Coöperatieve Rabobank U.A. New York Branch (“Rabobank”) processes personal data. We wish to inform you about this clearly and transparently. This privacy statement will answer your most important questions about the processing of personal data by Rabobank.
In this privacy statement we will use certain terms. Below is an explanation of those terms.
- Personal data:
Data that directly or indirectly identifies individuals. Examples are your name and address, but also income.
Any acts that can be performed in relation to personal data. These may include collection, but also storage, use and removal of your data from our records.
This Privacy Statement may be revised from time to time.
1. Whose personal data are processed by Rabobank?
We process personal data of individuals associated with entities with whom we have, wish to have, or previously had, a direct or indirect relationship (the “Subject Entity”). This may include:
- clients and their representatives;
- persons who show an interest in our products and services; or
- persons who are associated with a business or organisation with which we have, wish to have, or previously had, a relationship.
Please note: if your business or organisation provides us with personal data of employees, you are under the obligation to inform your employees thereof. You may provide them with this privacy statement, so that your employees can see how we treat their personal data.
To protect your interests as well as our own, we may process personal data of third parties. We may do so, for example, for purposes of fraud control.
2. Who is responsible for the processing of my personal data?
All Rabobank Group divisions process personal data. Rabobank Group includes Rabobank and various subsidiaries globally. However, any reference in this privacy statement to Rabobank will refer to the Rabobank Group.
The key Rabobank subsidiaries and locations in the Netherlands are:
- Coöperatieve Rabobank U.A.
- Rabohypotheekbank N.V.
- Rabo Groen Bank B.V.
- Rabo Financieringsmaatschappij B.V.
- Rabo Herverzekeringsmaatschappij N.V.
- Rabo Vastgoedgroep (including Rabo Bouwfonds Holding N.V., Bouwfonds Investment Management B.V., Bouwfonds Property Development B.V., Rabo Eigen Steen Holding B.V., and FGH Bank N.V.)
- De Lage Landen International B.V.
- Obvion N.V.
3. For what purposes does Rabobank process personal data of individuals?
We process personal data of individuals for the following purposes:
a. To be able to enter into a relationship
If you as an individual are associated with a Subject Entity that wishes to become a Rabobank client, or if you, as an individual are associated with an entity that wishes to purchase a new product or a new service, we will require personal data. For example, we will have to carry out an investigation to review whether we can accept the Subject Entity as a client, or whether we can provide the Subject Entity with a loan. To that end, we can collect data from you (as an individual) such as your name and contact information, date of birth, citizenship, government issued identification, financial information (such as your net worth and income) and banking information. We may also collect credit, financial and identity information from credit reporting agencies, references and persons with whom you have a financial relationship. We may also collect personal data from government registries (inside and outside of the United States) as necessary to satisfy our legal and regulatory obligations under anti-money laundering, terrorist financing or similar laws.
b. To maintain the relationship with you and to execute orders
If you are an individual associated with a Subject Entity, we want to provide you with quality service. For that purpose, we process personal data. We will use your name and address details, for example, to maintain contacts with you. Furthermore, we need your name to be able to execute payment orders. We may also disclose your name to others, e.g. in the context of payment transactions.
c. To protect your individual personal interests as well as our own
To protect your personal interests as well as our own and the security and integrity of the financial sector, we may process personal data. For instance, to combat or investigate fraud. For this purpose, we may consult, and enter personal data in, the incident registers and alert systems of the financial sector. Furthermore, we may also for this purpose consult public sources such as public registers, newspapers and the Internet.
d. For purposes of development and improvement of our products and services
In order to be able to continue to provide you, a Subject Entity, with quality service, we are constantly developing and improving our products and services. In some cases, this may involve the processing of personal data, for example if you have a question about a product.
e. For promotional and marketing purposes
We may process your personal data for promotional or marketing purposes. For example, to inform you about a new product that may be of interest to you, or to better anticipate your wishes. If you do not wish to be contacted for commercial purposes, please notify the Rabobank location that you do business with.
f. Conclusion and execution of agreements with suppliers and corporate clients
If you as an individual have business contacts with Rabobank, we may process your personal data. For example to be able to ascertain that you are authorised to represent your company. Or to grant you access to our offices.
g. To perform statutory obligations
We are required by certain national and international laws and regulations to collect data about you. For example we are sometimes required to initiate a (further) investigation if you have certain assets or in the event of an unusual transaction in your account. Furthermore, we might be required to ascertain who the ultimate beneficial owner (UBO) is of a company with which we have a relationship. Laws and regulations may also require us to disclose data about you to a government or regulatory body inside or outside of the United States. In addition, based on our duty of care, we are required to process personal data whenever there is cause to do so.
h. For purposes of our operations
As a financial service provider, it is important to us, and necessary, to have a good overview of our client relations. That includes knowing whether you collaborate with other parties that may pose a risk. To obtain such overview, and to take measures, we process personal data, e.g. in order to assess our risk when providing a loan and to decide whether we wish to take out insurance in that respect.
i. For archiving purposes
We do not collect more personal data than is necessary for the purposes set forth above. If we do not store the data for those purposes, we may nonetheless do so for archiving purposes. That means that they will only be used for legal proceedings, or for historic, statistical or scientific purposes.
4. Does Rabobank also process sensitive data?
Sensitive data are special types of personal data, for example data concerning physical or mental health, criminal data or racial or ethnic data
Rabobank participates in incident registers and alert systems for the financial sector, and may process data concerning criminal records for that purpose. The purpose of an incident register or alert system is to protect the interests of financial institutions and their clients, e.g. by detecting fraud. Furthermore, we will process sensitive data only if so required by law, with your consent, or at your request. If you request us to record sensitive data about you, or if you disclose such data yourself, we will only process them if that is necessary for our services.
5. How does Rabobank treat my personal data?
The files containing your persona data will be maintained at the offices of the Rabobank division that you do business with or electronically on its servers, serves belonging to an entity within the Rabobank Group or the servers of service providers.
Your personal data are stored carefully and no longer than necessary for the purpose for which they were processed. Within Rabobank, your personal data can be used only by employees who require access to such data for the performance of their duties. Our employees are subject to a confidentiality obligation. If we wish to use data for a purpose other than that for which they were originally processed, then we may only do so if the two purposes are closely related. Your personal data may also be shared between various Rabobank divisions and subsidiaries, but only if this is reconcilable with the purpose for which the personal data were collected and if this is compliant with other requirements following from applicable privacy laws and regulations. We sometimes engage third parties to edit personal data, e.g. a printer who carries out a client mailing for us and prints name and address details on envelopes. We can engage third parties only if this fits the purpose for which we have processed your personal data, e.g. for promotional and marketing purposes. In addition, such third party may only obtain our order if he has demonstrably taken appropriate security measures and warrants confidentiality. Your personal data may also be shared with third parties that we engage in our operations or the provision of our services (for example, data hosting, data processing, processing of payment transactions and similar services). Some of these third parties may be located outside of the United States. Your personal data may, both during and after processing, be subject to investigation by competent national authorities in the countries where such data are located for purposes of processing. Your personal data will not be sold or hired out.
6. Can I view the personal data that Rabobank processes about me?
Yes, you may request a summary of the personal data processed about you from the Rabobank location that you do business with.
If you feel that your personal data have been processed incorrectly or incompletely, or if you feel that such processing was unnecessary, then you can file a request for editing, supplementation or removal your personal data with the Rabobank location that you do business with.
7. Who can I turn to if I have a question or a complaint?
If you have any questions or complaints about Rabobank’s processing of personal data, please contact your Relationship Manager.