ExpertBank

Privacy and cookies policy

Date of last update October 26, 2019

At ExpertBank, we take the privacy of our clients, prospects, former clients and others whose data we process very seriously due to the relationship we have with our clients. In this privacy policy, we provide you with detailed and understandable information about the personal data that we will process about you, their origin, the uses we will give to them and the basis of legitimation applicable to each of the aforementioned uses. We also explain in detail what rights you have and how to exercise them. Please take a few minutes to properly read and understand its content. If you have any questions, please contact our Data Protection Officer, whose contact details you will find below.

Who is responsible for processing my data?

“ExpertBank”, 134 Avenue de la Plaine de France, 95500 Gonesse, France.
Contact of the Data Protection Officer: support@expertbank.financial.

What data does ExpertBank process about me?

The personal data that we collect and process about you to provide our services to you includes: identification and contact information; financial and socio-economic data; place of residence; data related to your geolocation; personal, professional and business profile; picture, voice and recordings of calls, video calls or electronic conversations that we have with you; biometric data; IP adress; your browsing data on our website or mobile applications; and the data we obtain through the use of terminals such as mobile devices, POS terminals or ATMs.

When you register as a customer with us, we also collect and integrate into our database additional information about your financial solvency, income level and consumption habits, either because you provided it yourself, or because they were generated within the framework of the contractual relationship. you have with us.

Please note that we sometimes obtain information about you from external sources in order to prevent fraud, comply with legal obligations to which we are subject, and improve and personalize your customer experience.

Sometimes we also process inferred data about you, which we infer and / or obtain from data you have previously provided to us (for example, when we create profiles).

For what and with what legitimacy does ExperBank process my personal data?

At ExpertBank, we process your data for the following purposes and in accordance with the following legitimacies:

a) For the proper performance of the contract:

Management of my

registration as a customer and provision of ExpertBank services If your request is accepted, we will process your data to register you as an ExpertBank customer and for the development and timely management of the contractual relationship we have with you, as well as to send you communications related to the management of your registration or those necessary to fulfill and execute the contractual relationship with you when you are already a customer.

In addition, we will keep your identity document (including your image) and, if applicable, we will consult it by all means, formats and media, for the sole purpose of verifying your identity when necessary to fulfill the signed contract. with you and to meet legal requirements.

When you register, we may also view the credit information files managed by Asnef-Equifax Solvency and Credit Information Service, SL (ASNEF File) and Experian Credit Bureau, SA (BADEXCUG File), respecting the procedures, rights and guarantees established by the legislation in force at any time. Through this analysis, we will assess your ability to meet the obligations related to the opening of your bank account and avoid situations that could be detrimental to us, such as a possible overdraft. Please keep in mind that following this consultation, we may approve or deny your release. If your registration is refused, you will be immediately informed.

The data that we indicate in the registration form as “mandatory” are necessary for the proper execution of the contractual relationship with ExpertBank. In this way, the failure to provide them would mean the inability to fulfill your request for registration as a client and to provide you with our services.

Maintain the relationship

We will process your personal data to issue and manage the transactions you contract and send you all the information you request.

In addition, throughout your contractual relationship with ExperBank, there may be situations in which we record your voice and / or image and the electronic conversations we have with you. In such situations – of which we will inform you, in advance and expressly, when they take place – we will keep the telephone and / or electronic conversation for a dual purpose: both to internally audit the quality of the service and to use the recording as evidence – in and outside court – if necessary.

Categorization of movements

We may classify your bank account movements or the information we access through the financial aggregator into representative expense categories (eg, education, restaurants, supermarkets, leisure). We will carry out this data processing, as part of the management of the contractual relationship that we have with you, in order to offer you information that will allow you to more easily manage and supervise your finances.

In addition, depending on the product you are contracting, for the proper execution of the ExpertBank relationship, you must perform additional processing:

If I am requesting the subcontracting of an asset product, such as an UNCOVERED MORTGAGE / LOAN / CREDIT CARD / PROTECTION:

At Openbank, we will process (i) the information you provide to us, (ii) the information we obtain by consulting the internal and external files detailed above, (iii) or the information we obtain from your interaction on our site Web / application, to manage and analyze your application, check and assess your solvency and credit risk, as we explain in more detail at the end of this section. In this way, we can carry out the study of your request and approve or reject it, according to the risk criteria that we have established at any time, in order to fulfill and execute the contractual relationship of the new Active Product that you contract and in accordance with our sectoral regulations. We will not be able to process your request without performing this analysis.

On the other hand, if the product that you are going to contract is a mortgage, from ExperBank we will communicate your data within the framework of the said contract to the expert, the corresponding notary and the land registry.

We may have obtained your data through a mortgage intermediary, in the event that you have used the services offered by this type of entity to receive advice on the mortgages best suited to your situation. situation and initiate the previous procedures for taking out your mortgage with us. In any case, we will ensure that you are informed by the aforementioned entity about the transfer of your data to ExpertBank. The financial intermediary itself will inform you via its website of the data processing it carries out.

Likewise, if at the moment you are only evaluating the possibility of taking out a mortgage with us, and for this you carry out a simulation on our website / app, we will use the data you provide to calculate your costs and send it to you by e -mail if so. you want, or so that you can retrieve the simulation later on our website / App. We will keep the data exclusively to identify you in case you need time to think it over and you contact us again after a few days. This way we will assist you more quickly and avoid duplication of procedures.

Likewise, if you rent a credit card, in some cases it may take out insurance, in which case your data may be transferred to the corresponding insurance company.

Solvency and credit risk analysis when requesting an asset product:

ExpertBank has implemented an automated system for risk assessment and the creation and analysis of customer profiles. This means that when you request the active product and enter your data into the system, we will perform – based on the information we have about you – an automatic analysis to assess whether or not we can grant you the product.

In particular, with regard to the proper execution of the contractual relationship, when you request an Active Product, such as a credit card, certain types of loans or overdraft protection, and for the assessment of your level of risk and your ability to make in terms of paying the amounts you can commit to, we will compare and profile your data with the behavior and risk models we have designed in ExpertBank.

On the one hand, we will perform this assessment on the basis of the information we have about you from internal sources, such as:

   (i) Information that you provide to us directly, either at the time of your registration as a customer, or throughout
   your contractual relationship with ExpertBank.
   (ii) Information derived from our contractual relationship with you.
   (iii) Information we obtain from your interaction on our website / app.

We can also consult external sources, in compliance with the procedures, rights and guarantees established at all times by the legislation in force, such as:

   (i) Credit information files maintained by Asnef-Equifax Solvency and Credit Information Service, SL (ASNEF File) and Experian Credit Bureau, SA (BADEXCUG File).
   (ii) Bank of Spain Risk Information Center (“CIRBE”).
   (iii) Public administration bodies such as the Ministry of Finance
   (iv) Public registers such as the National Institute of Statistics, the Commercial Register, the Property Register and the Cadastre.
   (v) Information Obtained from Suppliers.
   (vi) Publicly available sources such as promotional census, lists of persons belonging to professional groups, newspapers and
   official newsletters, open social networks or the Internet.

This analysis of your creditworthiness, through which we will assess your ability to meet the debts you request or any debts, will be carried out by making automated decisions according to our behavior models. Please keep in mind that following this risk study, we can approve, modify or refuse the contractualization of the product you request or, failing that, condition its validity on the constitution of a payment guarantee, the all based on the risk we detect and the credit rating resulting from the analysis of this information. In the event that we refuse a request that you have made due to the result of such consultations and / or analyzes, you will be immediately informed and you can make any allegations you deem appropriate.

Keep in mind that at ExpertBank we subject this system to periodic reviews to avoid any inconsistencies, errors or inaccuracies in the assessment. However, if you are not satisfied with the result of the evaluation, you can dispute it by providing the information you deem appropriate to refute the decision taken and request the personal intervention of one of our analysts.

If I request the subscription of a liability product, such as a PAYROLL ACCOUNT / CURRENT ACCOUNT / SAVINGS ACCOUNT / DEPOSIT:

At ExpertBank, we will process the information you provide to us or, where applicable, that we obtain from your interaction on our website / application to manage your request, to respond and thus execute the contractual relationship of the new liability product that you contract. and in accordance with our industry regulations.

These pre-contractual measures are necessary to assist and decide on the request you have made, and for this reason you must provide us with all the information indicated in the form as “mandatory”. Otherwise, you will not be able to subcontract the product you requested.

If I request the contract of a payment method, such as DEBIT CARD / PREPAID CARD / BIZUM (IMMEDIATE PAYMENTS) / MOBILE PAYMENT APPLICATIONS / FINANCIAL AGGREGATOR / PASSWORD MANAGER DATABASE :

At ExpertBank, we will process the information you provide to us or, where applicable, that we obtain from your interaction on our website / app, to manage your request and comply with the contractual relationship of the new payment method that you are renting and in accordance with our industry regulations. We will also process information that you have provided to us on previous occasions and that we have recorded in our database.

In addition, some mobile applications available for payments may require, before you start using them, that you accept the terms and conditions of ExpertBank and / or the relevant service provider. Under these conditions, we will inform you of the way in which your personal data will be processed in each of these services.

These pre-contractual measures are necessary to assist and decide on the request you have made. If you do not provide the necessary information, you will not be able to subcontract the product or service you requested.

If I request the contract of a payment method, such as DEBIT CARD / PREPAID CARD / BIZUM (IMMEDIATE PAYMENTS) / MOBILE PAYMENT APPLICATIONS / FINANCIAL AGGREGATOR / PASSWORD MANAGER DATABASE :

At ExpertBank, we will process the information you provide to us or, where applicable, that we obtain from your interaction on our website / app, to manage your request and comply with the contractual relationship of the new payment method that you are renting and in accordance with our industry regulations. We will also process information that you have provided to us on previous occasions and that we have recorded in our database.

In addition, some mobile applications available for payments may require, before you start using them, that you accept the terms and conditions of ExpertBank and / or the relevant service provider. Under these conditions, we will inform you of the way in which your personal data will be processed in each of these services.

These pre-contractual measures are necessary to assist and decide on the request you have made. If you do not provide the necessary information, you will not be able to subcontract the product or service you requested.

If I request the rental of a PRODUCT IN THE NAME OF A MINOR, such as a prepaid card, a savings account, or a registration in the “Expert Young” Application:

At ExpertBank, we will process the information you provide us to manage your request and comply with the contractual relationship. Keep in mind that when processing a minor’s data, we will have to guarantee that you are their father / mother or their legal representative for the subcontracting and maintenance of products (prepaid card, savings account or registration with the “Youth Expert”).

You can obtain more information on the protection of personal data of minors and their rights.

These pre-contractual measures are necessary to assist and decide on the request you have made. If you do not provide the necessary information, you will not be able to subcontract the product or service you requested.

If I take out an investment product, such as EQUITIES / INVESTMENT FUNDS / WARRANTS / PENSION PLANS / ETFS / SECURITIES ACCOUNT / MODEL PORTFOLIO / AUTOMATED INVESTMENT SERVICE:

At ExpertBank, we will process the information you provide to us, or the information we obtain from your interaction on our website / application, to manage and analyze your request and thus execute the contractual relationship of the new investment product that you contract and in accordance with our industry regulations.

Depending on the investment service you have requested and the product, we may approve or reject the contract in accordance with applicable regulations.

If you wish to subscribe to an investment fund or contract a pension plan, as marketers of the fund or of the plan, as the case may be, we will have to communicate your data to the management entity and to the entity corresponding depositary, where applicable, in order to proceed with your subscription, subcontracting and / or management. Likewise, in the event that you request a transfer from ExpertBank to another entity, your data must be transferred to the destination entity in order to mobilize your balance and your consolidated financial rights.

Likewise, to determine the convenience or suitability of contracting the investment services or products you request, we will process the information you provide to us to define your investor profile, taking into account your knowledge and experience in financial instruments, investment objectives and financial situation. .

These measures are necessary to assist and decide on the request you have made, and for this reason, you will need to provide us with all the required data. Otherwise, the product cannot be contracted.

If I request the rental of an INSURANCE product:

At ExpertBank, we will process the information you provide to us, or the information we obtain from your interaction on our website / app, to manage and analyze your request and thus comply with the contractual relationship of the new insurance product you are renting. and in accordance with our industry regulations.

Depending on the assurance you request, we will inform you, in each case and individually, of all the legal aspects of the processing, for example, what uses we will give to your data and the third parties that may intervene in the process of contracting. markets. More specifically, since ExpertBank acts as an insurance mediator, to fulfill the aforementioned purposes, we will have to communicate certain data to the insurance entities with which you contract the products, which will be responsible for the data processing.

These pre-contractual measures are necessary to assist and decide on the request you have made, and for this reason it is necessary to provide all the information indicated in the form as “mandatory”. Otherwise, you will not be able to subcontract the product you requested.

If I make a SOLIDARITY DONATION:

At ExpertBank, we offer two methods for making solidarity donations: the solidarity transfer and our solidarity debit card.

Whenever you use these services, we will process the data you provide to us to fulfill and execute the contractual relationship, as indicated above, respectively, in the sections relating to the subcontracting of liability products (in relation to the joint transfer) and Means of Payment (compared to the solidarity debit card).

In addition, when you take out a solidarity card, we will provide some of your personal data to NGOs / Foundations, in order to manage your donations and, if possible, so that they can issue the annual donation certificate.

b) On the basis of ExpertBank’s legitimate interest:

From ExpertBank, and on the basis of our legitimate interest, we can carry out the processing described below, while respecting your privacy and your rights at all times. In any case, remember that you can always exercise your right to object to these treatments as we describe below in this document.

Sending commercial communications on ExpertBank products and services or on the benefits associated with said products and services, tailored to my profile on the basis of information obtained from internal sources.

As an ExpertBank customer, we want to keep you up to date with our products and services, but we don’t want to bother you with any messages or information that you are not interested in. For this reason, we will send you information which, due to your customer profile and your consumption habits, may be of more interest to you.

In particular, in order for you to get the most out of your financial situation, we may send you commercial communications about ExpertBank products and services similar to those you have contracted and the benefits associated with such products and services (for example, l application of a discount to hold a credit card and make certain purchases), adapted to your profile, interests and needs (by post, telephone, SMS, instant messaging applications, email, web push, pop- up or any other electronic or telematic means available at any time) and inform you about loyalty programs and raffles, while being a customer.

You should consider that in this case, it is not necessary that you give us your consent for us to send you these communications, since we are authorized to send them, as long as they relate to ExpertBank products and services similar to those that you have contracted. or the benefits associated with such products and services, as long as you are an ExpertBank customer. However, you can exercise your rights at any time, as indicated in the section “What are my rights when I provide my data?”

For the personalization of the aforementioned commercial communications, and on the basis of the legitimate interest recognized by the European General Data Protection Regulation, we will process the information obtained from our own sources in order to create profiles generated on the basis of models of common behavior.

In order not to disturb you and to comply at all times with the provisions of the law, before processing your data for marketing purposes, we will consult the ad exclusion databases (Robinson lists) included in the relationship published by the Spanish Data Protection Agency to verify that you are not included in any of them, in cases where such consultation is legally foreseen.

Personalized advertising on the private ExpertBank website

When you access the private section of your profile on our website, we will show you advertisements about features, products and services that may be of interest to you. If you wish, you can choose not to receive this type of personalized advertising, by following the instructions in the section “What are my rights when I provide my data?”, But keep in mind that you will continue to receive generic advertisements which will not be based on your interests or preferences.

Sending information about products and services that interest me via social networks

If you are registered on a social network, we can through it show you advertisements specifically directed at you on ExpertBank products or services similar to those you have already contracted with us and which may be of interest to you. Of course, we will not bother you with information about products and services that you have already contracted.

To carry out these actions, we will use tools that social networks have developed specifically for this purpose (such as, for example, Facebook Custom Audiences) and which allow them to check whether, in addition to being our client, you have ‘an open profile with them. To do this, we need to share your contact details with social networks (mainly, your phone number and email address). Social networks themselves will offer you in their privacy policies information on how they treat your data through these tools.

We also advertise on social networks or online tools based on user interests and therefore if you are a user of a social network and you are ranked in the audience we select you may receive advertising from ExpertBank. Keep in mind that in these cases, to object to the receipt of these communications, you must go to the social network that reached you.

Analysis of solvency and credit risk to offer me an Active Product, based on information obtained from internal sources

As we have stated previously, we have an automated risk assessment system and the creation and analysis of customer profiles.

We can also use this system to assess the level of risk and solvency vis-à-vis customers who have not requested an Active Product, specifically to make these Products available to them, as a loan.

For these purposes, we will profile our clients’ data against behavior and risk models previously designed by ExpertBank, and we will make automated decisions.

We will make this assessment only on the basis of the information we have about you from internal sources, such as:

   (i) Information that you provide to us directly, either when you register as a customer, or throughout your relationship
   contractual with ExpertBank.
   (ii) Information derived from our contractual relationship with you.
   (iii) Information we obtain from your interaction on our website / app.

Design and training of risk models

At ExpertBank, we want to provide the best possible customer experience. For this, it is important that we know and understand the needs of financial and banking products and services, financial solvency and the consumption habits of our customers. For this, and on the basis of our legitimate interest in designing, creating and offering innovative and efficient financial and banking products and services, we process the personal data of our clients to design and train algorithms that allow us to create different models of behavior and risk. To design and train our behavior and risk models, we use pseudonymized personal and economic information from our own external sources such as:

   (i) Information we have about you derived from the documentation you have provided to us;
   (ii) Information contained in ExpertBank files about your behavior in transactions signed with us.
   (iii) Information in financial solvency files, credit information or fraud to which we have access, such as the
   ASNEF file, BADEXCUG, CONFIRMA or CIRBE file.

While your personal data will be used to design and train our behavior and risk models, this will not have any individualized legal consequences for you.

We may use these behavior and risk models for later, to compare our clients’ database with them, to profile our clients, both for marketing purposes (sending advertising) and to analyze and assess their level risk and solvency. We give you more information about these treatments and their corresponding legitimacy in other sections of this document.

Communication of Defects to Credit Information Files

In the event of non-payment on your part during your contractual relationship with ExpertBank, it may be communicated to the credit information files, in particular to:

   (i) Asnef-Equifax Servicios de Información sobre Solvenncia y Crédito, SL, responsible for managing the ASNEF file. You can
   access additional information on the data processing carried out by this entity by consulting its website.
   (ii) Experian Credit Bureau, SA, responsible for managing the BADEXCUG file. You can access additional information on
   the data processing carried out by this entity by consulting its website.

These communications will at all times respect the procedures, rights and guarantees established and recognized by the legislation in force.

All of the above will be carried out in the legitimate interest of ExpertBank, as we must prevent non-payment situations and carry out adequate monitoring thereof and, in the legitimate right of third-party financial entities to know of the existence of non-payment . payments in the face of new funding requests.

Detection of possible fraud attempts

At ExpertBank, we have an obligation to prevent fraud and protect you and the rest of our customers against possible fraudulent and criminal behavior, such as identity theft, card duplication or theft of Passwords.

We will process your data for these purposes, including data you have provided to us directly, as well as data related to your location, behavior patterns, or data we obtain from specialized external sources, such as prevention agencies. fraud.

In particular:

   (i) We may consult your data in our own internal sources, in order to prevent and detect possible situations of fraud (such as inappropriate access to personal customer information, possible identity theft or any situation that may be interpreted as fraudulent or unwanted use of the account) in order to protect the interests of our customers. In the event that an attempted fraud is detected, and unless there is a circumstance of public interest, we will notify you, we will review the information available and, if appropriate, we will need additional information. Likewise, as a precaution, and until we perform the appropriate checks, any decision, whether automated or not, will be paralyzed.

   (ii) For the legitimate interest of ExpertBank, the obligation to respect an adequate risk control and to avoid possible fraud attempts, we share some of your personal data with third parties who help us to detect and prevent possible fraud attempts, respecting and respecting the procedures, rights and guarantees that current legislation establishes and recognizes at all times. The information we share with these third parties includes some of the information you provide to us when you register as a customer, such as your email address, as well as information related to your browsing, such as the IP address of your device. Emailage Limited, based in the UK, is one of the third parties we use to help us detect and prevent fraudulent transactions. Emailage is also responsible for the processing of your personal data and will use them for the purposes established in its privacy policy https://emailage.com/es/privacypolicy/. You can exercise your data protection rights against Emailage surtivacy@emailage.com.

   (iii) On the other hand, and also in order to detect and avoid possible fraud attempts, ExpertBank is attached to the CONFIRMA file, in respect of which we are required to communicate the following to you: "The candidates are informed of the communication of data from this application to the CONFIRMA file, the purpose of which is the prevention of fraud. The legal basis for the processing of personal data is the legitimate interest of the controller to prevent fraud (Recital 47 GDPR) The maximum data retention period will be two years.

Those responsible for processing are the Entities Adhered to the Rules of the CONFIRMA File, being the person in charge of processing Confirma Sistemas de Información, SL, with address in Avda. De la Industria 18, Tres cantos, 28760, Madrid. Applicants can consult the list of Entities that currently adhere to the CONFIRMA Files Regulations on the website www.confirmasistemas.es. Entities which adhere to its Rules and which, in their field of activity, may be the subject of contractual fraud may participate in the CONFIRMA File.

The data communicated to the CONFIRMA file can be transferred to entities adhering to the rules of the CONFIRMA file. The transfer of data to a third country or an international organization is not foreseen.
In accordance with the regulations in force on data protection, the signatories can exercise their rights of access, rectification, deletion, limitation of their processing or opposition, by going to the address of the controller, CONFIRMA SISTEMAS DE INFORMACIÓN, SL, at the above address. Likewise, signatories can make use of their right to lodge a complaint with the supervisory authority.
Confirma Sistemas de Información, SL has appointed a Data Protection Officer, whose contact email address is dpo@confirmasistemas.es.

Pseudonymization of my personal data

We will also perform pseudonymization procedures on your data, which means that the data resulting from this process cannot be traced back to you, i.e. we will not be able to identify you with the information that we process, unless we use additional information. and the processes for doing so. The purpose of these procedures is simply to use the pseudonymized information, based on ExpertBank’s legitimate interest, for statistical purposes and for the development of behavioral models.

Surveys and market studies

In order to meet your expectations and increase your level of satisfaction and experience as a customer, and on the basis of our interest in improving our products and services, ExpertBank will process personal data associated with the use of the products and services to which you have subscribed. carry out surveys, market studies or internal statistics and prepare activity reports.

Management and improvement of the experience on social networks

When you use our channels on social networks, such as Facebook, Twitter or Instagram, we may process your data using specialized tools, in order to speed up the response to your queries and improve your experience.

Sending notifications via the ExpertBank app and website

Through the notification functionality of our app and website, we may notify you of certain circumstances that occur with the products and services that you have contracted with ExpertBank, based on our legitimate interest and in order to improve the services. that we lend you. For example, if you have contracted a card with us, we may send you notifications whenever you use it for security reasons and so that you can control your spending and notify you when a purchase is declined.

You can turn on / off and even configure some of the notifications as you wish by entering the settings in the “Notifications” section of the main menu of the App, or in the “Notifications” section of your private area on our website.

Resume requests or contracts that had been launched and were pending

In the event that you have not completed your request for registration as a customer or the subcontracting of any of our products or services, we may contact you for a reasonable period using the information you have given us. provided, to remind you that you have not completed the process and inform you of the steps to follow if you wish to complete it, as well as to detect any technical problem that may occur.

Communication with the entity I represent or in my capacity as a self-employed person

If you represent a legal person (such as a company or association) that is a client of ExpertBank or that wishes to hire one of our products or services, we will process your contact details as well as those related to the position you hold and , in general, the data necessary for your professional location, on the basis of our legitimate interest. We must use this data to be able to communicate with the legal person you represent and to maintain the contractual relationship between us.

If you are self-employed or have a liberal profession and work alone, we will also process your data to manage your registration as a client, provide you with our services and maintain the relationship with you as a professional. Under no circumstances will we process your information to establish a relationship with you on a private level.

c) In accordance with ExpertBank’s legal obligations:

At ExpertBank, we must comply with certain legal obligations to manage your products / services or those you request and contract, such as:

Prevention of money laundering and terrorist financing

In accordance with Law 10/2010 on the Prevention of Money Laundering and Terrorist Financing, we will process your data, among other things, to:

   (i) Report monthly to the Financial Property File the identification data of our customers and the persons concerned, concerning the date of opening or cancellation, current accounts, savings accounts, securities accounts and deposits eventually. Therefore, the above data will be part of this file, which is the responsibility of the Secretary of State for the Economy and Business Support.
   (ii) Provide information on payment transactions to the authorities or official bodies of other countries, located both inside and outside the European Union, in the context of the fight against the financing of terrorism and serious forms of organized crime and the prevention of money laundering. Financial entities are also generally required to adopt adequate measures to prevent, investigate and uncover fraud.
   (iii) Verify the veracity of the information and documents you provide to us in order to know the nature of your professional or commercial activity and provide them to the authorities or official bodies of other countries, located both inside and outside the country. outside the European Union, within the framework of the fight against the financing of terrorism and serious forms of organized crime and the prevention of money laundering.

Information at CIRBE

By Law 44/2002 on the reform of the financial system, ExpertBank must communicate to CIRBE the risks of your operations, their recoverability and, where applicable, any breaches on your part.

Communication of information to AEAT

We will have to communicate certain information on your tax residence and your accounts to the Tax Agency (hereinafter, the “AEAT”), which in turn may be required to transmit it to the competent tax authorities of other countries in accordance with the regulations relating to the automatic exchange of tax information (Foreign Account Tax Compliance Act -FATCA- promoted by the United States of America and Common Reporting Standard -CRS- promoted by the OECD).

Communication of information to other Group companies for the prevention of financial crime

At ExpertBank, we will communicate customer data to the other companies of the Santander Group, of which we are a part, as well as any relevant information on operations allowing said companies to comply (i) with the Group’s internal regulations on the prevention of financial crime. , (ii) its legal obligations to prevent money laundering and the financing of terrorism and (iii) the regulatory report to the supervisory authorities.

The processing of data arising from obligations of a legal nature to which we are subject at Openbank will continue to be carried out even after the end of the contractual relationship with you, as long as we are legally obliged to do so.

d) After obtaining my consent:

From ExpertBank, we can carry out the following treatments as long as you have given us your authorization, which, in any case, you can modify or withdraw at any time.

Video call identification and recording retention

At ExpertBank, we are required under the regulations on the prevention of money laundering and terrorist financing to reliably identify you by means of a valid identity document, as well as to retain certain data collected in said document.

In order to be able to carry out this identification in a more comfortable and simple way for you, we provide you with a procedure which allows us to identify you thanks to a video call assisted by an agent. You will also have the option of making an unattended, agentless call, in which case we will subject your image to facial recognition techniques involving biometric data processing. If you choose to identify yourself by video call (assisted or not), we will need your prior consent in order to make it, record it and keep the recording. This information can be viewed by different organizations, when required by law.

Alternatively, if you prefer, you can identify yourself by other means that we make available to you, such as providing us with your account number at another bank.

Sending commercial communications

   (i) Communications on ExpertBank products and services tailored to my profile and based on external sources

If you authorize us, from ExpertBank we may send you commercial communications about our own products and services tailored to your interests and needs (by post, telephone, SMS, instant messaging applications, social networks, email, web push , pop-up or any other electronic or telematic means available at any time), personalized according to your behavior and your risk profile that we can develop thanks to the information obtained both from our own internal sources, as well as from third parties (such as ASNEF, EXPERIAN) and Internet browsing and / or data.
To send communications and commercial offers adapted to your solvency and your risk, we will check your credit history in the various transactions you have had with us, in addition to analyzing your behavior in the transactions currently in force and those carried out. over the past six (6) years.

   (ii) Communications on employee products and services tailored to my profile and based on external sources

At ExpertBank, depending on the type of authorization you have accepted, we can send you, by any means (postal mail, telephone, SMS, instant messaging applications, social networks, email, web push, pop up or any other means electronic or telematic available at any time) commercial communications of products or services of other companies with which we can sign collaboration agreements, tailored to your interests and needs, or personalized according to your profile prepared with information obtained at the same time from our internal sources and from third parties (such as ASNEF, EXPERIAN or CIRBE) and navigation and / or Internet data.
We indicate the different sectors of companies with which we can sign agreements, without limiting the inclusion of new sectors in the future: insurance, travel agencies, passenger transport, telephony and Internet, health services, beauty treatments, press and magazines, toys, food, restaurants, textiles, shoe stores, perfumery, jewelry, books and records, education, sporting goods, housewares, automobiles and accessories, motorcycles and accessories, gas stations, furniture, electrical appliances, electronics , computers, hotels, department stores, leisure parks, zoos, museums, shows, electricity, gas, travel goods, subscription TV, security services, opticians, DIY, musical instruments, photography, air conditioning, sanitation, gardening, swimming pools and home renovations in general.

Serve me via website / app if I am not yet an ExpertBank customer

On our website / app there are various forms that users who are not yet ExpertBank customers can voluntarily fill out if they are interested in our products or services, want to send us specific questions that might arise about ExpertBank or our operations, or even request simulations of our products.

Users have the option of receiving the requested information by email, but they can also ask us to contact them by telephone by filling out the form specifically provided for this purpose.

We will process user data, where applicable, to provide them with the information requested, respond to their queries and requests by the means they have indicated, acknowledge receipt of requests and ensure follow-up.

In these cases, by filling out and sending the corresponding form, users give us their consent for us to proceed with the data processing described here.

Which stakeholders are affected by this policy?

Through this policy, we regulate ExpertBank’s processing of personal data of various categories of interested parties. More specifically, the Policy covers the processing of data of (i) current customers, (ii) pre-customers, (iii) potential customers, (iv) former customers and (v) other third parties that we may process. the data in ExpertBank. Due to the relationship we have with our clients, such as guarantors / guarantors, authorized representatives, legal representatives and contact persons of those clients who are legal persons.

  1. How long will ExpertBank keep my data?

At ExpertBank, we will process your data for as long as necessary for the purposes for which it was collected and, thereafter, we will keep it blocked during retention periods or statutory limitation periods. After these periods, we will proceed to its destruction.

More specifically, if you are a customer, we will process your data for as long as you maintain the contractual relationship with us. Once this relationship is terminated, as a rule, we will keep your personal data blocked for 10 years, after the obligations arising from the contract have ended, as required by the regulations on the prevention of money laundering. In time, we will also be governed by the statutory limitation periods that apply depending on the specific contracts you sign with ExpertBank (e.g. up to 21 years in accordance with mortgage regulations, or even indefinitely with regard to imprescriptible actions in accordance with the regulations of the general conditions of sale). Once the aforementioned legal deadlines have elapsed, where applicable, we will destroy your data.

These requests or simulations that you make but which do not end in a contract, we will keep them for as long as we deem reasonable, to avoid duplication of your efforts and in the event that you have to face a claim due to how we use your data. We will then proceed with the cancellation of the data.

To which recipients could ExpertBank communicate my data?

(i) We will communicate your personal data to public authorities, official bodies or banking supervision and control entities and competent tax authorities that need it, for the purpose of complying with the regulations applicable at all times in the banking and financial sector regulations , regulations on the prevention of money laundering and terrorist financing, and consumer protection legislation.
(ii) In the event of non-payment, we will communicate the data to the financial solvency files (ASNEF file and BADEXCUG file), respecting the procedures and guarantees that the legislation in force establishes and recognizes at all times.
(iii) We will share your data with the entities of the Santander Group, in order to comply with their internal regulations regarding the prevention of financial crime, their legal obligations to prevent money laundering and the regulatory report to supervisory authorities.
(iv) When you contract certain products or services (e.g. funds, pension plans, insurance), we will communicate your data to third party collaborators for the correct provision of the service (e.g. management entities, management entities deposit of products, insurance entities).
(v) We will communicate your data to the Notaries, when their intervention is necessary, in the event that the service you have requested must be formalized with their participation.

(vi) Your data will also be transferred to appraisal companies, when their intervention is necessary, in order to manage the request for appraisal and to draw up the corresponding appraisal report.
(vii) We will pass the data on to public registers (for example, the property register) when the corresponding guarantees need to be registered.
(viii) Likewise, at ExpertBank, we have the collaboration of third-party service providers who may have access to your personal data, but who will process it on our behalf, following our instructions at all times, and always to provide the services to us. . that in each case we were able to contract.
More specifically, at ExpertBank, we contract for the provision of services by third party providers who exercise their activity, by way of example and not by way of limitation, in the following sectors: logistics services, legal advice, private expertise services, authorization of vendors, professional multidisciplinary service companies, hosting companies, maintenance related companies, technology service companies, IT service companies, physical security companies, instant messaging service providers, infrastructure management and maintenance companies and call center service companies.
In all cases, at ExpertBank we follow strict criteria for the selection of third-party providers in order to comply with our data protection obligations, and we undertake to sign with them the corresponding data processing contract by which We impose on them, among others, the following obligations: to apply the appropriate technical and organizational measures, to process the personal data for the agreed purposes and only in accordance with our documented instructions, and to delete or return the data after the provision of the services has been completed.
(ix) We carry out international transfers of your data, only as part of some of the above services provided by third party providers. Their objective will always be the maintenance and management of the contractual relationship that you have with us. These transfers are made both to countries offering an adequate level of protection, comparable to that of the European Union, and to countries which do not benefit from this level. In the latter case, do not worry, at ExpertBank we use different mechanisms provided for in the regulations to be able to comply with all the guarantees when we process your personal data, such as standard contractual clauses or certification mechanisms. You can view the international data transfers we make here or by contacting office@expertbank.financial.

How does ExpertBank obtain my personal data?

To carry out the aforementioned data processing, we use the data concerning you that we obtain through the internal and / or external sources listed below, in compliance with the procedures, rights and guarantees established by the legislation in force at all times:

   (i) Information that you provide to us when you contract and maintain products and / or services with us, directly and
   indirectly.
   (ii) Information we infer from data you have previously provided to us.
   (iii) Public administration bodies, such as the Ministry of Finance, the General Social Security Treasury and the Agence de la
   state tax administration.
   (iv) Public registers, such as the National Institute of Statistics, the Commercial Register, the Property Register and the Cadastre.
   (v) Common capital solvency files (ASNEF file and BADEXCUG file) and CIRBE.
   (vi) Fraudulent data detection files (eg CONFIRM).
   (vii) Sources accessible to the public, such as official journals and journals, public archives, resolutions of
    public administrations, telephone directories, lists of people belonging to professional associations, open social networks and
    Internet.
   (viii) Third party companies to which you have given your consent for the transfer of your data to ExpertBank or which
   legitimately transfer your data to ExpertBank in accordance with the legislation in force.

Do I need to keep my contact details up to date?

In order to communicate properly with you, as well as to be able to correctly provide you with the contractual services, you agree that all the information you provide to us is correct, complete, accurate and duly updated, assuming any liability that may arise from has provided us with incorrect, erroneous or inaccurate information.

Thus, if you modify any of the personal data that you have provided to us, and in particular your postal address, e-mail and contact telephone numbers (landline and mobile), we ask you to inform us as soon as possible by calling us at the Contact Center: +33 07 52 82 57 16 (for local and foreign calls), by managing it directly in your “Personal data” section of your ExpertBank profile or by sending us an email to support @ expertbank .financial. In some cases, it may be necessary for us to request additional documents or evidence.

In the event that you do not notify us of these possible changes, you assume that the communications we have sent to your postal or e-mail address, as well as the contact telephone numbers that appear in our files.

Given the nature of the services we provide and the means used, as we have informed you above, for the execution of the contractual relationship with you, we will record the calls and electronic communications that you have with us , as well as the use of computer and telematic records of access to our services as sufficient and definitive means of proof of the instructions received and the operations carried out.

Changes to this privacy policy

At ExpertBank, we are committed to keeping this privacy policy up to date to collect any news that may arise in relation to the extent of the processing of your personal data that we carry out. For this reason, it is important that you regularly take the time to read and understand it. Any possible modification that we have to introduce, we will inform you in advance, at least via our website / App and via a personalized message that we will send to you in the private area of ​​your customer profile and to your e-mail address. personal so that you have the opportunity to keep yourself fully informed at all times.

Use of cookies

At ExpertBank, we use cookies, among other things, to improve your browsing experience, remind you who you are when you access your private area or personalize the content so that it interests you.

When you enter the ExpertBank website, we will inform you of the cookies we use and you can configure the analytics, advertising and personalization cookies that you use while browsing ExpertBank.

You can consult our cookies policy for more information.

What are my rights when I provide my data?

We inform you that you have and can exercise the following rights:

• Right of access: you have the right to obtain confirmation of the processing by ExpertBank of your personal data and, where applicable, to access it.
• Right of portability: you have the right to receive the personal data that you have provided to us in a structured and readable format in common use, as well as to transmit them to another entity.
• Right of rectification: you have the right to request rectification of data when it is inaccurate.
• Right of deletion: you can request the deletion of data when, among other reasons, the data is no longer necessary for the purposes for which you gave it to us.
• Right to object: in certain circumstances, you can object to the processing of your personal data. In this case, ExpertBank will stop processing the data, except for compelling legitimate reasons or for the exercise of possible complaints.
• Right to restriction of processing: in certain circumstances established by current data protection regulations, you can request that the processing of your data be limited.
• Right not to be subjected to fully automated decisions: in the event that you have authorized profiling and this is carried out entirely by an automated procedure, you can request the personal intervention of one of our analysts, express your point of view and challenge decisions based on such profiles.
You can exercise the aforementioned rights through the following channels:

• Web: from your customer profile in the “Personal data” section.
• E-mail: support@expertbank.financial / office@expertbank.financial.
• Postal mail: “ExpertBank” 134 Avenue de la Plaine de France, 95500 Gonesse
• Branch: 134 Avenue de la Plaine de France, 95500 Gonesse, France
• Contact Center: +33 07 52 82 57 16

Finally, you can complain to ExpertBank and / or the French Data Protection Agency (as the competent supervisory authority for data protection), in particular when you have not obtained satisfaction in the ‘exercise your rights, by writing to the address indicated above or via our website www.expertbank.financial.

Last updated: July 11, 2019

At ExpertBank, we use cookies on our website www.expertbank.financial and we want to tell you all about them.

What are cookies?

Cookies are data storage and retrieval files that are downloaded to users’ devices when they access and / or browse our website. They even contain a number that allows the user’s computer or mobile device to be uniquely identified, even if the user changes location or IP address.

What are they used for?

Cookies allow us to collect data which could identify or identify your approximate location, the time of connection, the device from which you are accessing (landline or mobile), the operating system and browser used, the most popular pages. most visited, the number of clicks made and data about your behavior on the Internet.

In addition, in some cases, they record information about your browsing habits and preferences that will allow us to provide you with a better and more personal experience, or even show you advertisements related to your preferences every time you visit our page. .

They also allow us to collect data on the use patterns of our website in order to identify problems and make improvements, to develop new products or services and to carry out statistics or measurements of use.

How are cookies activated?

Cookies can be activated in different ways, depending on their functionality. In some cases, insofar as they are necessary for the operation of our website, they are installed while browsing and in others, as your permission will be required, they will be activated when you give us your permission. You can modify this consent at any time thanks to the different configuration options that we offer you later in this cookies policy.

Keep in mind that you can access our page without having to enable all cookies, although disabling them may prevent them from functioning properly.

What types of cookies do we use?

As you browse our page, you may find the following types of cookies and we will explain what they are and what they do:

4.1. Technical cookies

These cookies are necessary to facilitate the correct navigation on our website and to ensure that the content is loaded efficiently, allowing the correct use of the different options or services that exist there. In the private part of the Openbank website, certain technical cookies are also used to meet legal requirements, verify concluded contracts and resolve technical errors in contract flows.

4.2. Analytical cookies

These cookies provide us with statistical information about the use you make of our website which allows us to make improvements, for example if you have had technical problems when accessing certain pages, we can detect them. and improve them.

4.3. Personalization cookies

Personalization cookies allow us to offer you predetermined general characteristics based on the data collected from the user’s terminal, for example: language, type of browser, regional configuration through which you access, etc.

4.4. Behavioral advertising cookies

Behavioral advertising cookies collect information about your behavior based on your browsing habits and allow us to manage advertising spaces more effectively by tailoring content to your specific profile.

How long are cookies activated?

Depending on the type of cookies and what we tell you about each one, cookies may remain active at one time or another.

In the case of session cookies, these are designed to collect and store data while the user accesses a web page, when the browser is closed or the session expires, these cookies disappear.

In the case of persistent cookies, that is, they remain active when they leave the site and the user reconnects, they will remain stored for the time indicated in each case, although you can delete them. at any time.

Who processes or manages cookies?

The data collected in cookies may be managed by both Openbank and by third parties. In the explanation of each of the cookies found above, we inform you which cookies are ours and which are third parties.

Do you have any questions?

If you have any questions about the cookies policy of our website, you can contact us by sending us a letter to Paseo de la Castellana 24, 28046, Madrid or an e-mail to support@expertbank.financial

Finally, we recommend that

Check the cookie policy frequently for information on possible changes.
Read this cookie policy as well as our data protection policy also available on our website, where we explain how we treat your personal data.