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Note for the Protection of personal information

The BNP Paribas Group highly values the protection of your personal information. For this reason, the BNP Paribas Group has adopted strong principles in terms of protecting personal information.

The present Note is aimed at supplying you with detailed information as to the manner in which BNP Paribas Wealth Management Monaco SAM, a company incorporated in the Principality of Monaco and located at 15/17, avenue d’Ostende 98000 Monaco (hereafter “we”), protects your personal information.

We are in charge of collecting and processing your personal information, which we use within the framework of our activities.

Therefore, we ask that you read the present Protection of personal information note (hereafter “Note”) which gives you detailed information on the protection of your personal information. In addition, we invite you to share this Note with any person whose information you supply to us.

The present Note’s aim is to inform you of the personal information we collect, the reasons why we use it, who we share it with, how long we store it, and your rights and how to exercise them.

This Note applies to all products and services of BNP Paribas, and we may be required to supply you with additional information should the need arise, when you subscribe to a particular product or service.

1.     What personal information do we use?

We collect and use the personal information necessary to us within the scope of our activities, and this notably to comply with the relevant regulations and to offer quality products or personalised services.

We may be required to collect different types of personal information pertaining to you, including:

-       Personal information (name, first name, address and other contact information, date and place of birth, nationality);

-       Identity documents and authentication data (specimen signature);

-       Family status (marital status, matrimonial regime, number of children);

-       Fiscal status (tax identification number, fiscal status);

-       Information regarding education and employment (level of studies, current employment, name of employer, remuneration);

-       Information regarding banking, financial and transactional data (bank details, credit card number, transfers, value of your assets, investor profile, credit history, debt and expenditure);

-       Information regarding your financial situation (solvency, scoring/rating, origins of the assets);

-       Advertising and sales information;

-       Information contained in documents (Board Meeting minutes);

-       As well as other information comparable to the above-mentioned categories.

We may be required to collect the following sensitive information, provided we have obtained your previous and explicit consent:

-       Information regarding your health (for example, for the subscription of certain insurance contracts where it is necessary; the information is processed in accordance with the Need to Know principle).

We will never ask you to supply personal information regarding your racial or ethnic origins, political opinions, religious or philosophical beliefs, union membership, sexual orientation or information regarding administrative or penal proceedings or sanctions, unless this is required by a legal obligation.

 

2.     Specific case of collection of data including indirect collection

In certain circumstances, we may collect and use personal information regarding the persons with whom we carried out or will carry out a professional relationship, such as:

-       Visitors on our internet sites;

-       Prospects;

-       Participants at our events.

We may also be required to collect information regarding persons who are not clients and with whom we do not carry out a direct relationship. This may be the case for example when your employer provides us with information pertaining to you, or when your contact details were obtained from one of our clients, because you are, for example:

-       A member of our client’s family;

-       Guarantor co-borrower(s);

-       Legal representative(s), corporate representative(s) or authorised person(s) of a corporate entity who is a BNP Paribas client;

-       Principal(s) or beneficiary(ies) of a transaction carried out in relation to our client;

-       Employed by a company who is a client of the Bank, holder(s) of a card subscribed to by said company;

-       Beneficiary(ies) of insurance policies and trusts

-       Owner(s)

-       Beneficial owner(s)

-       Company shareholder(s)

-       Employee of our service providers and commercial partners.

Lastly, we may also be required to collect information from:

-       Publications/databases made available by official authorities (for example, the Commerce & Industry Register);

-       Partners supplying marketing lists, provided the concerned person has given their consent to be contacted;

-       Internet sites/social network pages containing information you have made public (for example, your own internet site or social media);

-       Databases made available to the public by third parties.

 

3.     Why and on what legal basis do we use your personal information?

a-     To comply with our legal and regulatory obligations

We are subject to various legal obligations as well as provisions of the banking surveillance authorities. Therefore, we use personal information to comply with said legal and regulatory obligations, including:

-       The fight against money laundering and the financing of terrorism by identifying and verifying the clients’ identity, politically exposed persons, representatives and beneficial owners, proxies through the determination of a risk profile and checking of operations and transactions;

-       Compliance with the relevant legislation in terms of international sanctions and embargoes;

-       The fight against tax evasion, the compliance with obligations regarding fiscal control and declaration, including through the identification of the clients and related accounts;

-       Compliance with the provisions applicable to trusted service providers supplying certificates for electronic signatures;

-       Compliance with banking and financial regulations which require, among others:

o   Communicate to payment service providers who act at our request (for example my payment services initiators and providers of an information service on the accounts, also called accounts aggregators), information on your accounts, transactions and their beneficiaries or respective issuers;

o   Fulfil our declaratory obligations to the ACPR (Autorité de Contrôle Prudentiel et de Résolution) and the CCAF (Commission de Contrôle des Activités Financières) ;

o   Assess your financial solvency;

o   Prevent unpaid debt;

o   Fulfil our duty of advice;

o   Identify for certain services, the categorisation of the investor as well as his/her profile, including his/her knowledge and experience, capabilities and investment objectives;

o   Declare and evaluate the risks to which the bank may be exposed;

o   Set up security measures to prevent abuse and fraud;

o   Detect unusual transactions;

o   Define your credit risk rating and reimbursement capabilities;

o   Control and inform us of risks we may incur;

o   Record where necessary telephone conversations, conversations, electronic mails, etc.

The following list of legal provisions is not exhaustive and may evolve:

-       Respond to official requests made by duly authorised public or legal authorities;

-       Response to a request to exercise rights.

 

b-     To execute an agreement signed with you or to supply you upon request with pre-contractual information

The processing of your information enables us to offer you the services we agreed upon contractually with you. The purpose of the processing depends primarily on the banking products you require (for example accounts, loans, securities, deposits). Your information is used for analysing your needs, for advisory services, the management of your wealth and monitoring thereof, as well as transaction execution.

Therefore, we use your personal information to finalise and execute our contracts, including for the following purposes:

-       Supply you with information regarding our products and services;

-       Assist you and answer your requests;

-       Assess whether we can offer you a product or service and, if appropriate, under what conditions;

-       Subscription to products and services offered by BNP Paribas;

-       Within the scope of managing the client relationship including:

o   Manage and execute products and services such as payment instruments and granting of loans;

o   Evaluate your needs and your knowledge;

o   Wealth management;

o   Distribution of insurance products, the insurer or service provider, depending on the case, being responsible for the processing required to set up the insurance transaction and the provision of service;

o   Security of the payment services you use.

-       Supply products or services to our corporate clients of whom you are an employee or client.

 

c-     For the continuation of our legitimate interests

We use your personal information to set up and develop our products or services, to optimise our risk management and to legally defend our interests, including for the purposes of:

-       Storing proof of transactions or operations,

-       Managing information technologies, including infrastructure (for example, shared platforms), the continuity of activities including IT security,

-       Preventing fraud,

-       Studies and client satisfaction surveys

-       Debt recovery,

-       Creating individual statistic models, on the basis of the analysis of your transactions, in order to define your credit rating score,

-       Creating anonymous statistic models, tests, for research and development, in order to optimise the risk management of the BNP Paribas Group or improve our offering of products and services, whether existing or new,

-       Recording of telephone conversations,

-       Data cross-referencing which does not require consent,

-       Personalisation of commercial offers we make to you:

o   By improving the quality of banking, financial or insurance products or services;

o   By offering you products or services that meet your situation and your profile as we define it.

 

These commercial proposals may be prepared thanks to:

-       Prospect and client segmentation;

-       The analysis of your habits and preferences (visits to the Bank, electronic mail, internet site visits, etc);

-       The transmission of your information to another company of the BNP Paribas Group in particular if you are a client of said entity or may become one;

-       Comparing the products and services you already use and data we hold in relation to you (for example, we may determine that you have children based on the information you supplied, but do not hold a family protection insurance), and

-       Checking transactions in order to identify those that may be unusual (for example, when a large cash debit on your account takes place in a country where you do not reside).

 

d-    To respect your choice when we asked for your consent for specific processing

In certain cases, consent is necessary to process your data, for example:

-       When the described purposes lead to an automated decision with legal effects, concerning you or significantly affecting you, we will notify you separately of the underlying reason as well as of the importance and anticipated consequences of said processing:

-       If we proceed with processing, for purposes other than those described in section 3, we will inform you and, if required, will ask for your consent.

If you have authorised the processing of your personal information for one purpose, we can legitimately process said information for said purposes. You are free to withdraw your consent at any time.

Please note that said withdrawal is only valid for the future. The processing of data effected until the moment of withdrawal is not affected by the latter.

 

4.     Who has access to your personal information?

In order to fulfil the above-mentioned purposes, we only communicate your personal information to:

-       Entities of the BNP Paribas Group (for example, for you to benefit from our full range of products and services) and entities in which BNP Paribas Group holds a participation;

-       Service providers and subcontractors who carry out activities on our behalf;

-       Organisations and public institutions (for example, the ACPR, the Direction du Budget et du Trésor de la Principauté de Monaco, French or Monaco regulators, Monaco legal authorities or financial guarantee body) in accordance with a legal or administrative obligation;

-       Other financial or credit institutions or financial institutions to which we send your personal information within the scope of our commercial relations (for example, correspondent bank, brokers, independent agents, intermediaries);

-       Other companies of the BNP Paribas Group for the purposes of risk management in accordance with legal or administrative obligations;

-       Certain regulated professions such as lawyers, notaries or auditors.

 

5.      Transfer of information outside the Principality of Monaco

Generally, international transfers of personal information outside the Principality of Monaco can only take place on the condition that the country or body to which the transfer takes place has an adequate level of protection or the authorisation of the Commission de Contrôle des Informations Nominatives (“CCIN”).

The adequacy of the level of protection offered by the third-party country must be measured with regard to all the circumstances relating to the transfer of personal information, including the nature of the information, the purpose, the duration of the proposed processing, the legal rules in place in the relevant country as well as professional rules and security measures applied there.

Without prejudice to the above-mentioned provisions, the CCIN holds at the disposal of any concerned person the list of countries with an adequate level of protection, as mentioned in the above paragraph.

 

6.     How long do we store your personal information?

We store your personal information either for the duration necessary to the compliance of applicable regulations, or for the duration defined by our operational obligations, such as efficient account management, efficient management of the client relationship, as well as to respond to legal petitioners or requests made by authorities or regulators.

In a majority of cases, your personal information is stored for a duration of ten years, either as of the end of the business relationship when you are a client, or as of the last contact when you are a prospect.

In the event that the information is no longer required for the execution of contractual or legal obligations, it will be periodically destroyed, unless it is still required for short-term continuation of the processing. Such a case may occur for the following reasons:

-       Breach of storage obligations regarding fiscal matters;

-       Breach of special requirements obliging us to store the personal information for an indeterminate duration, for example in anticipation of legal complaints.

 

7.     What are your rights in terms of confidentiality?

In accordance with applicable regulations, you have several rights:

-          Right of information: you hold a right of information over your personal information. Indeed, you must be informed of the collection of your information and its purposes.

-          Right of access: you may obtain information regarding the processing of your personal information as well as a copy of said information, whatever the medium used.

-          Right of modification: you may modify, complete, clarify or actualise your personal information, if this is incorrect, incomplete, unclear or out of date. You may obtain a copy of the amended information free of charge.

-          Right of suppression: you may demand that all information pertaining to you be suppressed should it be incorrect, incomplete, unclear or out of date. You may also exercise this right when the collection, recording, communication or storage of your data is prohibited.

-          Right of opposition: you may oppose the processing of your personal information, for reasons linked to your particular situation. You have an absolute right, at any time, to oppose the processing of your personal information for purposes of commercial prospecting, including the profiling linked to said prospecting.

You may exercise the above-mentioned rights, by mail addressed to BNP Paribas Wealth Management Monaco, Service Réclamations, 15/17 Avenue d’Ostende, 98000 Monaco, who holds the list of processes in place and which may be consulted by any individual or corporate entity. Please enclose a copy of your identification card or passport, allowing us to identify you.

All automated processing of personal information is put in place upon receipt of the authorisation of the president of the Commission de Contrôle des Informations Nominatives (“CCIN”).

In accordance with applicable regulations, you have the right to challenge the relevant control authority, the CCIN, at the following address: 12, avenue de Fontvieille, MC98000 Monaco.

 

8.     Modification of the personal information

We need you to supply us with the information necessary to our commercial relationship, and to enable us to comply with our contractual and/or legal obligations. Without this information, we are generally unable to conclude a contract with you or to execute it.

We are obliged, in particular, in view of the provisions relating to the fight against money laundering and the financing of terrorism, to identify you by your legitimate documents prior to entering into a commercial relationship with you, and thus to collect and store your signature, citizenship, names, date and place of birth, as well as information contained in your identification document. In order for us to comply with these provisions, you are required to supply us with important information. In the event of any change during the commercial relationship, you are required to inform us immediately. Should you fail to supply us with the required information, it will not be possible for us to enter into and maintain a commercial relationship with you.

 

9.     Do we use an automated decision-support system?

We do not use a fully automated decision-support system for entering into and maintaining the commercial relationship. If, in isolated cases, we exceptionally use such a system, we will inform you separately, so long as the law requires us to.

 

10.   Is the processing of your information automated?

We use semi-automated processing of your information in certain cases in order to measure determined personal criteria (profiling), for example in the following cases:

-          In order to fight against money laundering, the financing of terrorism and criminal offences, we carry out an evaluation of the data (including the subject of payment trafficking)

-          We use measuring instruments to offer you interesting and relevant information on our products. This way, we focus our communication and advertising, including market studies and opinion surveys, depending on the needs.

 

11.   Security note

We have put in place technical and organisational measures to prevent unauthorised or illegal access to the personal information you have supplied to us. As full security of the data cannot be guaranteed in the case of communication by electronic mail, instant messaging and other similar communication means, we recommend that you send any particularly confidential information by another secure means.

 

12.   How can you access the modifications made to this information Note pertaining to your personal information?

In a world of constant technologic evolution, we will regularly update this information Note.

We invite you to consult the latest version of this document on our internet site, and will inform you of any substantial modifications via our internet site or our usual communication methods.

 

13.   How do you contact us?

Should you have any questions regarding the use of your personal information covered by the present Note, you may contact us by mail at the following address:

BNP Paribas Wealth Management Service Réclamations

15/17 Avenue d’Ostende, 98000 Monaco.