• Anti-money laundering program
• Privacy Statement

Your PRIVACY is important to us

Transparency has always been a core value of Anadolubank N.V. and this extends to how we use your data.

Anadolubank N.V., being an EU financial Institution, is obliged to comply with the EU General Data Protection Regulation 2016/679 (GDPR).

The General Data Protection Regulation (GDPR) only allows the processing of personal data if one or more conditions are met; these are known as a lawful basis for processing. Anadolubank N.V. will only process your personal data for the reasons it was provided for, and only where there is a lawful basis for processing allowing this.

We have our Personal Data Protection Policy in compliance with the privacy laws and regulations, and Anadolubank N.V. privacy statement explains why we collect personal data, how we process, store and maintain them, accordingly.

Our privacy statement is for all existing and prospective clients including retail and corporate customers.

What is personal data?

Personal data means any information relating to an individual who can be directly or indirectly identified by reference to the information. A wide range of information constitutes personal data, including names, contact information, identification numbers such as social security numbers, and location data or online identifiers often referred to as ‘cookies’ for example. This applies to both automated information and to information included in manual filing systems.

Why we need your personal data?

For the following carefully selected purposes we need to have your personal data.

• To decide whether or not to enter into a customer relation with you;
• To enter into and maintain contracts with you and other customers;
• To ensure money can be paid and received;
• To analyse personal information for investigations or for other security reasons;
• To comply with legislation or court orders, which Anadolubank Nederland N.V. is subject to;

What personal information we are collecting?

• Data that are necessary to contact you: like home address, telephone number and e-mail address.
• Your BSN or tax number; the number you have been given by the government to identify who you are.
• Contractual information; information about the products and services we provide to you.
• Transaction information; information about when a payment has been made, to whom you have paid or from whom you have received a payment, and what the balance is on your account.
• Information obtained from call recordings and camera surveillance; we may record and store telephone conversations. We use the recordings to combat fraud, due to legal obligations or for reasons of evidence. We also use them to improve the quality of our services.                
• For security reasons, camera surveillance takes place in and near our offices.
• Personal information; information about who you are, such as your first and last name, gender, date, country and place of birth, nationality.
• Information about your financial situation and your products; think of bank account numbers and the products you have with us, information about your financial situation, your risk profile when you invest and pay slips.
• Administrative information; Registration numbers and administrative reports.
• Information we receive from other parties: For example, data from the land register, the trade register of the Chamber of Commerce, from public sources such as the insolvency register, trade information bureaus, newspapers or the internet.
• Information about the use of our website: Device data (such as device type, operating system, IP addresses). Cookies and usage data about your use of our products and services.
• Information we use for identification and verification: photo of an identity document.

Who do we share data with and why?

We treat all your personal data confidentially and in accordance with the law, even if you are no longer a customer with us. We do not share information with anyone unless:

• We are required by law to share the information. This includes sharing information with Regulatory Bodies like AFM, DNB and the tax authorities and enforcement authorities such as the police.
• We need to share the information in connection with legal proceedings, to obtain legal advice, or to establish, exercise or defend legal rights.
• Sharing the data is required to protect our interests or the interests of someone else (for example, to prevent fraud).
• You yourself give permission for the sharing of the data.

We share data with other companies because they perform administrative or other services on behalf of Anadolubank Bank N.V. When a third party processes your personal data on our behalf, we ensure that they follow our instructions to protect your personal data. Third parties are required to sign agreements in which they commit themselves to safeguard your personal data and agree to only use the data to provide services to us included in the agreement.

How you can access your personal data?

In order to have information on your personal data that we are processing, please send a request to the following address with a valid proof of your identity (copy of your ID card or passport)

To the attention of: Data Protection Officer

Anadolubank Nederland N.V.

De Boelelaan 7, Officia 1,

1083HJ Amsterdam Nederland

What are the client’s rights?

Your personal data is protected by legal rights and GDPR entitles you to a number of rights in relation to your personal data.

Anadolubak N.V. uses your personal data to be of service to you. We handle this very carefully. Of course you remain in control of this information.

We would like to point out your rights:

- The right to be informed

Individuals or data subjects as they are referred to under data privacy legislation, have the right to be informed about the collection, use and sharing of their personal data. Organizations must provide individuals with certain information at the time personal data is collected. This Privacy Statement provides you with the information you are entitled to and we are required to give you.

You may make a request by electronic means (for example through by e-mail), and unless otherwise requested by you, the information will be provided in a commonly used electronic form. When you apply, please use the following information use and explain to us:

• What are you applying for?
• What is the reason for the request?
• Which data should it be applied to?

Apply by e-mail: dataprivacy@anadolubank.nl

Good to know: before we grant access to your personal data, we ask you to verify your identity. In this way we want to protect you against identity theft and financial crime. We may also ask some questions to make sure we have understood your request.

- The right of access

You have the right to access your data to establish what it is being used for and verify the lawfulness of any processing. Before providing access to your personal data we will ask you to verify your identity to protect you from identity theft and financial crime. We may also need to ask you some questions to ensure we have understood your request correctly

- The right of rectification (correcting mistakes and inaccuracies)

It is important that any personal data we use is accurate, up to date, and relevant. To ensure that your data is correct you have the right to access, correct and/or update your personal data at any time. If you think your data is incorrect or incomplete and you wish to correct your data or privacy settings, please contact us.

- The right of data portability

You have the right to receive your personal data in a structured, commonly used and machine-readable format. You may ask us to transfer your personal data to you or another company as long as the request is in the scope of the personal data that we process automatically with your consent or on the basis of an agreement with you. We will transfer your personal data as far as it is technically possible and in accordance with the legislation.

- The right to restrict processing data

You have the right to request the restriction of the processing of your personal data for a limited period and under certain circumstances. For example, this could apply if you feel that your personal data held by Anadolubank N.V. is inaccurate, has not been processed lawfully, or is no longer needed for the purposes it was originally collected for. Anadolubank N.V. has the right to store your personal data while your query is investigated.

- The right to object to processing

You have the right to object to the processing of your personal data based on legitimate interests, direct marketing, and processing for historical research and statistical purposes. If you decide to exercise this right, please contact us and we will consider your request; Anadolubank N.V. is legally allowed to continue to process your data if one of the following can be demonstrated:

• Compelling legitimate grounds for the processing, which override your interests, rights and freedoms; or
• Processing is required for the establishment, exercise or defense of legal claims.

- Rights in relation to automated decision making, including profiling

When establishing and conducting a business relationship, Anadolubank N.V. doesn’t make decisions based solely on automated processing, including profiling.

- The right to deletion of your personal data (to be forgotten)

You have right to request that we delete your personal data if:

• Your personal data is no longer needed in relation to the purposes for which was collected;
• You withdraw your consent and there are no other legal bases to process your personal data;
• You object to us processing your personal data for the legitimate interests of Anadolubank N.V.;
• You feel that your personal data is not being processed lawfully;
• Your personal data needs to be deleted to comply with legal requirements.

- The right to complain

Please contact our Data Protection Officer in the first instance, dataprivacy@anadolubank.nl, if you have any concerns with how we have used your personal data.

You also have the right to lodge a complaint directly with the Dutch data privacy regulator, the Dutch Data Protection Supervisory Authority (Autoriteit Persoongegevens) via www.autoriteitpersoonsgegevens.nl/en

How do we determine how long we keep your personal data?

The General Data Protection and Implementation Act (GDPR) does not have specific retention periods for personal data. Other laws may contain minimum retention periods that we must adhere to. Think, for example, of the general administrative obligation for companies (as stated in the Dutch Civil Code), tax legislation or the legislation that applies specifically to financial companies (Financial Supervision Act).

How long we keep personal data varies. This can vary from months to years.

Examples of retention periods at Anadolubank Nederland N.V.

After the end of the retention periods, the personal data will be deleted or anonymized. There are reasons to keep certain personal data for longer. This applies, for example, to our risk management, for security reasons or because of claims, investigations or lawsuits.

If personal data is kept for longer, we take measures to ensure that that data is only used for the purposes for which a longer retention period is necessary.

When personal data is no longer needed for any purposes and we are not required by law to retain it, we will take measures to delete your personal data.