Purpose of this Privacy Statement
ThoughtBox respects your privacy and is committed to maintaining the confidentiality and security of the Personal Data of its existing, prospective and former customers and beneficiaries. This Privacy Statement informs you about how we process Personal Data, how we look after it and tells you about your rights with respect to your Personal Data. ThoughtBox encourages you to review this Privacy Statement and become familiar with it.
Personal Data processed
3.1 What does Personal Data mean?
Personal Data is data which identifies an individual or which can be used in combination with other data to identify an individual, such as name, address, telephone number and e-mail address.
ThoughtBox collects Personal Data from Data Subjects mainly through its branches, websites, and third parties or publicly available sources. For more information on these sources of Personal Data, please refer to the sections below.
Where ThoughtBox needs to collect Personal Data by law or under the terms of a contract we have with you, and you fail to provide that Personal Data, ThoughtBox may not be able to fulfil
our contractual obligations (e.g. a money remittance) and we may have to cancel the services you requested.
3.2 Personal Data collected
To provide the services requested by ThoughtBox customers, ThoughtBox collects the following Personal Data through its network of branches and Online Money Transfer platforms (OMT):
o Full Name (sender and recipient of the transaction)
o Address (sender and recipient of the transaction)
o Nationality (sender and recipient of the transaction)
o Telephone, including mobile (sender and recipient of the transaction)
o Relationship between sender and recipient of the transaction
o Birth Place
o Employer details
o Origin of the financial resources
o Financial background
o Identification document (e.g. National ID, QID, Passport with valid visa etc. as permitted by Qatar regulation)
o Bank Statements
o Transaction amounts
o Bank account details
o Credit / Debit card numbers
o Marketing &amp; other Contact Preferences
As a financial institution, ThoughtBox has certain obligations with regards to identity verification, fraud prevention and other similar security purposes. To ensure compliance with those obligations, certain of the Personal Data described above may be collected from, or verified against, third party sources such as government agencies and consumer reporting agencies. For identity verification purposes, senders and recipients of money transfers may be required to produce valid identification or consent to verification by other means before releasing funds.
3.3 Personal Data collected by ThoughtBox websites
At its websites, ThoughtBox collects aggregated user data (i.e. information that cannot be used to identify you), Personal Data that Data Subjects voluntarily provided, and Personal Data collected using cookies (as explained in the next section).
3.3.1 Definition and usage of cookies
A cookie is a small piece of information that is stored on your device (such as your computer) and which records the way that you use a website so that, when you revisit that website, ThoughtBox can provide tailored options based on the information that has been collected from your last visit. Cookies can also be used to analyse traffic and, in some cases, to provide you with tailored advertising and marketing.
Following are the broad categories of cookies used on ThoughtBox websites:
o Essential cookies: These cookies make ThoughtBox website operation work and therefore they cannot be turned off or rejected. These cookies do not gather any information about you and do not have the ability to remember how you have used our website.
o Performance cookies: ThoughtBox use these cookies to help analyse how its website is used and to improve its performance. For example, ThoughtBox use them to understand where visitors to the ThoughtBox site are based, how many people visit the website and which sections of the website are the most used;
o Functionality Cookies: These cookies allow ThoughtBox website to remember if you have previously visited the ThoughtBox site or the choices you made (e.g. language preferences) to provide a more personalised online experience.
o Third-Party cookies: These cookies collect information from your device and perform tasks that analyse behaviour and collect other information, such as demographics. These cookies may be used to provide you with personalised advertising.
3.3.2 Third Party Marketing Cookies and Social Advertising
3.4 Personal Data collected by ThoughtBox through Social Media
ThoughtBox may process anonymized data derived from Data Subjects' publicly available social media resources for statistical purposes. Although anonymized may be derived from your Personal Data, it is not considered Personal Data in law as this data will not directly or
indirectly reveal your identity. We may also process Personal Data derived from publicly available social media resources that Data Subjects make available when interacting with us including: Facebook, Twitter, YouTube, LinkedIn, Instagram, Google+, Pinterest, Weibo and WeChat. Such Personal Data may include but is not limited to:
o Public Social Media Profile Name
o Mobile number
o ThoughtBox related posts (e.g. Mentions and Hashtags)
Legal basis for processing Personal Data
Personal Data will be processed by ThoughtBox only if and to the extent that at least one of the
Compliance with Legal Obligations
ThoughtBox may process Data Subjects Personal Data when necessary to comply with a legal obligation, e.g. Anti-Money Laundering screening and reporting requirements and where required to comply with court order or judicial proceedings.
Necessary to achieve legitimate purposes
ThoughtBox may process Data Subjects Personal Data in pursuance of its legitimate business purposes where such processing is necessary, and our interests are not overridden by the privacy rights of the Data Subjects. E.g., our legitimate business interests may include communication with our customers in relation to requested transactions, pursuit of customer care initiatives, internal record keeping purposes and fraud prevention.
ThoughtBox may process Personal Data as required to ensure we comply with our contractual obligations towards Data Subjects.
Purpose of Data Processing:
ThoughtBox generally uses Personal Data from Data Subjects for the purpose of providing a
service. This may include the following:
o Authorising and processing Data Subjects' transactions, including effecting and administering money transfers and ensuring proper payment to the designated recipient of funds.
o Monitoring and improving our services including websites/mobile apps and its content.
o Sending information to Data Subjects about ThoughtBox products and services.
o Customer care initiatives to improve ThoughtBox services.
o Meeting legal, regulatory, self-regulatory, risk management, fraud prevention and security requirements, which may include (among other measures) verifying the identity of the sender and recipient of funds and checking identities against money laundering, terrorist financing or similar watch lists established by regulatory agencies or similar bodies. For identity verification purposes, senders and recipients of money transfers may be required to produce valid identification or consent to verification by other means before releasing funds.
o Maintaining business and transaction records for reasonable periods, and generally managing and administering ThoughtBox business.
o Meeting insurance, audit and processing requirements.
o Otherwise as permitted or required by law.
Personal Data Sharing
In order to carry out the processing activities established in this Privacy Statement, ThoughtBox
may disclose Personal Data relating to its Data Subjects to:
o Data Processors: ThoughtBox may share Personal Data with third-party service providers ("Data Processors"), including affiliates of ThoughtBox performing services
on ThoughtBox behalf, for example: information technology, data hosting, marketing, customer care, fraud prevention, etc. subject to relevant regulation. ThoughtBox takes steps to ensure that Personal Data that is processed by Data Processors is protected and not used or disclosed for purposes other than as directed by ThoughtBox.
o Third Party Data Controllers and Joint Controllers: ThoughtBox may share Personal Data with third parties acting independently from ThoughtBox as may be required in connection with the services provided to Data Subjects, for example: any intermediary banks or other financial institutions involved in the transaction of ThoughtBox services.
o Successors: if ThoughtBox is purchased by/sold to a third party, Personal Data held by ThoughtBox will be transferred to the successor entity.
o Relevant Authorities: ThoughtBox may disclose Data Subjects' Personal Data as necessary to meet legal and regulatory requirements. This may include disclosure of Personal Data to government authorities, for example, in compliance with suspicious activity reporting requirements under anti-terrorism, anti-money laundering and similar laws and regulations.
Cross Border Personal Data Transfers
In connection with providing services to its customers, ThoughtBox may transfer Personal Data to destinations outside Qatar in accordance with our legitimate business purposes and where permitted under law. When transferring Personal Data outside Qatar, ThoughtBox ensures that
security measures and appropriate safeguards are put in place to protect the Personal Data and to ensure that all transfers comply with applicable data protection law.
Data Subject’s Rights
Data Subjects have certain rights with respect to their Personal Data. In summary, these are:
o To be informed: Data Subjects have the right to receive certain information about how their Personal Data is processed. Therefore, we are providing you with this Privacy Statement.
o Access: Data Subjects have the right to access and receive a copy of their Personal Data.
Data Subjects are also entitled to lodge a complaint with the Data Protection regulatory authority, the Ministry of Transport and Communications (MoTC). We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so
please contact us in the first instance. For more information on your rights, please contact us using the details below.