4.1 As mentioned earlier we are committed to protecting your privacy and handling your data in an open and transparent manner and as such we process your personal data in accordance with the GDPR and the local data protection law for one or more of the following reasons:
For the performance of a contract
We process personal data in order to offer you financial services. Therefore, we require you to fill
appropriateness form with additional data, which will enable us to provide you with best suited product. Such
information, which we are obligated to collect, is necessary for us to be able to provide you with our services.
The purpose of processing personal data depends on the requirements for each product or service our Client
Agreement provides more details with regards to this matter.
For compliance with a legal obligation
There are a number of legal obligations emanating from the relevant laws to which we are subject as well as
statutory requirements, e.g. the Money Laundering Law and various supervisory authorities whose laws and
regulations we are subject to. Such obligations and requirements impose on us necessary personal data
processing activities for identity verification, compliance with court orders, tax law or other reporting
obligations and anti-money laundering controls.
For the purposes of safeguarding legitimate interests
We process personal data so as to safeguard the legitimate interests pursued by us or by a third party. A
legitimate interest is when we have a business or commercial reason to use your information. But even then, it
must not unfairly go against what is right and best for you, therefore, our objective is to process your data in
fair, transparent and lawful manner. Examples of such processing activities include:
• Means and processes we undertake to provide for the Company’s IT and system security,
preventing potential crime, asset security, admittance controls and anti-trespassing measures;
• Setting up CCTV systems, e.g. at ATMs, for the prevention of crime or fraud;
• Measures to manage business and for further developing products and services.
• Sharing your personal data within the Company Group for the purpose of updating/verifying
your personal data in accordance with the relevant anti-money laundering compliance
framework; and Company Group risk management.