code: 4CA2019V2
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