04 Our group and your personal data

We may share your personal data within our group for specific purposes. We may do this for internal administrative purposes, to improve our services to you, because we are required to do so by law, or to fulfil our duty of care. If, for example, you apply to us for a loan, we need to know whether you have already obtained a loan from one of our subsidiaries. This allows us to gain a more complete picture of your financial situation.

Subsidiaries are also allowed to contact you with offers. In that context, it must be possible for you to tell that the undertaking is affiliated with our group, for instance because our name or logos are used, or because this is clearly stated on the website or in advertising.

Required personal data

If we need personal data from you in order to conclude a contract with you, and you refuse to provide this data even though this is required by law, or these personal data are required for the contract, we will unfortunately not be able to enter into the contract with you. The required personal data is specified in the online forms and other forms we occasionally need you to complete.

Do you want us to remove your personal data from our systems? We are unfortunately unable to remove required or other personal data that we need, for instance for the performance of the contract you have with us, or because we are required to keep this data by law or owing to a legitimate interest of the bank.

Camera images, telephone calls, chat messages and video chat sessions

If you visit a branch of our bank, we may capture images of you on camera. We do this for security purposes. We can also be contacted by telephone, by chat messages or in video chat sessions, for instance for mortgage advice. We may also record your telephone calls, chat messages or video chat sessions with our advisers. We do this for the following purposes:

  • to improve our services, for example so that we can coach or assess the performance of our employees, 
  • owing to a legal obligation, 
  • in order to be able to provide evidence, or 
  • to prevent fraud. 

We handle video and audio recordings with due care. They are subject to the same rules as other personal data. You may exercise your rights, such as your right of access. 

Use of your personal data for direct marketing purposes

If you have previously purchased a product or service from us, we are keen to keep you informed about similar products and services we offer that are suited to your needs. This also applies if you are a visitor to our website. In order to do this properly, we use various sources. These are described below.

  1. The personal data that we received from you in the context of the contract. When you visit our website, we study how you use the website. We do this using your IP address. We can then make you offers that are relevant to you personally. In that case, you must have agreed to the use of cookies and similar technology such as JavaScript. For more information about cookies, please see our Cookie Statement. 
  2. The use of social media depends on the privacy settings you use on social media sites. 
  3. Other sources of information, including public sources. We will always check first whether a public or other source of information can be used reliably. Where applicable, we will check whether you, as a client, have consented to the use of personal data that comes from another party.

You can use the Internet Banking privacy settings (under 'Use of your personal data') to specify whether we may use your personal data to make you relevant offers.

Social Media

We use social media channels to discuss our organisation, products and/or services with clients, users of apps and visitors to the website. We do this so that we can offer useful, relevant information and/or answer questions we receive through social media. We use the internet and social media channels, such as Facebook and Twitter, for this purpose. In addition, we become involved in discussions on these channels and/or we reply to individual, relevant questions and comments from other participants. In such situations, it is of course possible that we record personal data. We will of course process this personal data in accordance with the terms of this privacy statement.