01. Who is legally responsible for the safeguarding of your personal data?

Our company Bank A/S
John Doe str 15,
Canada

We are required to handle (“process”) your personal data securely and otherwise in accordance with the GDPR and if any national legislation requires a higher level of protection for personal data than the GDPR, such stricter requirements are to be complied with. Should you have queries or complaints about the way in which we process your personal data, please see your options here: How do I request support? – Our company Bank A/S Support (help.company). You can also contact Our company’s Data Protection Officer via the contact details above or the following email address: [email protected].

02. What personal data might we process about you and where do we get it from?

We will only collect data about you that is relevant in the context of the relationship which we have with you.

We primarily collect information directly from you. But we will also collect personal data from other sources, which may include other Our company Bank A/S entities, other companies and financial institutions, publicly available sources (e.g. the press, registers of companies, the internet, including social media platforms) and from providers of business-risk screening services, anti-fraud databases, sanctions lists and databases of news articles.

The types of personal data that we process may include:

• Name and contact information
• Records related to our client relationship and relevant services, including data deriving from your usage of our IT platforms and, mobile apps;
• KYC (Know Your Customer) records, such as passport details, social security number, date and place of birth, source of wealth, rationale for use of corporate structures, your employment including whether you are entrusted with a prominent public function, as well as information from adverse media relevant for the relationship.
• Financial information, such as bank account details, specimen signature, income, assets, outgoings, investment objectives, marital status and details of knowledge about financial products and services, risk appetite, capacity for loss, tax status and domicile.
• Biometric data for the purpose of verifying your identity during onboarding.
• Recordings of calls and electronic communication.
• Records of your engagement with our platform, apps, emails, text messages and social media.
• Information on geographical location for the purpose of complying with sanctions and other legal requirements.

03. For which purposes will we use your data and on what legal basis?

We process your personal data with the following purposes:

• For the performance of a contract It may be necessary for us to process your personal data in order to perform a contract with you relating to our financial services, or to act upon at your instructions prior to entering into a contract.
  
  For further details, please refer to your contractual documentation with us.
• For compliance with a legal obligation or acting in the public interest As a licensed bank, we are subject to a number of statutory and regulatory obligations that may require us to collect, store or disclose personal data, such as for anti-money laundering purposes, sanctions or to respond to investigations or disclosure orders from the police, regulators of our group entities, and tax or other public authorities.
• For the purposes of legitimate interests Where necessary, we process your personal data to serve our legitimate interests or those of a third party. Cases where we rely on our legitimate interests to process your personal data includes: Business analysis and development of products and services, including optimisation of platforms experience and customer service; Activities relating to information security and building security, including use of recording Contact information for potential clients before finalising account opening and visitors Recording of telephone lines and monitoring of electronic communications for business and compliance purposes, besides the legal requirements Prevention and detection of fraud, financial crime and market abuse, including on any activity or transaction by end-clients of white-label clients on Our company’s platform Evaluating, bringing or defending legal claims
• On the basis of your consent If we wish to process your personal data in a way not covered by the legal justifications above, we will need your consent. Where you give consent, you are entitled to withdraw it at any time. Note that withdrawing your consent does not render our prior handling of your personal data unlawful, and that it might have an impact on our ability to continue to provide our services in the same way in future.
  
  We rely on your consent for the following purposes: Verifying your identity by the use of biometric data If you are part of the Preferred Broker Program, Our company will share with the Employer certain data pertaining to the Client’s trading activities on Our company’s trading platform. For providing marketing content. For collection of behavioural and statistical data (cookies) from using our websites.
• For compliance with a legal obligation or acting in the public interest As a licensed bank, we are subject to a number of statutory and regulatory obligations that may require us to collect, store or disclose personal data, such as for anti-money laundering purposes, sanctions or to respond to investigations or disclosure orders from the police, regulators of our group entities, and tax or other public authorities.

04. Who is legally responsible for the safeguarding of your personal data?

Where necessary to fulfil your instructions to us and for the other purposes outlined above, we may share information about you with a range of recipients including the following: background screening providers, financial institutions, funds, payment recipients, payment and settlement infrastructure providers, exchanges, regulators, public authorities (including tax authorities), our other group entities and service providers, professional advisers, auditors, insurers and potential purchasers of elements of our business.

We will only disclose information about you as permitted under the contractual terms we have in place with you, the GDPR and client confidentiality obligations. Our company do not under any circumstances sell the collected data to third party.

Please click here to see our categories of recipients of personal data.

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