Privacy
Rabobank collects and processes personal information. We wish to inform you about this clearly and transparently. This privacy statement will answer your most important questions about the collection and processing of personal information by Rabobank. This Privacy Statement describes how Rabobank Canada collects and processes your personal information. As set out herein, Rabobank Canada shares information with Rabobank Group, which includes global divisions, for the purposes set out herein. Any reference in this privacy statement to Rabobank refers to Rabobank Group. In this privacy statement we will use certain terms. Below is an explanation of those terms. Personal information Information that alone or in combination with other information identifies you. Examples are your name and address and your income. Processing Any acts that can be performed in relation to personal information. These may include collection, but also storage, use and removal of your data from our records. This privacy statement may be revised from time to time.
Whose personal information is collected and processed by Rabobank?
We collect and process personal information of persons with whom we have, wish to have, or used to have, a direct or indirect relationship. These may include personal information of:
Please note: if your business or organisation provides us with personal information of employees, you are under the obligation to inform your employees thereof. You may provide them with this privacy statement, so that your employees can see how we treat their personal information.
We also collect and process information of third parties who may be associated with any of the persons listed above. We may collect and process information of these third parties to protect your interests as well as our own (e.g. for purposes of fraud control).
What information does Rabobank process and for what purpose?
We process personal information for the following purposes:
(a) To be able to enter into a relationship with you
If you wish to become a Rabobank client, or if you wish to purchase a new product or a new service, we will require personal information. For example, we will have to carry out an investigation to review whether we can accept you as a client, or whether we can provide you with a loan, which will include verifying your identity and your current and ongoing creditworthiness and compliance with certain legal and regulatory requirements. To that end, we may collect one or more of the following categories of personal information from you: name, contact information, date of birth, citizenship, government issued identification, financial information (such as your net worth and income) and banking information. We may also collect credit, financial and identity information from credit reporting agencies, references and persons with whom you have a financial relationship. We may also collect personal information from government registries (inside and outside of Canada) as necessary to satisfy our legal and regulatory obligations under anti-money laundering, terrorist financing or similar laws.
(b) To maintain the relationship with you and to execute orders
If you are a Rabobank client, we want to provide you with quality service. For that purpose, we process personal information. We will use your name and address details, for example, to maintain contact with you. We may also use any personal information that you provide to us in the course of managing our relationship with you.
We may make (audio and chat) recordings of our verbal and written exchanges with you for the purpose of monitoring the quality of our customer services, and to the extent relevant for the purpose of combating criminal activities and complying with any legal obligations.
(c) To protect your interests as well as our own
We may process your personal information to protect your interests as well as our own and the security and integrity of the financial sector. For example we may process your information, to combat or investigate fraud. For this purpose, we may consult, and enter the following categories of information in, the incident registers and alert systems of the financial sector: name, contact information, date of birth, citizenship, government issued identification details, financial information, credit, financial and identity information, references and persons with whom you have a financial relationship and personal information from government registries.
Furthermore, for this purpose, we may also consult public sources such as public registers, newspapers and the Internet for the following categories of personal information: adverse news information, name and contact information, financial and identity information and history.
(d) For purposes of development and improvement of our products and services
In order to be able to continue to provide you with quality service, we are constantly developing and improving our products and services, for example if we are addressing a question you have about a product. This may involve the processing of the following categories of personal information: name, contact information, date of birth, citizenship, government issued identification details, financial information, credit, financial and identity information, references and persons with whom you have a financial relationship and personal information from government.
(e) For promotional and marketing purposes
We may process your personal information for promotional or marketing purposes. For example, we may process your personal information (as stated in section 2(a) above) to inform you about a new product that may be of interest to you, or to better anticipate your wishes.
If you do not wish to be contacted for commercial purposes, please notify the Rabobank location that you do business with or use the unsubscribe function included in our emails to you.
(f) Conclusion and execution of agreements with suppliers and corporate clients
If you have business contacts with Rabobank, we may process your personal information. For example, we may process your personal information to be able to ascertain that you are authorised to represent your company, or to grant you access to our offices.
(g) To perform statutory obligations
We are required by certain national and international laws and regulations to collect data about you. For example we are sometimes required to initiate a (further) investigation if you have certain assets or in the event of an unusual transaction in your account. Furthermore, we might be required to ascertain who is the ultimate beneficial owner (UBO) of a company with which we have a relationship. Laws and regulations may also require us to disclose data about you to a government or regulatory body inside or outside of Canada.
(h) For purposes of our operations
As a financial service provider, it is important to us, and necessary, to have a good overview of our client relations.
That includes knowing whether you collaborate with other parties that may pose a risk to our operations. To obtain such overview, and to take measures, we process the following categories of personal information, in order to comply with legal obligations, assess our risk when providing a loan and to decide whether we wish to take out insurance in that respect: contact information, financial information (such as your net worth and income), banking information, credit, financial and identity information from credit reporting agencies, references and persons with whom you have a financial relationship and personal information from government registries.
(i) For archiving purposes
We do not collect more personal information than is necessary for the purposes set forth above. If we do not store the data for those purposes, we may nonetheless do so for archiving purposes, meaning that we will only use this information for legal proceedings, or on an anonymized basis for historic and/or statistical purposes.
Does Rabobank process “sensitive data”?
Canada’s federal and provincial privacy commissioners consider certain categories of information to be typically sensitive such as information concerning physical or mental health, criminal data or racial or ethnic data (referred to herein as "sensitive information").
Rabobank participates in incident registers and alert systems for the financial sector, and may process data concerning criminal records for that purpose. The purpose of an incident register or alert system is to protect the interests of financial institutions and their clients, e.g. by detecting fraud.
Furthermore, we will process sensitive information only if so required by law, with your consent, or at your request. If you request us to record sensitive data about you, or if you disclose such data yourself, we will only process such information if it is necessary for purposes set out herein.
How does Rabobank treat my personal information?
The file containing your personal information will be maintained at the offices of the Rabobank division that you do business with or electronically on its servers, servers belonging to an entity within the Rabobank Group or service providers' servers. Your personal information is stored carefully and no longer than necessary for the purpose for which it was collected. Within Rabobank, your personal information can be used only by employees who require access to such data for the performance of their duties. Our employees are subject to a confidentiality obligation. Your personal information may be shared between the various Rabobank divisions and subsidiaries, but only to carry out the purposes for which the information was collected.
We sometimes collect personal information through technological means, such as by using third- party online applications. We also sometimes engage third parties to vet your address. We may engage third parties to assist us in carrying out the purpose for which we have collected your personal information, e.g. for promotional and marketing purposes. Rabobank imposes contractual obligations on these third parties to safeguard your information using appropriate measures
Your personal information may also be shared with third parties that we engage in our operations or the provision of our services (for example, data hosting, data processing, payment transaction processing and similar services). Our operations, as well as those of some of these third parties, may be located outside of Canada or your local jurisdiction, including in the United States of America and the Netherlands.
As a result, your personal information may be transferred to and processed outside your local jurisdiction, and it may be accessed by the courts, law enforcement and national security authorities in those jurisdictions..
Your personal information will not be sold or hired out.
The collection and processing of personal information
The key Rabobank Group entities that process your data, and the jurisdictions in which such information is processed, are:
Personal information may be shared within Rabobank Group to the extent that this is permitted by law. When sharing data within Rabobank Group, we comply with applicable regulatory requirements.
Does Rabobank disclose my personal information to third parties?
Other than the transfer of your information to service providers, the disclosure of your information among the Rabobank affiliates as described herein, and the disclosure as required by law, Rabobank does not disclose your personal information to third parties.
Requesting the personal information that Rabobank processes about me?
Yes, you may request access to or correction of the personal information processed about you from the Rabobank location that you do business with. We may not always be able to provide you with the requested access if for example, such access would compromise our ability to carry out a confidential investigation or comply with legal obligations, or such access would require disclosure of information about a third party.
If you feel that your personal information has been processed incorrectly or incompletely, or if you feel that such processing was unnecessary, then you can file a request for editing, supplementation or destruction of your personal information with the Rabobank division that you do business with.
Can I withdraw my consent?
Yes, you may also withdraw your consent to the communication or use of your personal information. If you withdraw your consent, we may not be able to provide you with the product or service you requested.
Who can I turn to if I have a question or a complaint?
If you have any questions or complaints about Rabobank’s processing of personal information practices, please either contact the division that you do business with or Rabobank’s Office of the Privacy Officer by mail or by email.
Email:
fm.ca.Toronto.Compliance@rabobank.com
Mail:
Attn: Privacy Officer
22 Adelaide Street West, Suite 3720
Bay Adelaide Centre East Tower
Toronto, ON M5H 4E3
Will this Privacy Statement be changed?
Our Privacy Statement may change from time to time. Clients will be kept informed of significant changes.