Amsterdam Trade Bank N.V. (hereinafter: "ATB") is fully committed to protecting your personal data and in particular your privacy-sensitive data. ATB ensures that this takes place in accordance with all relevant legislation and regulations, such as the General Data Protection Regulation (GDPR).
What is personal data?
Personal data consists of details about you and/or data that is identifiable to you. It includes but is not limited to your name, address, contact details, social security number, ID information, bank account balance, IP addresses, or login records. ATB can ask you for personal data, for example, when you complete a form on ATB’s website, apply for a product or use ATB’s online Internet Banking services. We only process special categories of personal data where this is permitted by law or because this information was made public by you.
Why does ATB process personal data?
ATB processes your personal data in various internal processes. This allows ATB to offer you its services as efficiently and effectively as possible:
- ATB processes personal data to enable its services and to execute agreements with its (potential) customers (e.g. activation of a savings account, granting of loans, maintaining customer relationships and processing of financial transactions for its customers).
- ATB processes personal data for internal analysis, training purposes and product development. This enables ATB to continuously improve its products, services and websites.
- ATB processes personal data of (potential) customers for communication and marketing purposes.
- ATB registers personal data in order to comply with (international) laws and regulations and in order to fulfil our duty of care. For example to comply with legislation designed to combat fraud, crime and terrorism, such as the Anti-Money Laundering, Counter Terrorism Financing and Fraud prevention laws and/or regulations.
- ATB uses personal data for security purposes to prevent fraud and possible resulting damage in relation to its services as much as possible.
ATB has the right to process personal data on the basis of one of the following legal grounds: for the execution of an agreement between ATB and a customer, on the basis of a legitimate interest of ATB, or to comply with a legal obligation.
Personal data received from third parties
ATB uses various external sources to obtain additional information about its customers for customer identification and screening purposes, such as the Chamber of Commerce, Dow Jones, Compliance Link, Bloomberg, newspapers and websites.
Who has access and where is personal data stored?
ATB takes all relevant measures to prevent unauthorized access to your personal data.
Within ATB, your personal data can be accessed only by individuals who need to have access owing to their role and for official business purposes. All of these individuals are bound by a duty of confidentiality.
Your personal data will only be provided to third parties on the basis of legal grounds, for example when information is requested by the tax, investigation or supervisory authorities, or if such is required for ATB to meet its obligations in the agreement concluded with you.
ATB may contract third parties to support the services to its clients. These parties may have (partial) access to your personal data, but only in those cases where these third parties comply with the same legal and security requirements as ATB. Your personal data will be stored in accordance with the EU principles as included in the GDPR. This may be within the EU or countries with an adequate level of protection as established by the European Commission. In some cases this is outside the EU, but in all cases in accordance with the established framework of the GDPR.
ATB stores your personal data no longer than is necessary. The period depends on the purpose for which ATB processes your personal data. Your personal data will be kept as long as you have an agreement with ATB or as long as is required for ATB to meet fiscal and legal obligations (on average 5-7 years after the agreement has ended). Your personal data will be deleted or anonymized after the expiration of the retention period.
What are your rights?
Below are your rights in relation to the processing of your personal data by ATB:
- The right to transparency of information
Amsterdam Trade Bank processes data. This data also includes personal data. You are entitled to clear and transparent information about the processing of this data. You can find this in this Privacy Statement. Sometimes we give you more information, if there are other reasons for providing you with information, in addition to the Privacy Statement. We may do that by means of a letter, e-mail or another channel.
- The right to access, rectification and copy
You have the right to ask for the data about you that Amsterdam Trade Bank processes. The list of data will contain information concerning the source, type, purposes and categories of recipients of the data in question. If your data is incorrect or incomplete, or in violation of applicable law, you are entitled to have your data rectified.
- The right to have your personal data erased in certain cases
You can ask for the data registered about you to be deleted if you object to the processing of that data. An example is if the processing is not legitimate or no longer necessary for the purposes for which the data was collected.
- The right to object to processing based on a legitimate interest
If we process your data because we have a legitimate interest in doing so, you may object to this. In that case we will make a new determination of whether your data should no longer be used for this purpose. We will stop the processing if your interest outweighs our interest. We will inform you of our decision, stating reasons.
- The right to object to direct marketing
You have the right to request that we stop using your data for direct marketing purposes.
- The right to restriction of processing
In certain cases you may request restriction of the personal data concerning you that is processed. For example if the accuracy of your data is contested you can ask to temporary stop processing this data until the accuracy of the data is verified.
- The right of “data portability”
You have the right to request that the data that you have provided to us on the basis of an agreement or which are processed with your permission be delivered to you or transferred to another party. Transferred to another party is only an option where technically possible. A great deal of this information is already available to you via ATB Connect. If you request your data, Amsterdam Trade Bank will transfer it to you in a structured and readable form.
- The right not to depend solely on automated processes in the case of profiling or automated decision-making with legal consequences
We will only make a decision based solely on automated processing including profiling which produces legal effects concerning you or significantly affects you, in case it is allowed by law and we have notified you. In these cases you have the right to express your opinion, to disagree with the outcome and you have the right to have the outcome of the process assessed by a natural person. At this moment we don’t make a decision based solely on automated processing including profiling.
- The right to withdraw consent in the case personal data is processed based on the legal ground of ‘consent’
At this moment we don’t process your personal data based on the legal ground of ‘Consent’.
You can make your request known by sending an email to ATB's Data Privacy Officer: email@example.com. ATB will respond to your request within one month.
If, in spite of ATB’s efforts and the rights described above, you have a privacy-related question or complaint, you can contact ATB’s Data Privacy Officer or submit your complaint to the Dutch Data Protection Authority.
Amsterdam Trade Bank N.V.
P.O. Box 16628
1001 RC Amsterdam
Registered Mail Address
Amsterdam Trade Bank N.V.
World Trade Center Tower
Tower I, Level 6
1077 XX Amsterdam