RaboResearch processes personal data. We would like to inform you about this in a clear and transparent manner. In this privacy statement we provide answers to the most pertinent questions about the processing of personal data by RaboResearch.
How we deal with the processing of personal data is explained in this privacy statement and examples are given to make this explanation as clear as possible. If you have any questions about this privacy statement, you can find information here about how to contact us.
What does RaboResearch mean by ‘the processing of personal data'?
This privacy statement is about the processing of personal data. What do these words mean?
These are details that say something about you, either directly or indirectly, such as your name and address but also your income. Details about a sole trader, general partnership or professional partnership are also considered to be personal data.
Details about a legal entity are not considered to be personal data. Details about a contact person or representative of a legal entity are, however.
Everything that can be done with personal data, such as collecting, but also storing, using, transferring and removing data.
1. Whose personal data does RaboResearch process?
We process personal data if we have, would like to have or have had a business relationship with you. Or if we have been in touch with you.
We process the personal data of, for example, individuals who:
- show an interest in RaboResearch or our products or services;
- visit our website;
- subscribe to our newsletter;
- we send a newsletter to;
- contact us, for instance by email.
2. What does RaboResearch expect of businesses and organisations?
If your business or organisation transfers the personal data of employees, directors or ultimate beneficial owners to us, we also expect you to inform your employees, directors or ultimate beneficial owners of this. RaboResearch itself also collects data of employees or directors, i.e. without your business or organisation providing them to us, by requesting them from the Commercial Register for instance. And we will also record the data. We expect you to inform your employees and directors of this as well. You can give them this privacy statement, so they will be able to read how we deal with their personal data.
3. Who is responsible for the processing of your personal data?
This privacy statement is about the processing of personal data by RaboResearch, a member of Coöperatieve Rabobank U.A.
4. Which personal data does RaboResearch process?
RaboResearch processes various types of personal data:
Types of data
Examples of these types of data
Examples of the use of these data by RaboResearch
Directly or indirectly identifying data
Name, address, telephone number, email address.
In order to send you a newsletter or to ask you to take part in a survey.
Data that provide information about the use of our website and the app
Cookies, IP address, data about the device you use for online services or our website.
In order to improve the use of the website and the services we provide you.
5. How does RaboResearch come in possession of your personal data?
We receive your personal data because you yourself give them to us, for instance when you indicate that you wish to receive our newsletters or when you leave your details on our website so we can contact you.
We can also receive your details from divisions within the Rabobank Group.
6. What are the purposes and bases for the processing of personal data by RaboResearch?
The types of personal data processed by RaboResearch are stated above. The purposes of the processing of your personal data are given below. The basis for the processing is also given below.
According to the law, each individual processing of personal data must have a legal basis.
For the development and improvement of products and services
In order to be able to provide a high-quality service and for innovation purposes, we develop and improve our services all the time. We do this for ourselves or for other parties.
We also carry out research in order to improve our products and services. This means that we may ask you what you think of our website, for example. You do not need to participate in such a survey.
We may sometimes use other parties to process your data for this purpose. For example to gauge or ask you how we can improve our services. In such cases, these other parties act on the instructions of RaboResearch.
We process your data because we have a legitimate interest in doing so. We may also request your permission for processing your data for the development and improvement of our products and services.
For customer relationship management, promotion and marketing purposes
We process your personal data for customer relationship management, promotion and marketing of our public knowledge. We use your personal data for this purpose.
You can subscribe to our newsletter. We will send you this newsletter by email. You can also unsubscribe to our newsletter. In order to be able to send you our newsletter we need to process your name and email address. If you no longer wish to receive our newsletter, you can unsubscribe by email.
We process your data because we have a legitimate interest in doing so. We may also request your permission for processing your data for promotion and marketing purposes.
8. How long does RaboResearch keep your personal data?
We will not keep your personal data any longer than required for the purposes for which we collected them or the purposes we re-use them for. Rabobank has a retention policy. This policy specifies how long we keep your data. If you unsubscribe to our newsletter, we will not keep your email details for more than one month after you have unsubscribed.
In specific situations we can also keep data for a longer period than the retention period specified by us. For example, if you have submitted a complaint and it is therefore necessary to keep the underlying data for a longer period.
When we no longer need the data for the purposes described above, we may still keep the data for record keeping purposes, in the case of legal proceedings or for historical or scientific research or statistical purposes.
9. Will RaboResearch make decisions about me automatically?
Automatic decisions are decisions about you made by computers and not, or not any longer, by people. According to the law, RaboResearch may use automated decision-making, including profiling. Certain rules do apply, however. At present, RaboResearch does not apply totally automated decision-making. If we do start doing this, you will be informed.
10. Who has access to your data within RaboResearch?
Within RaboResearch only those persons who need your personal data in connection with their duties will have access to them. All of these persons are bound by an obligation of confidentiality.
11. Does RaboResearch also use personal data for other purposes?
If we wish to use data for a purpose other than that for which we were given the data, we may do so if there is a close connection between both purposes.
If the connection between the purpose for which we were given the data and the new purpose is insufficient, we will ask you for permission. If you have given us permission to process special personal data, you can withdraw your permission at any time by contacting RaboResearch.
12. Will RaboResearch transfer your personal data to others and to other countries outside the EU?
a. Within the Rabobank Group
Your personal data may be exchanged between members of the Rabobank Group. Because you have asked us to do so, for example. Or because you are also purchasing a product from another division of Rabobank. We will only share this information if the other divisions abide by the rules of the Rabobank Group: the Rabobank Privacy Code. This code contains the rules all these divisions of the Rabobank Group must comply with. The Rabobank Privacy Code guarantees an appropriate level of protection of personal data.
b. Outside the Rabobank Group
Your data will also be transferred to other parties outside RaboResearch if we are obliged to do so by law, because we must execute an agreement with you or because we will be engaging another service provider.
We will transfer your personal data to a third party if we are obliged to do so. To European or other supervisory authorities for example, such as the Dutch Authority for the Financial Markets (AFM), the DNB or ECB or the tax authorities.
We may sometimes engage other parties/business partners who will process personal data on our instructions. Such as a printing company that sends out mailings to our customers for us and prints your name and address details on envelopes. Or parties carrying out market research on behalf of RaboResearch. Or parties who store data for us. These parties must first be considered sufficiently reliable by us. We can only engage other parties if this is in keeping with the purpose for which we have processed your personal data. Such as for promotion and marketing purposes. In addition, this other party can only be given this assignment by us if this party makes certain agreements with us and has demonstrably taken appropriate security measures and is able to guarantee confidentiality. Your personal data may also be exchanged with other parties engaged by us in our business operations or in the performance of our services.
If we ourselves transfer your data to other parties outside the European Union, we will take additional measures to protect your data. The same rules for protecting your data that are obligatory within Europe do not apply in all countries outside the European Union. If we use a third party outside the EU and, according to the European Commission, the country where this party is established provides insufficient protection for the processing of personal data, we will only transfer personal data to them if other appropriate guarantees are in place, such as contractual agreements approved by the European Commission or on the basis of the Privacy Shield (United States).
13. Which rights do you have at RaboResearch?
a. Right to information
Through this privacy statement you are informed by RaboResearch of what it does with your data. Sometimes we may provide more or other information. For example if RaboResearch enters your data in its incident registers. We will then inform you about this separately, if this is permitted. If there are other reasons for keeping you informed, besides the privacy statement, we will do so. We may send you this information by letter, by email or in some other manner we have opted for.
b. Right of access and right to rectification
You can ask us whether we process any of your data and which data these are. If this is the case, we will be able to grant you access to any of your personal data processed by us. If you believe that your personal data have been processed incorrectly or incompletely, you can ask us to alter or supplement the data (rectification).
c. Right to erasure
In some instances, you can ask us to erase personal data held by us. For example if you object to the processing of your data. Your interests must also outweigh the interests of RaboResearch in processing the data.
d. Right to restriction
In some instances, you can ask us to restrict the processing of your personal data. This means that we will restrict the amount of data concerning you that we process.
e. Right to data portability
You have the right to ask us to send you the data that you have provided us under the terms of a contract with us or with your permission in a structured and machine-readable format and you have the right to transfer those data to another party. If you ask to have data transferred directly to another party, this can only be done if technically possible.
f. Right to object to processing based on a legitimate interest
If we process your data because we have a legitimate interest in doing so, for example when we make telephone recordings without being legally obliged to do so, you can object to this. In that case we will re-assess whether your data may indeed no longer be used for this. If your interests outweigh our interests, we will cease the processing of your data. You will be informed of our decision and the underlying reasons.
g. Right to object to direct marketing
You have the right to ask us not to use your data any longer for direct marketing purposes. It may be that your objection is based only on being approached through a specific channel. For instance when you no longer wish to be contacted by telephone but do still wish to receive our newsletters. In that case, we will ensure that you are no longer approached through that specific channel.
If you have made any of the above requests, we will respond to your request within one month of receiving it.
We may ask you to be more specific regarding your request to access your data. For example if you ask us for access to call recordings. We may then ask you for search keys such as the time and number the call was made from. In very specific cases we may extend the period within which we will respond to at the most three months. In that case you will be informed of the progress of your request.
We may ask you to provide proof of identity when you make such a request. In the case of a request for access and data portability, for example, we wish to make sure that we provide your personal data to the right person. We will then ask you, for instance, to come to the bank and provide proof of your identity and allow us to verify this. In some instances we may have doubts as to whether we can send you the data safely. We may then also ask you to come to the bank and collect the data yourself.
We may decide to deny your request. For example because the rights of others may be harmed or because this is not permitted by the law or the police, the Public Prosecution Service or another government agency. Or because we have weighed up the interests, and the interests of RaboResearch or others in processing the data prevail. In that case you will also be informed.
If your data are altered or erased at your request, you will be informed. And wherever possible the recipients of your personal data will also be informed.
14. Who do you contact at RaboResearch if you have a question or complaint about the processing of your personal data?
If you have any questions about the processing of personal data by us you can contact:
If you have a complaint about the processing of your personal data by RaboResearch you can contact:
15. Can RaboResearch amend this privacy statement?
Yes, our privacy statement may be amended from time to time. If there are any new data processing operations, we will amend the privacy statement accordingly. And if these amendments are also relevant to you, we will draw your attention to this or make the amendments known to you in a distinctive manner. You can always find the most current version of our privacy statement at https://economics.rabobank.com/privacy-and-cookies/.
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