In this Privacy Policy we explain:

• what personal data we collect and how;
• for what purposes and on what grounds we process your personal data;
• with whom we share your personal data;
• how long we keep your personal data;
• the rights you have as data subject;
• how your personal data is protected;
• our use of cookies;
• changes to this policy; and
• how you can contact us.

This Pri­vacy Pol­icy ap­plies to all per­sons of whom Home Federal Bank processes per­sonal data, such as (prospect) cus­tomers or their rep­re­sen­ta­tives or Ul­ti­mate Ben­e­fi­cial Own­ers, per­sons who have sub­scribed to newslet­ters or events, and per­sons who have ap­plied for a job at Home Federal Bank.

Personal data
Per­sonal data is any in­for­ma­tion re­lat­ing to an iden­ti­fied or iden­ti­fi­able nat­ural per­son. Per­sonal data that we process may in­clude:

• ‘Data on who you are’ such as (i) basic information like your first and last name, prefix, title, (ii) contact details such as your e-mail address, postal address and phone number, (iii) data contained on your identity document, and (iv) your role (e.g. authorized representative, legal representative, director or guarantor);
• ‘Your transactions and payments’: name and account number of the person instructing a payment, account number of the person receiving a payment, time and location at which payments were made, amounts transferred or deposited and the balance in your account and investments orders;
• ‘Your contact history’: the subject of the contact you had with us, when did the contact occur and with which department, how (via post, email etc.) and the recording of a telephone conversation or report from a discussion;
• ‘Data needed for security and fraud prevention’: internal reference register (i.e. a list of people and institutions with whom we no longer wish to have a relationship), external reference register (a list kept by banks in the Netherlands containing people and institutions who have committed fraud or otherwise pose a risk to the financial sector), national, European and international sanctions lists, camera footages in our offices and payment patterns;
• ‘Your financial situation and Home Federal Bank products’: your personal and business Home Federal Bank products and services, the balance in your accounts and on your loans, your registration with the credit registration office, your investment profile and data on payment arrears;
• ‘Sensitive personal data’: citizen service number (BSN) and criminal data;
• ‘Your use of our websites’: your IP address, data on your visit to our website, the device you used to visit our websites, cookies and your cookie-settings;
• ‘Data on you from external parties’: data on companies, their representatives and Ultimate Beneficial Owners (UBO’s) provided by the companies itself or from the Land Register and the Commercial Register of the Chamber of Commerce, data from the Credit Registration Office (BKR), data from public sources such as status inquiry agencies (companies specialized in credit profiles), the insolvency register, newspapers, the internet or social media;
• ‘Job Applications’: data you may provide us for the purpose of a job application, such as your full name, date of birth, address, phone number, nationality, marital status and any other personal data set out in your application;
• Personal data that you provide us with for the purpose of attending events or meetings, such as access and dietary requirements; and
• Any other personal data relating to you which you may provide us with or that we may obtain in relation to the purposes and based on grounds set out below.
  We collect this personal data because you provided this data to us. For example, you may provide data when entering into an agreement with us, by entering your data on our website, by giving us your business card or by applying for a job. We may also collect your personal data from other sources, such as from a local counsel, counterparties, the Trade Register, the Land Registry or by using publically available sources.

Purposes and legal basis for the processing of personal data
Home Federal Bank saves and uses per­sonal in­for­ma­tion for care­fully se­lected pur­poses as in­cluded in the Code of Con­duct for the Pro­cess­ing of Per­sonal Data by Fi­nan­cial In­sti­tu­tions. A sum­mary of these pur­poses is out­lined be­low:

• To verify whether or not Home Federal Bank can accept someone as a customer;
• To enter into and execute contracts with you and (other) customers;
• To ensure money can be paid and received (payments);
• To analyse personal information for investigations and statistic and scientific objectives;
• To provide information about Home Federal Bank products and services (marketing);
• For prevention of fraud and unusual transactions and in general for the protection of security and integrity of your transactions and of the financial market;
• To comply with legislation or court orders to which Home Federal Bank is subject[i];
• To maintain contact with you,(other) customers and/or business relations; and/or
• To handle your job application or subscription to any of our recruitment services and events.

We will process your per­sonal data us­ing one or more of the fol­low­ing le­gal grounds:

• Performance of a contract;
• Compliance with a legal obligation;
• Legitimate interest;
• Your consent.

Sharing with others

Home Federal Bank may share your per­sonal data with any com­pany be­long­ing to the Home Federal Bank group for the pur­poses de­scribed in this Pri­vacy Pol­icy.

In some cases we may also share your per­sonal data with third par­ties. This may in­clude, but is not lim­ited to:

• Other financial institutions;
• The government (such as Tax Authority, Finance Intelligence Unit Nederland, Tax and Customs Administration, Police, Justice officials, Intelligence services and Supervisory Authorities); and/or
• Service providers who work for Home Federal Bank and companies Home Federal Bank works with.

We will only share your per­sonal data with these third par­ties for the pur­poses and on the le­gal grounds stated in this Pri­vacy Pol­icy.

To the ex­tent that a third party processes your per­sonal data as a data proces­sor of Home Federal Bank, Home Federal Bankwill con­clude a pro­cess­ing agree­ment with such party that meets the re­quire­ments set out in the GDPR.
To be able to pro­vide our ser­vices, it may be nec­es­sary for us to trans­fer your per­sonal data to a re­cip­i­ent in a coun­try out­side of the Eu­ro­pean Eco­nomic Area. In that case, Home Federal Bank will en­sure that the data trans­fer is com­pli­ant with GDPR and the ap­plic­a­ble law.

Retention period
Home Federal Bank will not store your per­sonal data any longer than is nec­es­sary to achieve the pur­poses stated in this Pri­vacy Pol­icy or to com­ply with the rel­e­vant laws and reg­u­la­tions. We main­tain a list of min­i­mum record keep­ing re­quire­ments that are spec­i­fied by dif­fer­ent leg­is­la­tions, such as tax law and re­tire your per­sonal data from our sys­tems to the ex­tent it is tech­no­log­i­cally pos­si­ble. We may keep some of your per­sonal data longer for spe­cific pur­poses like risk man­age­ment, se­cu­rity and le­gal pur­poses. In such sit­u­a­tions, we limit ac­cess to your per­sonal data to ab­solute min­i­mum.

Your rights

You, as a data sub­ject, have a num­ber of le­gal rights:

• Right of access. This means you can make a request to obtain access to the personal data concerning yourself;
• The right to rectification or correction of your personal data if it is inaccurate or incomplete;
• The right to erasure of the personal data that relates to you. Please note that there may be circumstances in which we are required to retain your data in order to meet our legal and regulatory obligations;
• The right to object to or to request restriction of the processing. Again, there may be circumstances in which we are legally entitled to refuse your request;
• The right to data portability. This means that you have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
• The right to object to profiling;
• The right to lodge a complaint with a supervisory authority; and
• The right to withdraw your consent. Again, there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.

Security

Home Federal Bank has taken tech­ni­cal and or­ga­ni­za­tional mea­sures to en­sure an ap­pro­pri­ate level of se­cu­rity to pro­tect your per­sonal data from unau­tho­rized or un­law­ful pro­cess­ing and from loss, de­struc­tion, dam­age, al­ter­ation or dis­clo­sure. If you have any ques­tions re­gard­ing the se­cu­rity of your per­sonal data, or if there are in­di­ca­tions of mis­use, please con­tact our Data Pro­tec­tion Of­fi­cer at [email protected]

Cookies
Home Federal Bank uses cook­ies on its web­sites and in­ter­net bank­ing ap­pli­ca­tions. Home Federal Bank does not place any cook­ies on your browser with­out your con­sent, ex­cept for the cook­ies that are func­tion­ally re­quired.

Please visit the Cookie Declaration page for more in­for­ma­tion on cook­ies, the de­tails of cook­ies we use, and to see or mod­ify your cur­rent cookie con­sent sta­tus.

Changes
Home Federal Bank may amend this pri­vacy pol­icy from time to time. On this web­site, you can al­ways view the lat­est ver­sion of our pri­vacy pol­icy. We would ad­vise you to check the pol­icy reg­u­larly and, in any event, when­ever you pro­vide us with per­sonal data.

Contact
If you need fur­ther in­for­ma­tion or have any ques­tions or com­ments about our pri­vacy pol­icy or the pro­cess­ing of your per­sonal data, please con­tact us in writ­ing via: [email protected]