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DAILY BANKING
As a trusted companion, the protection of your personal data is important to the BNP Paribas Group. We have enhanced this
Privacy Notice by being more transparent on the following information on:
We take the protection of your personal data very seriously; accordingly, the BNP Paribas Group has adopted strong principles
in its Personal Data Protection Charter available at BNP Paribas - Personal Data Privacy Charter (group.bnpparibas).
BNP Paribas Fortis SA ("We"), as controller, through our brands (BNP Paribas Fortis, Fintro and Hello Bank!) are responsible
for collecting and processing your personal data in relation to its activities.
Our business is to help all our customers – individuals, entrepreneurs, small and medium-sized enterprises, large companies
and institutional investors – in their day-to-day banking activities and in achieving their projects thanks to our financing,
investment, savings and insurance solutions.
As a member of an integrated banking-insurance Group in collaboration with the various entities of the Group, we provide our
customers with a complete range of financial and insurance products and services.
The purpose of this Privacy Notice is to explain how we process your personal data and how you can control and manage them.
Further information may be provided where necessary at the time of collection of your personal data.
This Privacy Notice applies to you if you are ("You"):
When you provide us with personal data related to other people, please make sure that you inform them about the disclosure of
their personal data and invite them to read this Privacy Notice.
You have rights which allow you to exercise real control over your personal data and how we process them. We draw your attention to the fact that these rights may be limited where regulations so provide. This is the case with the regulations relating to the fight against money laundering and the financing of terrorism, which prohibit us from allowing you to exercise your various rights with regard to your personal data processed for this purpose.
If you wish to exercise the rights listed below, please submit a request by post addressed to BNP Paribas Fortis SA – Data Privacy Office – 1GA2U, Montagne du Parc/Warandeberg 3, 1000 Brussels or via Easy Banking Web or app1, with a scan/copy of your identity card. You can also call the Easy Banking Centre or visit one of our branches.
If you have any questions relating to our use of your personal data under this Privacy Notice, please contact our Data Protection Officer at the following address BNP Paribas Fortis SA – Data Privacy Office – 1GA2U, Montagne du Parc/Warandeberg 3, 1000 Brussels or by sending us an e-mail to mailto:privacy@bnpparibasfortis.com.
2.1. You can request access to your personal data
You can directly access some data through your client account on our Easy Banking Web website or via the Easy Banking App mobile application.
If you wish to have access to your personal data, we will provide you with a copy of the personal data you requested as well as information relating to their processing.
2.2. You can ask for the correction of your personal data
Where you consider that your personal data are inaccurate or incomplete, you can request that such personal data be modified or completed accordingly. In some cases, supporting documentation may be required.
2.3. You can request the deletion of your personal data
If you wish, you may request the deletion of your personal data, to the extent permitted by law.
2.4. You can object to the processing of your personal data based on legitimate interests
If you do not agree with a processing activity based on a legitimate interest, you can object to it, on grounds relating to your particular situation, by informing us precisely of the processing activity involved and the reasons for the objection. We will cease processing your personal data unless there are compelling legitimate grounds for doing so or it is necessary for the establishment, exercise or defence of legal claims.
2.5. You can object to the processing of your personal data for commercial prospecting purposes
You have the right to object at any time to the processing of your personal data for commercial prospecting purposes, including profiling, insofar as it is linked to such prospecting.
2.6. You can suspend the use of your personal data
If you question the accuracy of the personal data we use or object to the processing of your personal data, we will verify or review your request. You may request that we suspend the use of your personal data while we review your request.
2.7. You have rights against an automated decision
As a matter of principle, you have the right not to be subject to a decision based solely on automated processing based on profiling or otherwise that has a legal effect or significantly affects you. However, we may automate such a decision if it is necessary for the entering into or performance of a contract with us, authorised by regulation or if you have given your consent. In any event, you have the right to challenge the decision, express your views and request the intervention of a competent person to review the decision.
2.8. You can withdraw your consent
If you have given your consent to the processing of your personal data, you can withdraw this consent at any time.
2.9. You can request the portability of part of your personal data
You may request a copy of the personal data that you have provided to us in a structured, commonly used and machine readable format. Where technically feasible, you may request that we transmit this copy to a third party.
2.10. How to file a complaint with the Data Protection Authority?
In addition to the rights mentioned above, you may lodge a complaint with the competent supervisory authority, which is usually the one in your place of residence. In Belgium, this is the Data Protection Authority.
In this section we explain why we process your personal data and the legal basis for doing so.
3.1. Your personal data are processed to comply with our various regulatory obligations
Your personal data are processed where necessary to enable us to comply with the regulations to which we are subject,
including banking and financial regulations.
3.1.1. We use your personal data to:
3.1.2. We also process your personal data for anti-money laundering and countering of the financing of terrorism purposes
As part of a banking Group, we must have a robust system of anti-money laundering and countering of terrorism financing (AML/TF) in each of our entities managed centrally, as well as a system for applying local, European and international sanctions.
In this context, we are joint controllers with BNP Paribas SA, the parent company of the BNP Paribas Group (the term "We" in this section also includes BNP Paribas SA).
The processing activities performed to meet these legal obligations are detailed in appendix 1.
3.2. Your personal data are processed to perform a contract to which you are a party or pre-contractual measures taken at your request
Your personal data are processed when it is necessary to enter into or perform a contract to:
3.3. Your personal data are processed to fulfil our legitimate interest or that of a third party
Where we base a processing activity on legitimate interest, we balance that interest against your interests or fundamental rights
and freedoms to ensure that there is a fair balance between them. If you would like more information about the legitimate
interest pursued by a processing activity, please contact us using the contact details provided under section 2 "HOW CAN YOU CONTROL THE PROCESSING ACTIVITIES WE DO ON YOUR PERSONAL DATA?” above.
3.3.1. In the course of our business as a bank-insurer, we use your personal data to:
3.3.2. We use your personal data to send you commercial offers by electronic means, post and phone
As part of the BNP Paribas Group, we want to be able to offer you access to the full range of products and services that best
meet your needs.
Once you are a customer and unless you object, we may send you these offers electronically for our products and services and those of the Group if they are similar to those you have already subscribed to.
We will ensure that these commercial offers relate to products or services that are relevant to your needs and complementary to those you already have to ensure that our respective interests are balanced.
We may also send you, by phone and post, unless you object, offers concerning our products and services as well as those of the Group and our trusted partners.
3.3.3. We analyse your personal data to perform standard profiling to personalize our products and offers
To enhance your experience and satisfaction, we need to determine to which customer group you belong. For this purpose, we build a standard profile from relevant data that we select from the following information:
Unless you object, we will perform this customization based on standard profiling. We may go further to better meet your needs, if you consent, by performing a tailor-made customization as described below.
3.3.4. We record electronic communications data
In addition to recordings of electronic communications permitted or required by law or to which you have consented, we may record electronic communications to which you are a party, including traffic data, in the course of lawful business transactions in order to:
We retain records of electronic communications for as long as required or permitted by law, including for the period in which a dispute relating to those communications may arise.
This applies to both telephone conversations and electronic communications (such as e-mails, SMS, instant messaging or other similar technology) that you have with our call centre, (independent) branches, private banking and business centres, dealing rooms or one of our representatives.
3.4. Your personal data are processed if you have given your consent
For some processing of personal data, we will give you specific information and ask for your consent. Of course, you can
withdraw your consent at any time.
In particular, we ask for your consent for:
You may be asked for further consent to process your personal data where necessary.
We collect and use your personal data, meaning any information that identifies or allows one to identify you. Depending among others on the types of product or service we provide to you and the interactions we have with you, we collect various types of personal data about you, including:
We may collect sensitive data such as health data, biometric data, or data relating to criminal offences, subject to compliance with the strict conditions set out in data protection regulations.
We collect personal data directly from you; however, we may also collect personal data from other sources.
We sometimes collect data from public sources:
We also collect personal data coming from third parties:
6.1. With BNP Paribas Group's entities
As a member of the BNP Paribas Group, we work closely with the Group's other companies worldwide. Your personal data may therefore be shared between BNP Paribas Group entities, where necessary, to:
6.2. With recipients outside the BNP Paribas Group and processors
In order to fulfil some of the purposes described in this Privacy Notice, we may, where necessary or provided for in our services, share your personal data with:
In case of international transfers originating from the European Economic Area (EEA) to a non-EEA country, the transfer of your personal data may take place. Where the European Commission has recognised a non-EEA country as providing an adequate level of data protection, your personal data may be transferred on this basis.
For transfers to non-EEA countries where the level of protection has not been recognized as adequate by the European
Commission, we will either rely on a derogation applicable to the specific situation (e.g., if the transfer is necessary to perform our contract with you, such as when making an international payment) or implement one of the following safeguards to ensure the protection of your personal data:
To obtain a copy of these safeguards or details on where they are available, you can send us a request using the contact details provided under section 2 “HOW CAN YOU CONTROL THE PROCESSING ACTIVITIES WE DO ON YOUR PERSONAL DATA?”.
For more information on retention periods, see annex 3.
In a world where technologies are constantly evolving, we regularly review this Privacy Notice and update it as required.
We invite you to review the latest version of this document online, and we will inform you of any significant amendments through our website or through our standard communication channels.
We are part of a banking Group that must have a robust anti-money laundering and countering the financing of terrorism
(AML/CFT) program at entity level, managed at a central level, an anti-corruption system, as well as a mechanism to ensure
compliance with international Sanctions (this concerns all economic or trade sanctions, including all laws, regulations, restrictive measures, embargoes, and asset freezing measures that are enacted, governed, imposed, or enforced by the French Republic, the European Union, the U.S. Department of the Treasury’s Office of Foreign Assets Control, and any competent authority in the territories where we are established).
In this context, we act as joint controllers together with BNP Paribas SA, the parent company of the BNP Paribas Group (the
term “we” used in this section therefore also includes BNP Paribas SA).
For AML/CFT purposes and to comply with international Sanctions, we carry out the processing operations listed hereinafter to comply with our legal obligations:
In this context, we make use of:
We may need to process special categories of data or criminal data as the purpose is combatting money laundering and terrorist financing.
We carry out these checks when you enter into a relationship with us, but also throughout the relationship we have with you,
both on yourself and on the transactions you carry out. At the end of the relationship and if you have been the subject of an
alert, this information will be stored in order to identify you and to adapt our controls if you enter into a new relationship with a BNP Paribas Group entity, or in the context of a transaction to which you are a party.
In order to comply with our legal obligations, we exchange information collected for AML/CFT, anti-corruption or international
Sanctions purposes between BNP Paribas Group entities. When your data are exchanged with countries outside the European Economic Area that do not provide an adequate level of protection, the transfers are governed by the European Commission’s standard contractual clauses. When additional data are collected and exchanged in order to comply with the regulations of non EU countries, such processing is necessary to enable the BNP Paribas Group and its entities to comply with both their legal obligations and to avoid local sanctions, which is our legitimate interest.
Some of our personal data processing is fully automated and leads to a decision about you without human intervention. Where this is the case, we will always inform you before you start a fully automated process on our digital channels and we will explain the underlying logic behind the automated decision and its consequences.
In this annex, you will find an explanation of the processing operations that involve an automated decision about you. We will
supplement it if additional automated decisions are made in our processing.
In order to make this decision in an automated way, we base ourselves :
We make sure that the data we use is as up to date as possible and we re-evaluate your creditworthiness profile at least once a month, taking into account your then current loans.
The system will automatically determine whether the loan corresponds to your needs and whether you have sufficient
repayment capacity to meet your commitments.
The decision models on which the decision is based, are based on the combination of your creditworthiness and your ability to repay, as well as your risk profile as determined by us (e.g. based on statistical models that take into account any past defaults).
The models are adapted to the customer's profile and the purpose of the loan and are review regularly.
The automated decision system will generate one of the below responses:
You can stop the process at any time and contact your usual advisor or through one of the "contacts" link that are made
available through our digital channels. Our staff will be able to provide you with further information and advice.
Macro purpose | Retention period |
Management of our buildings and agencies | The data stored in our visitor register is kept for 6 months from the date of collection. Video recordings are kept for 1 month from the moment they are made. Security incident reports are kept for 10 years from the time they are closed. |
Business development and analytical models for commercial purposes |
Personal data related to prospects is kept for a maximum of 3 to 12 months from the time of collection. Data collected for our analytical models is kept for 10 years from the date of collection. |
Customer relationship management for commercial purposes and fraud prevention |
The data collected in the context of commercial management (for example the minutes of exchanges and emails) are kept for a maximum of 17 years from the end of the relationship. |
Provision of services and/or products | Data related to a product: transactions, securities, cheques and invoices are kept for 20 years from their issue. Contracts are kept for 20 years from the end of the contract. Information relating to safe deposit box access and cards information as well as cheque receipts, are kept for a maximum of 11 years. |
Management of credit granting | The credit profile drawn up at the time of a loan application shall be kept for 20 years from the closure of the loan. The documents with contractual value linked to a loan/security are kept for 20 years from the end of the loan/security. |
Management of our investment products |
As part of our MIFID II obligations, investment profiles and related telephone and electronic exchanges are kept for 11 years. |
(dernière mise à jour le 25 janvier 2022)
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