1. Your Privacy

At Vidanova Bank N.V. (hereafter ‘Vidanova’ or ‘we’, ‘our’, ‘us’), we understand that your personal information is important for/to you. This Privacy Statement explains what personal data we collect, record, store, use and how we safeguard your privacy when processing your personal data.

2. Why we collect:

We use your personal information, which can be defined as personally identifiable information, to help make our organization and our services as effective, reliable and efficient as possible. We may use your personal information for the conclusion and also the execution of agreements and or forms, for example if you want to open an account with us or take out a (mortgage) loan. This also applies when we provide services to you, for example in the context of payment services.  We may collect your personal information for the following purposes:

• verify your and your spouse’s identity;
• understand your interests and offer you services and products that might be fitting your needs;
• comply with regulatory and legal requirements including but not limited to the anti-money laundering and counter terrorist financing laws;
• investigate possible trends, problems, causes of errors and risks; this way we can handle complaints and prevent damages;
• detect and prevent fraud or suppressing any other form of financial abuse;
• respond to foreign court orders, warrants or other demands and or requests which we may assess as valid at our sole discretion, or to comply with rules of local or foreign court;
• collect debts or enforce you to an obligation towards us.

If you are a representative of your company or your company has or wants to engage in any services we provide, we may use the personal information of the contact person, shareholder, director and ultimate beneficial owner of this company, for the same purpose as mentioned above. In certain situations we do not ask for your consent. This is the case if we require your personal data to comply with the law, if a legitimate interest exists, or if this is necessary in the context of the contract that we conclude with you.

3. What we collect:

• your name, address, telephone number, nature of your business or occupation and date of birth, all of which may be required by law;
• government identifiers, such as a valid driver’s license, ID card (“Sedula”) or passport. In addition we might also request a recent utility bill in order to verify your name and address;
• transactions you have made with or through us, including payment history, account activity and how you intend to use the account or service and the source of any incoming funds or assets
• your annual income, assets and liabilities and credit history;
• information about third parties such as your spouse if you are applying for certain services, where this information is required by law;
• information about beneficial owners, intermediaries, business partners, shareholders and other parties, which is required by law.

4. Marketing

We may use your personal information, for example your telephone, mobile and e-mail address, for marketing purposes, for example to contact you about our products and services. You agree that we may share information with you about or from third parties that we select for this purpose, only if permitted by law. This consent is not a requirement for conducting business with us; so you may withdraw your consent for this purpose any time by unsubscribing for marketing emails through our website. We also use social media channels for marketing purposes. For more information about the use of cookies, similar technologies and your settings, please see our Cookie Statement. Your consent for us to use your personal information will also apply to any company that is part of the Vidanova Group and to those that may form part of the Vidanova Group in the future, for the purpose of marketing. Your consent hereto may also be withdrawn at any time.

5. Third parties:

To provide you with the best possible services and to remain competitive in the market, we may share certain personal data with third parties relevant to the services that we provide. These are including but not limited to:

• Third parties for the purpose of preventing fraud and financial criminal abuse;
• Third parties like competent (public) authorities, supervisory and judicial authorities we engage with in order to comply with regulatory and legal requirements;
• Third parties engaged to process certain payment and payment methods cash withdrawal transactions, this may require us to provide information about clients or their representatives with other financial institutions;
• Third parties like business partners, other financial institutions or entities involved in payment transactions or investments;
• third party service providers authorized to process your personal data including but not limited to communication service providers and other suppliers we outsourced certain services to.

Third-Party tools and features:

Our website(s) utilize advanced third-party tools and features, including a text-to-speech (TTS) feature powered by ReadSpeaker and a chatbot for guided assistance.

• Text-to-Speech: This functionality allows visitors to have website content read aloud.

No personal data is collected or processed by the TTS feature.

• Chatbot: Our chatbot, “Genie,” operates using predefined scripts with button-based navigation. It is designed to provide quick answers and guide users through our services.

The chatbot does not collect, store, or process any personal information.

These tools are implemented to improve your experience and make our website(s) more accessible and user-friendly.

We may be obliged to provide personal data to these third parties, but we are not responsible for how these third parties handle your personal data. May it be necessary for us to transfer your personal data to a recipient in another country jurisdiction as of ours, we will ensure that the information is transferred according to the applicable law. For the purposes described in this Policy we may also share your personal data with any company belonging to the Vidanova Group.

6. How long we keep your personal information:

The retention period of your personal information can vary from a few months to several years depending on the applicable legislation. As soon as your personal data is no longer needed, we delete the data or make them anonymous or remove them in accordance with law and legislation.

7. How your personal information is protected:

To maintain the confidentiality and integrity of your personal data and how it is processed, we take relevant technical and organizational measures in a manner that ensures appropriate security of personal information, including but not limited to protection against unauthorized or unlawful processing such as against malicious hackers, accidental loss, and destruction and/or damage.  Your personal data will be accessed by the Bank’s employees who have a legitimate purpose to use your information. The Bank’s employees are obliged to keep your data confidential and are not allowed to share your personal data without (your) authorization.

8. What can you do:

You have the right to:

• request personal information or copies of the information we have collected from you;
• request the sources your personal data has been collected from;
• request us to remove your personal data any time; take into account that this will not be possible in all cases and we are not obliged to honor this request if by law the personal data must be retained for longer periods;
• get your personal data and reuse it for your own purposes; this is called data portability.
• request us to remove your consent any time;
• ask us to change your personal data if this is not correct;
• request us to stop sending you customized marketing communications or unsubscribe to receive offers and newsletters any time through our website;
• file a complaint with the local data supervisory authority.

9. Our Group and what we share

We may share your personal information within the Vidanova Group for specific purposes. We may do this for internal administrative purposes (such as optimizing data quality), to improve our services to you, to fulfil a legal obligation, to enable us to comply more effectively and efficiently with the law, or to fulfil our duty of care. In every case, we first check whether sharing your personal data is permitted within the legal parameters.

10. Other

We preserve the right to change this policy from time to time at our sole discretion. We will not change anything about your rights under this policy without your written consent, unless it has do to with a change in legislation. The amended policy will be published on our website, it is available at our branch and upon request we can send it to your e-mail address.

For complaints, possible breach, questions or any remarks about this Privacy Statement you can contact us at [email protected] or reach us by our telephone number +59997329000.