Privacy Statement
Summary Privacy Statement
Your privacy is important to us. We therefore treat your personal data responsibly and carefully. It is essential for us that your information is safe with us. Our employees are bound by strict rules when handling information and our security standards are high. We do not sell personal information to third parties.
Use of your personal data
We process personal data of all our customers and therefore also of you. If you are a contact person for a customer, we also process your personal data. We need your personal data for many reasons. To accept you as a customer, but also to be able to offer products and services. You can think of your contact details, but also of information about your income where necessary. For some legal obligations, we also have to monitor your transactions. If you are no longer a customer of ours, we will destroy your personal data after a certain period of time.
In order to acquire new customers or promote new products or services, we also process personal data. This often involves a limited type of data, such as contact details. If you are not yet a customer, we may process a limited amount of your personal data in order to contact you within a reasonable period of time. We will ask for your permission at that moment.
Viewing, modifying, correcting personal data
We like to be transparent about what we do with your personal data and find it important that they are correct. You can therefore ask us to view, amend, supplement and improve your personal data. If you do not want us to process your personal data, you can object. It is your data, which is why you can also ask us to transfer data to you. The law determines whether we can cooperate with your request.
Provision of personal data to third parties
We use your personal data for our services. Sometimes we provide your personal information to third parties. We only do this if it is necessary to carry out the agreement with you or to keep our business operations efficient. For example, we work with a party that sends mail to our customers on our behalf. We give personal information to that third party in order to do so. We ensure that your personal information is in as good a hands as it is with us.
Recording customer phone calls
We may record the content of telephone conversations with customers. We must do so based on legal retention obligations (see 'Legal obligations') and for training and quality purposes (see 'For training and quality purposes'). We may also record customer telephone calls to protect our legitimate interest in a file if a dispute arises with a customer. Telephone calls made prior to the establishment of the relationship with the customer may also be recorded.
We must also comply with legal obligations to provide information (including personal data). For example, to a regulator or other public body, such as the Tax and Customs Administration. We may also have to provide personal data to foreign regulators or authorities.
Do you want to know exactly what we do with your personal data? Please read all the information in the full Privacy Statement below.
Full Privacy Statement
a. Correction or supplementation of personal data
You may ask Van Lanschot to correct or supplement personal data if they are incorrect or incomplete.
b. Access to personal data
You can ask Van Lanschot to view your personal data and to receive a copy of it. You may also ask us for information on how we process your personal data (such as the purposes of such processing and the categories of personal data).
c. Removal of personal data
You can ask us to remove your personal data. This may be the case, for example, if the personal data are no longer required or if you have withdrawn your consent to the use of the personal data.
d. Objecting to the processing of personal data
You can object to certain processing of personal data. This is only possible if we base a processing on the legal basis of 'legitimate interest' (in section 9. 'What do we process personal data for?' is mentioned if this is the case), if it concerns direct marketing or if the personal data are processed for statistics.
e. Restricting the processing
You can ask us to temporarily suspend the processing of personal data. This may be the case, for example, if, at your request, we examine whether personal data is incorrect or incomplete or if we process personal data without being allowed to do so. You can also ask us if you think you need the data for legal proceedings or if you have objected to the processing.
f. Downloading and transfer of data
You can download payment and securities transactions via online banking and possibly transfer them to a third party.
You can ask your question using the form at the bottom of this page. We will answer your question as soon as possible. There are no costs involved in handling a question, unless the answer is an exceptional burden for us. This would be the case, for example, if you repeat a question repeatedly within a short period of time. We will inform you in advance if we charge a fee.
a. Correction or supplementation of personal data
You may ask Van Lanschot to correct or supplement personal data if they are incorrect or incomplete.
b. Access to personal data
You can ask Van Lanschot to view your personal data and to receive a copy of it. You may also ask us for information on how we process your personal data (such as the purposes of such processing and the categories of personal data).
c. Removal of personal data
You can ask us to remove your personal data. This may be the case, for example, if the personal data are no longer required or if you have withdrawn your consent to the use of the personal data.
d. Objecting to the processing of personal data
You can object to certain processing of personal data. This is only possible if we base a processing on the legal basis of 'legitimate interest' (in section 9. 'What do we process personal data for?' is mentioned if this is the case), if it concerns direct marketing or if the personal data are processed for statistics.
e. Restricting the processing
You can ask us to temporarily suspend the processing of personal data. This may be the case, for example, if, at your request, we examine whether personal data is incorrect or incomplete or if we process personal data without being allowed to do so. You can also ask us if you think you need the data for legal proceedings or if you have objected to the processing.
f. Downloading and transfer of data
You can download payment and securities transactions via online banking and possibly transfer them to a third party.
9. What for do we process personal data?
Van Lanschot processes personal data for various reasons. You can read more about this below.
a. Becoming a customer
Before a person becomes a Van Lanschot customer, we are obliged to investigate the potential customer. We will then consider whether to accept the person as a customer. This is called the customer acceptance survey. The purpose of this investigation is to determine whether there are reasons not to accept an individual as a customer. We also examine whether there are any particularities that we should take into account in our services, such as whether there are any registered debts. We may process personal data for the purpose of this investigation to the extent that we need such data in order to comply with our legal obligation to conduct a customer acceptance investigation.
For the purpose of this investigation, we collect personal data from the customer, such as a copy of proof of identity, personal identification data, personal characteristics, financial data and criminal law data. We also use external sources for this investigation, such as the Land Registry, the Central Credit Information Register and the Internet.
Once a customer has been accepted, we will examine, based on our legal duty of care, whether we can offer the customer a product or service. In particular, we use personal characteristics and financial data for this purpose. We may process personal data for this purpose to the extent that we need these data in order to comply with our statutory duty of care.
We cannot accept a customer and may not offer a product or service if we do not receive the necessary personal data from the customer.
b. Being a customer
We also process the customer's personal data during the relationship with the customer.
In order to be able to have contact with the customer
During the relationship with the customer, we have contact with the customer. For example, by phone (landline or mobile phone), by email, text message, post, via an application (app), by using a chat function on the website or the app, or at the reception of one of our offices. For that contact, we use personal identification information. We may process these personal data to the extent necessary for the execution of the agreement with our customers.
Execution of the agreement
We process personal data in order to fulfil the agreement with the customer. We need personal data, for example, in order to carry out transactions or to advise the customer. Even if there are problems in the relationship with a customer, we can process personal data to find a solution. For example, if a customer is unable to repay a loan, or if a customer has been in the red for too long.
We may use personal identification data, personal characteristics, information about products and services, financial data and communication data for this purpose. We also use data from external sources, such as public registers (e.g. Chamber of Commerce and Land Registry). We may process this personal data to the extent necessary for the execution of the agreement with our customers.
Legal obligations
We process personal data in order to comply with legal obligations. More information about this can be found below.
Transaction monitoring
We are legally obliged to monitor our customers' transactions. We cannot fulfil this obligation without processing financial data and personal identification data.
Legal retention obligations
We are required by law to retain certain personal data. This applies, for example, to information relating to the customer acceptance survey, to investment transactions carried out and telephone calls made and to digital communication with the customer if these could lead to an investment transaction or investment service. Information obligations and requests for information
We may be required by law, on our own initiative or upon request, to disclose personal information about customers to a government agency, tax authority, regulator or court. We must provide information about customers' identity, assets and income from assets to the Swiss Federal Tax Administration regarding the automatic exchange of information in tax matters (also known as Common Reporting Standard). Foreign legislation may also oblige us to provide information to foreign authorities.
For training and quality purposes
We can record the content of telephone conversations with customers for training and quality purposes. Customers are informed in advance. The content of the communication is recorded in order to train and guide our employees in the contact with customers. We may process personal data for this purpose because it is in our justified business interest to improve the quality of telephone services. A customer may object to the processing of personal data on the basis of this interest for personal reasons. You can read more about this in the section 'Right of objection'.
Recording customer phone calls
We may record the content of telephone conversations with customers. We must do so based on legal retention obligations (see 'Legal obligations') and for training and quality purposes (see 'For training and quality purposes'). We may also record customer telephone calls to protect our legitimate interest in a file if a dispute arises with a customer. Telephone calls made prior to the establishment of the relationship with the customer may also be recorded.
c. The relationship between the client and Van Lanschot is or will be terminated
If the relationship with the customer is or will be terminated, we retain collected personal data. This can be done on the basis of Legal storage obligations (see section 9b), for Internal analyses (see section 9f), for the settlement of the agreement and the relationship or to use in the event of any differences of opinion during or after the completion of the relationship. Van Lanschot may process personal data for this purpose because this is necessary to protect its interests in order to have sufficient evidence at the time when a dispute arises with a customer. You may object to the processing of personal data based on this interest for personal reasons. You can read more about this in the section 'Right of objection'. Van Lanschot may also collect new personal data, such as financial data and data from public external sources (Commercial Register, Land Registry, the Central Credit Information Register), for the purpose of processing the agreement and the relationship.
d. For the safety and integrity of the financial sector and the prevention and limitation of fraud
We are required by law to ensure that our business operations are safe and sound. We therefore take measures to limit fraud and crime involving the processing of various personal data. For example, we analyse personal identification and financial data to detect skimming, cybercrime and other forms of fraud or improper behaviour. For example, we record the names and dates of birth of (legal) persons who pose a risk to the safety and integrity of our company.
Another way to ensure a safe and sound financial sector is to carry out fraud investigations into events. For this type of investigation, we can, for example, consult e-mail correspondence with customers, listen to recorded telephone calls and interview employees. It is possible that personal data of customers may be processed in the process. We may use third parties, such as lawyers or forensic accountants, to conduct this investigation.
We may process personal data for this purpose because we are obliged to ensure safe and sound business operations and because it is in the legitimate interest of our customers, the financial sector, our employees and ourselves as a company.
e. For promotion and marketing
Our activities in the field of promotion and marketing consist of acquiring new customers and consolidating the relationship with existing customers.
Recruiting new customers
In order to acquire new customers, we process personal identification data and personal characteristics from external sources and compare them with our customers' personal data. We process personal data of potential customers in order to contact them within a reasonable period of time. We request permission at that time. Consent can easily be withdrawn at any time. Withdrawal of consent has no retroactive effect; data processing up to the time of withdrawal is lawful. We may use personal data with specific permission to inform customers, for example, about products and services or to send newsletters. We also store personal data for a short period of time if the customer has informed us that he is not interested in our services. This enables us to prevent the customer from being contacted anyway. You can read more about this under the heading 'How long do we keep personal data?
Consolidating the relationship with existing customers
Through promotion and marketing, we try to point out new products and services to customers or serve them better. We do this, for example, by means of a commercial on television or an advertisement on social media. But sometimes we do this by means of a personal e-mail or a telephone call. For such marketing activities, we may process personal data, such as personal identification data, personal characteristics, product and service information and electronic identification data. We have a business interest in marketing and promotion, they support our business activities. A customer may object to the processing of personal data on the basis of this interest for personal reasons. You can read more about this in the section 'Right of objection'.
f. Analysis and research
Van Lanschot processes personal data for analysis and research purposes. The purpose of these analyses and surveys is to develop and improve our products and services and to provide our customers with a better service. We also use analyses to predict and prevent problematic debts.
For the development and improvement of products/services and for better customer service
We strive to ensure that our products and services meet the needs of our customers as closely as possible. That is why we regularly develop and improve our products and services. To determine how best to do this, we analyse the use of products and services. Where possible, we do not use personal or anonymous data. If this is not possible, we use personal data that we have received from customers, such as personal identification data, financial data and information about products and services. This allows us to create profiles of our customers. These are automated processing of personal data in which we evaluate certain personal aspects of our customers on the basis of personal data, in particular with a view to analysing or predicting the economic situation, personal preferences, interests, behaviour, location or movements of our customers. We can also use general (statistical) data from external sources, such as public registers (Commercial Register, Land Registry, the Central Credit Information Register), public sources (Internet, newspapers) and research institutes. We may process personal data for this purpose because it is in our and the customer's interest to improve our products and services and to better serve our customer. Customers may object to the processing of personal data based on this interest for personal reasons. You can read more about this in the section 'Right of objection'.
We also conduct customer surveys and interviews for this purpose. This involves processing personal data such as personal identification data and data about products and services. These personal details are processed with the customer's consent. Consent can easily be revoked at any time. Withdrawal of consent has no retroactive effect; the data processing up to the moment of withdrawal is lawful.
For predicting and preventing problematic debts
We process personal data to predict and prevent problematic debts. On the basis of risk parameters, we use personal data to calculate whether a situation of arrears or overstress can arise in the short term. For this purpose, we process personal identification and financial data.
a. Execution of the agreement
For example, your name may be disclosed to another bank in the case of a payment transaction. Conversely, for this reason we may also process personal data of third parties who are not our customers. In the case of international transactions, transaction data is provided to companies that facilitate (international) transfers of funds (e.g. SIC, SWIFT). These companies store personal data in the European Economic Area and the United States. U.S. authorities may request these personal data for counterterrorism purposes.
We also provide personal data to, for example, Card Service Providers such as VISA and Mastercard if you wish to havea credit card through us. We may also transfer personal data to a foreign body or tax authority, for example to reclaim withholding tax on foreign investments, if so agreed with you, or with exemption at source on foreign investments. This may also be the case if you are a participant in an investment vehicle.
b. Business Support
We also use third parties who support us in our business operations and therefore process personal data for us. These parties are called processors. For example, we work together with a third party that prints and sends out to customers daily statements and asset management reports on our behalf. We also sometimes use third parties for customer research. We make agreements with these third parties to ensure that the personal data are adequately protected. We only select this third party after careful examination. We demand that your personal details are also safe with these third parties. We may provide personal data to third parties in support of our business operations because it is in our justified interest to optimise our business operations.
Van Lanschot Kempen (Schweiz) AG
Mittelstrasse 10
PO Box 3078
8034 Zurich