DISCLAIMER AND PRIVACY POLICY

Protecting your privacy and treating the personal data of all users of our Electronic Services in accordance with the law is very important to us. We understand that by using our Electronic Services you may be entrusting us with personal information (“data”) and assure you that we take our duty to protect and safeguard this data very seriously. This Privacy Policy therefore explains the kind of data we process when using our Electronic Services, the purpose for which we process it, how we process it, whom we may disclose it to and the security measures we have put in place to protect it.

This Privacy Policy applies to all data we obtain through your use of our Electronic Services. It does not apply to data we obtain through other channels nor to Electronic Services of third parties (“third-party Electronic Services”), even if you access them via a link in our Electronic Services or even if they are necessary for the operation of our Electronic Services. We have no influence on the content or privacy policy of third-party Electronic Services and therefore cannot assume any responsibility for them.

Types of data being processed

When you use our Electronic Services, details of your usage may be automatically registered by our backend systems (such as your IP address, browser, http-header user agent, device-specific information the content you accessed, including time and date of access, usage and user interaction, and the redirecting website from which you came to our Electronic Services). We also process personal data such as your name, address, e-mail address, phone number, date of birth, gender and other data transmitted to us if you register for the usage of our Electronic Services or if you complete a registration form or comment field for a newsletter, product demos, etc..

Legal grounds and purpose of data processing

• We process the data based on the following legal grounds:
• For the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
• For compliance with a legal obligation to which we are subject;
• For the purposes of our legitimate interests.

We process the data for the following purposes:

• To comply with bank’s own internal guidelines;
• To check the identity and suitability of clients for certain products and services;
• To ensure the security and operation of our IT environment;
• To use it for marketing and advertising measures (e.g. newsletters via e-mail, online advertising);
• To analyse and monitor the usage, user behaviour and navigation while using the Electronic Services;
• To facilitate client administration.