KBC would draw your attention to the most important changes in this data protection statement of KBC Bank NV.

• Addition with regard to who to turn to if you have any complaints (see 2.10)
• Clarification with regard to the termination of the customer relationship within the scope of anti-money laundering, taxation (see 3.1), fraud and ethical principles (see 3.3)
• Clarification with regard to the support and advisory services for businesses (see 3.2)
• Clarification with regard to the granting and the use of Kate Coins (see 3.2)

Your privacy is very important to us. Our aim is to process personal data in a manner that is lawful, fair and transparent. In this data protection statement, we explain which of your personal data we collect from you as natural person and then process.

We define several categories of individuals whose personal data we collect and process:

• KBC customers (have entered into a contract with KBC for banking and/or insurance products such as a bank account or an insurance policy)
• Platform users (are not KBC customers but do use KBC’s additional services in the KBC Mobile app)
• Prospects (are not KBC customers and may or may not be platform users but are linked to KBC, for example, as a stakeholder or beneficiary)
• Owners of one or more immovable properties in Belgium.
  

We recommend that you read this information carefully, so that you know the purposes for which KBC may use your data. This data protection statement also contains more information about your data protection rights and how you can exercise them.

KBC Bank NV may make changes to this data protection statement. The most recent version is always available at www.kbc.be/privacy. KBC Bank NV will notify you of every all-important change to the content via its websites, Bolero Online, the KBC Mobile app, KBC Touch, the Bolero App or other communication channels.

We also recommend that you read the KBC cookie policy when you use one of KBC’s digital solutions, such as the KBC website or a KBC application. It explains what cookies are, which ones KBC uses, how you change your cookie preferences and how KBC protects your privacy. The cookie policy can always be found in the digital solution itself. For example, you can consult the cookie policy for the KBC website at www.kbc.be, at the bottom of the web page.

KBC Bank NV is a bank with operations in Belgium and a number of other countries worldwide. KBC Bank NV’s head office is at Havenlaan 2, 1080 Brussels. KBC Bank NV is part of the KBC Group (also ‘KBC’ in the following), which is an ‘integrated bank-insurance group’, i.e. KBC is a group of companies that, through close cooperation, create and distribute banking, investment and insurance products, and provide financial services.

The KBC Group principally focuses on retail customers, SMEs and high net worth customers, and mainly operates in Belgium, the Czech Republic, Slovakia, Hungary, Bulgaria and Ireland. In addition, the KBC Group operates via companies and entities in a selection of EEA and non-EEA countries. KBC Bank has legal branches in various places including Germany, the Netherlands, France, Ireland and Italy. For example, outside the European Union, this concerns countries or cities such as the United Kingdom, the United States, China, Singapore and Hong Kong. These may have their own data protection statement, which differs from this data protection statement. KBC also works with parties outside the European Economic Area. You can read more about this in 5.7.

More information on the activities of KBC Bank NV and the KBC Group is available at www.kbc.be.

KBC Bank NV is the controller of personal data in the context contemplated in this data protection statement.

Aside from that, KBC Bank NV also processes personal data on behalf of other KBC Group entities, such as where KBC Bank NV acts as an intermediary for KBC Insurance or KBC Asset Management. In cases such as those, KBC Bank NV processes the data of customers, insured persons and beneficiaries under insurance policies and under employee profit-sharing bonus programmes of those other KBC Group entities. In so doing, it follows instructions issued by that other KBC Group entity, which acts as data controller.

KBC Bank NV also processes personal data together with other KBC Group entities as joint controllers. You can read more about this in 3.5

If there are good reasons for doing so, such as are explained in this part 3, KBC may also make data available to other KBC entities, whether in Belgium or elsewhere. Or it can process this data if it has been collected lawfully from another KBC entity (in Belgium or elsewhere), Naturally, this is only possible provided there is no legal impediment, such as a confidentiality obligation or a provision of the data protection legislation.

You have a lot of rights when KBC processes your data. When KBC Bank NV asks your consent to do processing, you may subsequently withdraw that consent again whenever you see fit.

If you want to access the data concerning you that is processed by KBC Bank NV, let us know. Some data can be accessed directly by you, such as in the KBC Mobile app, KBC Touch, Bolero Online or the Bolero App.

If you exercise your right of access, KBC will give you as complete a list as possible of your data. It can happen that some personal data from files such as the usual back-up files, logs and stored/archived records (e.g., the existence of a consent) is not included in that list, Such data is not within scope of the data processed on an ongoing basis and is therefore not immediately available. It is possible to request access to data separately (e.g., cookie data).

In certain cases, anti-money laundering legislation prohibits KBC from giving you access to the personal data about you that KBC processes. For example, KBC cannot give you access to an anti-money laundering investigation. The law prohibits this, because the release of such information could compromise the investigation. In such cases, you may request further information by e-mailing dataprotection@kbc.be.

It can happen that certain information held on you by KBC Bank NV is not (or no longer) correct. You can ask for the data to be corrected or completed at any time.

Customers of Bolero services can change certain details themselves by navigating to the settings menu in Bolero Online and the Bolero App, as well as managing their communication preferences.

You can ask KBC Bank NV to erase your personal data. If KBC no longer has an overriding ground for processing your personal data, KBC will erase it. A legal requirement may prevent the erasure.

If you disagree with how KBC Bank NV invokes its legitimate interests to process certain data, you can object to such use. We will heed objections unless there are overriding grounds not to do so, such as when we process data with a view to combating fraud.
Below, you will find the main types of personal data processing operations based on the legitimate interest to which you can object:

You are, of course, free to object to any specific processing of personal data at any time (see 2.9). If you do not specify the reasons for your objection, KBC will interpret your query broadly.

It is possible that you don’t want KBC to process your personal data at all in order to send you direct marketing. KBC respects that. Simply e-mail mypersonaldata@kbc.be, drop in at your KBC branch or your KBC agency or contact our staff at KBC Live. If you are a platform user, KBC will also ask you for the mobile phone number you used to register with KBC.

But even if you exercise your right to object to direct marketing, you might still see an advertising message on a digital solution by KBC or through another channel. This may be a general advertising message, for which KBC does not process customers’ personal data, or to send notifications from the browser regarding the Private Banking newsletter (for which you can withdraw your consent at any time), or a personalised advertising message for which we only process your cookie data. If you don’t want the latter, you can withdraw your consent to the collection of these cookie data and them being used for sending customised commercial messages. You can find out how to do this in our cookie policy.

Some data processing operations and processes are fully automated, without any human intervention. Some automated decisions will have a greater impact you than others, for instance in the case of a credit decision or insurance underwriting. In most cases, KBC calculates these profiles only for customers requesting or using a certain service that requires the use of these profiles (see 3.3 for more information about customer profiles). In other cases, KBC calculates these profiles in advance.

KBC will then inform you on the screens or in the terms of use of its own applications that it concerns an automatically generated decision before asking for your personal data. KBC Bank discloses the logic of this automatically generated decision and its consequences at the moment of processing itself via a link to the ‘Annex to the KBC Data Protection Statement – automated decision-making’, which you will also find at www.kbc.be/privacy.

If you are dissatisfied with the result of such a fully automated decision, you can contact KBC Bank NV via KBC Live or any KBC branch. You can, for example, ask a KBC staff member to intervene or tell them why you disagree with the decision and request to view the decision taken.
Automated decision-making is often based on an underlying customer profile.

You are entitled to ask KBC for personal data that you yourself have provided to KBC with your consent or in the process of performing a contract to be transferred back to you or to a third party.
Legislation lays down a number of limitations to this right, as a result of which it does not apply to all data.

In some cases, you may ask KBC to restrict processing of your personal data. Exercise of this right is conditional. You can exercise your right to restricted processing:

• during the period needed by KBC to verify the accuracy of your personal data if you challenge the accuracy of personal data concerning you that KBC processes;
• where processing is unlawful but you do not want the personal data erased;
• when KBC no longer has a purpose for processing the personal data but still needs it in connection with a legal claim;
• pending KBC’s reply to whether KBC’s legitimate interest weighs more importantly than yours when you have exercised your right to object to processing for which KBC invokes its legitimate interest as legal cause.
  

Depending on the type of customer you are (see Part 1), you can exercise your rights in various ways.

Be as specific as possible when you exercise your rights. KBC Bank NV can only properly answer queries couched in sufficient detail. KBC Bank NV will need to be able to verify your identity in case someone else tries to exercise your rights. KBC may therefore ask for a copy of your identity card when you make such a request. If you are a platform user, KBC will also ask you for the mobile phone number you used to register with KBC.

If you have a question or a comment, you can go to your KBC branch, your KBC Insurance agent or e-mail them to mypersonaldata@kbc.be. This is your first resort for all enquiries regarding data protection.

You can consult, amend or terminate the use of certain data yourself via KBC Touch, the KBC Mobile app, Bolero Online, the KBC Business Dashboard, KBC 4 Business or a branch ATM.

If you would like more information or if you do not agree with the standpoint adopted by KBC Bank NV, be sure to visit the website of the Belgian Data Protection Authority, www.dataprotectionauthority.be. You can also lodge complaints there.

In some cases, you can also exercise your rights directly against third parties. That applies, for instance, to the databases that the National Bank of Belgium (www.nbb.be) maintains, such as its Central Individual Credit Register, its Central Corporate Credit Register and the NBB Central Point of Contact.

You can also exercise your rights if you are a platform user, prospect or property owner. To do so, please send an e-mail to mypersonaldata@kbc.be, stating your name, the telephone number you used to register in the application and, if applicable, the e-mail address.

If you have a complaint concerning exercise of your rights, KBC Complaints Management will be happy to look into it.

• KBC Complaints Management, Brusselsesteenweg 100, 3000 Leuven, or via e-mail (complaints@kbc.be).
• Also via KBC’s electronic channels KBC (including the KBC website, KBC Touch, Bolero Online and the Bolero App).

You can also always contact the ‘Data Protection Officer’ at KBC Bank NV by writing a letter to KBC Bank NV, Group Data Protection Unit (Group Compliance), Havenlaan 2, 1080 Brussels, sending an e-mail to dataprotection@kbc.be.

If you would like more information or if you do not agree with the standpoint adopted by KBC Bank NV, be sure to visit the website of the Belgian Data Protection Authority, www.dataprotectionauthority.be. You can also lodge complaints there.

These reasons have been grouped according to the applicable legal basis.

Mandatory reporting to the National Bank of Belgium

• Financial institutions are required by law to share certain information relating to their customers and proxy holders with the Central Point of Contact of the National Bank of Belgium, de Berlaimontlaan 14, 1000 Brussels, Belgium (www.nbb.be). Consequently, KBC is required to share information regarding its customers’ and proxy holders’ identities and their financial contracts, including information relating to:
  • the opening and closing of accounts, and powers of attorney for those accounts, including the date and the account number;
  • cash transactions;
  • the conclusion and termination of financial contracts and the applicable dates, such as: contracts for safe-deposit box rental, specific investment services, loans, including mortgage loans, repayment loans and open-ended credit facilities.
  • The account balances and financial contracts.
• If any information registered with the Central Point of Contact by KBC is incorrect, you can request that it be corrected or removed.
• The Central Point of Contact registers the information and keeps it for a period of ten years for tax investigation, verification and collection of certain receipts, investigation of criminal offences, to combat money laundering and the funding of terrorist activities and major crimes, solvency investigation in the event of collection of confiscated amounts, data collection by intelligence and security services, bailiffs in the event of attachment, and notarial searches related to tax returns for estates. Access to the information held by the Central Point of Contact is regulated by law. The National Bank of Belgium keeps a list of all requests to access information held by the Central Point of Contact for a period of two calendar years.
• You will find all of the details regarding the Central Point of Contact for accounts and financial contracts in the Act of 8 July 2018, and in Section 322, Subsection 3 of the 1992 Income Tax Code and its implementing decrees.

Anti-Money Laundering Act and preventing the financing of terrorist activities

• Banks must deploy all possible means to prevent, uncover and/or report instances of money laundering and financing of terrorism to the authorities. This is a matter of considerable public interest. KBC Bank NV must therefore take the necessary steps for this, at both central and local levels. For example, KBC has to gather data on customers and groups of customers or issue risk alerts.
• Specifically, KBC Bank NV has to:
  • identify you as a customer, representative or ultimate beneficial owner;
  • verify your identity;
  • determine your profile (in relation to the risk of money laundering), which involves collating various personal and business data, such as whether you’re a politically exposed person;
  • check your actions and transactions and prevent certain transactions and report them to the Financial Intelligence Processing Unit.
• In doing so, KBC Bank NV uses details given to it by you personally, plus data that can come from other channels (like Thomson Reuters’ World-Check, Graydon, Dun & Bradstreet, Swift, Internet search engines, social media, the Internet, etc.).
• For example, KBC Bank NV has to be in possession of a recent copy of your identity card. KBC will therefore scan in your digital identity card (e-ID) as a matter of course, for example if you register at a KBC or Batopin ATM with your e-ID or if you use your e-ID to confirm changes to your address or contact details as held by KBC Bank.
• KBC Bank NV may also process your personal data within the scope of the decision to terminate a customer relationship for anti-money laundering reasons.

Sanctions rules

• In the context of the part they play in fighting terrorism and their obligations under sanctions rules, banks are required to screen customer details against sanctions lists. Transactions are also monitored. In some cases, underlying documents are requested and payments may be held back (see the sanctions legislation as well as EU Regulations 2580/2001 and 881/2002). Here, too, KBC Bank NV uses outside sources such as the Thomson Reuters World-Check.

Prevention of market abuse and conflicts of interest

• Banks are also required (including at group level) to prevent, uncover and report improper use of insider dealing and market manipulation and to notify suspect dealings to the authorities (see inter alia Articles 16 and 17 of the Market Abuse Regulation of 16 April 2014).
• KBC may, directly or indirectly, provide loans, credit facilities or secondary guarantees and insurance contracts to the members of the Board of Directors and persons associated with them, to the members of the Executive Committee and the persons associated with them, and to associated companies. This must be carried out in line with market conditions. KBC has decided to register the identification details of these parties in the persons database so that these parties are recognisable in the systems. In this way, KBC manages to comply with the relevant legislation.

Mandatory use of personal data in banking services

• Banks are responsible for recording transactions in their books of account (required under the accountancy legislation, including the Royal Decrees of 23 September 1992).
• For payment transactions, banks have to pass on details of the originator or payee to the receiving or transferring institution regardless of where it is established (e.g., Section 3 of part VII of the Economic Law Code plus its implementing decrees).
• Banks have to consult certain databases for given types of credit (including current account overdrafts) or to enter information in those databases about the terms and conditions of the relevant agreements and the extent to which they’re complied with. For example, they may:
  • determine your borrowing options and repayment capacity, or make it possible for other institutions to do so;
  • perform risk management;
  • allow the National Bank of Belgium to perform scientific and statistical research and to do the work devolved upon it by law.
• As a rule, KBC Bank NV refers to the Central Individual Credit Register for all grants of consumer credit. The Central Corporate Credit Register keeps the data available for viewing for one year following the calendar month it relates to (under the lending statutes including the consumer credit and mortgage security acts and the Central Individual Credit Register (Chapters 1, 2 and 3 of Section 4 of Part VII of the Economic Law Code), the secondary Central Individual Credit Register legislation (Royal Decree of 7 July 2002), the Act on the Central Corporate Credit Register of 4 March 2012 and the secondary Central Corporate Credit Register legislation (Royal Decree of 15 June 2012).
• MiFID II (the Second European Markets in Financial Instruments Directive) requires banks to allocate their customers to certain categories. Natural persons automatically qualify as non-business customers (or Retail customers), although they can require reallocation as business customers in particular cases. Banks rendering investment advice are required to collect information appropriate to the relevant customer type on the customers’ knowledge and experience, financial resilience, investment objectives, and attitude towards risk and return in connection with products offered to them (see the provisions transposing MiFID II, including the Act of 2 August 2002 and the Royal Decree of 3 June 2007). In addition, under MiFID II banks have to examine whether customers form a certain product’s ‘target market’. Banks whose offering is limited to ‘execution only’ services such as the Bolero platform, also have to collate information according to customer category, which will mainly relate to the customer’s financial knowledge and experience.
• Banks also have responsibility for identifying account holders and the beneficial owners of accounts, safe-deposit boxes or insurance products in the context of reviving dormant accounts, safe-deposit boxes and insurance products (see the Act of 24 July 2008 and the website at www.slapendetegoeden.be to find out more).
• As provided by law (PSD2), KBC as bank is obliged to provide access to the balance and transaction information of its customers’ payment accounts, insofar as the customer has installed an online app. This access is only granted to third parties that are authorised to operate in Belgium (including other banks) and based on the consent granted to these third parties by the customer. KBC does not have the right to verify the validity of the consent granted to such third parties.
• The National Bank of Belgium requires banks to request a certified Energy Performance Certificate for home loans. This certificate is also compulsory if a home qualifies for an interest subsidy. KBC also processes the information in order to monitor the value of the loan portfolio.
• As borrower, KBC must annually inform the Vlaams Energie- en Klimaatagentschap (VEKA) i.e. the Flemish energy and climate agency (in Dutch only) about the interest paid by borrowers for a renovation loan. VEKA then later pays an interest subsidy to the borrower if the conditions, such as improved energy performance, are met.
• Under the Shareholders Rights Directive II, listed companies have the right to identify their shareholders. When listed companies exercise this right, as intermediary KBC Bank is obliged to pass on data such as the identity, place of residence, e-mail address, a legal entity’s registration number, etc.

Carrying out the Compliance function

• KBC can use personal data for the purposes of checks, investigations and opinions in areas subject to compliance considerations (such as prevention of money-laundering and fraud, investor and consumer protection and data protection).

Other risk monitoring

• Banks are responsible for appropriately controlling risks (including at group level). They are required to detect, prevent, mitigate and address risks. Examples include credit, insurance, counterparty and market risk, risks concerning information management and statutory compliance, the risk of staff, customer and/or supplier fraud, the risk of unethical behaviour by staff or breaches by them of their duties of care. Risk management has to be ensured at both central level (gathering data on customers and groups of customers) and local level (e.g., circulating risk alerts). In this context, all forms of risk profile are moreover stipulated (see the provisions governing credit institutions, inter alia the Credit and Stockbroking Institutions (Status and Regulation) Act of 25 April 2014 and the Insurers and Reinsurers (Status and Regulation) Act of 13 March 2016).
• Mandatory disclosure and reporting to the authorities
• Banks also have to respond appropriately when you exercise your rights under the data protection legislation: they are also required to answer questions from the Data Protection Authority, such as if a complaint is made.
• Banks have reporting duties and need to respond to questions to and from the authorities and bodies with supervisory duties relative to financial institutions such as the Financial Services and Markets Authority (www.fsma.be), the National Bank of Belgium (www.nbb.be) and the European Central Bank (‘ECB’ – in the context of certain of its oversight functions, including the Credit and Stockbroking Institutions (Status and Regulation) Act of 25 April 2014 as well as the Act of 2 August 2002 (AnaCredit reporting)).
• Upon a customer’s death, the tax legislation contained within the Inheritance Tax Code requires banks to file an official list of the deceased’s assets with the authorities (such as the Inheritance Tax Code).
• Banks have to respond to queries from the tax authorities or may need to voluntarily exchange information for the purposes of tax law (the Income Tax Code, the Foreign Account Tax Compliance Act (FATCA), the Common Reporting Standard (CRS)), and the European Directive on administrative cooperation (DAC 6)).
• KBC Bank NV may also process your personal data within the scope of the decision to terminate a customer relationship for tax reasons.
• Banks also have to respond to enquiries put to them by the courts administration (covering law enforcement right from the police, through investigating judges and prosecutors to trial courts) and especially concerning matters falling under the police statutes and court procedure in general (whether civil (Judicial Code) or penal (Criminal Investigation Code).
• In order to comply with the European Directive on the protection of whistle-blowers, KBC processes reports in the EQS Integrity Line www.eqs.com. The application guarantees whistle blowers’ confidentiality and anonymity (as an option) during and after the investigation, and reports the result internally and to the relevant authorities.

Financial services

Before KBC Bank NV concludes a contract for a financial or banking product, it may be necessary for certain information to be processed and/or to be analysed for profiling in order to deal with the application and assess properly whether the agreement can be concluded and, if so, under what terms and conditions. Examples include information collated and processed when a credit application is received (whether this involves an estimate of the property on which a mortgage or other security instrument is established makes no difference here), or when we are requested to issue a bank guarantee and process the contact details of the beneficiary or their contact.

KBC offers its services through various channels, directly in the KBC branches, via KBC Live or in the KBC apps, as well as through intermediaries.

As a customer of KBC Bank NV, you use various services and your doing so renders administrative and accounting processes incumbent on KBC Bank NV. Examples of processing for the performance of contracts include the administration of accounts, payments, deposits, lending, credit monitoring, monitoring security arrangements, safe-deposit boxes (physical or digital), custody, financial instrument transactions, investment advice or wealth management paying due regard to your investor risk profile, selling insurance and brokering financial leases, etc.

When you perform a payment transaction, KBC Bank NV passes the payee information on the transaction’s progress (e.g., general information on why the payment is not passing via a direct debit).

KBC processes the personal data of representatives of legal persons in order to authenticate and communicate with the legal persons and to exercise the company powers for KBC services and products.

Security Deposit Savings Accounts can be set up on the KBC website by the tenant or the landlord: the facility is open to both the facility is open to both, but the tenant, who becomes the holder of the Security Deposit Savings Account, is the bank’s customer. And the tenant’s personal data, like every other customer’s, gets processed by KBC. The landlord, on the other hand need not necessarily be a customer of the bank’s. But because we have to be able to identify them and the subjects of let in respect of which the escrow is bailed, we also process certain necessary personal data of the landlord.

To be able to give investment advice that’s more personal to you, KBC Bank NV combines the information in your investor profile with certain other details (such as your age and your investment horizon) to gauge your attitude to losses you might incur.

KBC Bank NV engages in bank-insurance business and therefore works closely together with KBC Insurance. To facilitate this, KBC Bank NV and KBC Insurance have a large sales network of bank branches and insurance agencies.

KBC wants to make investment advice accessible to a wide audience, which includes the use of digital channels. KBC calculates behavioural forecasting MiFID customer profiles based on historically available personal data such as transaction data, combined with personal characteristics. KBC calculates the customer profiles specifically for the department where the associated administrative and accounting processes are executed.

Additional services offered in the KBC Mobile app

• KBC’s own products and services

In the KBC Mobile app, KBC Bank NV offers its customers a few of its own non-financial products and services outside the general fields of banking and insurance, which may also be available to platform users, e.g., Goal Alert, Digital Safe, Digital My Real Estate Dashboard and Joyn loyalty cards. KBC Bank NV processes personal data to provide these services and, if the service functionality so requires, personal profiles calculated for that purpose.

• Partners’ products and services

In KBC Touch and the KBC Mobile app, KBC Bank NV offers its customers non-financial products and services of partners outside the general fields of banking and insurance If data needs to be exchanged to ensure efficient use of the partner’s service, KBC will inform the customer accordingly in the process. KBC also ensures secure payment. This information is also available in the KBC Mobile app.

To enable such apps to function properly, KBC exchanges personal data with the partner company, whereby KBC is usually the data controller in its environment (for payments or, for example, to pre-populate a form with your data) and responsible for the transfer of customer data to the third party. The partner company is the data controller in the context of the service to be provided (such as issuing your ticket).

Through the KBC Mobile app, KBC also wants to give you access to your personal government documents that can be consulted electronically in My e-Box. The condition is that you link your My e-Box account to the KBC Mobile app. Only you get to see the documents. KBC cannot see or process the content of the documents. If a new document becomes available for you, you will be notified.

KBC also develops specific applications for entrepreneurs, such as the cooperation with Go Solid NV for the collection of invoices, or with NOWJOBS NV for the recruitment of temporary staff. In the KBC Business Dashboard, an online application for businesses, KBC also makes services of third parties available. With your account, you can log in to companies that provide specialised services for businesses, such as BrightAnalytics BVBA, Cashforce NV and Soluz.io NV. In order for you to log in securely, KBC exchanges identification data (surname, first name and your identification number with KBC or a specific identification code) with these companies, subject to your consent. You can find NOWJOBS in KBC Mobile under Additional services – Offers for your business.

You must contact those third parties for more information on the protection of your personal data and to exercise your privacy rights.

Payment services remain the core of the KBC Mobile app. KBC integrates the Payconiq by Bancontact app in the Mobile app so that you can easily buy something or transfer money to an acquaintance without a bank card or cash. For the latter, it suffices to select your contacts from the contact list on your phone. KBC asks your consent to view that contact list and shares your selected contacts’ mobile phone numbers with Payconiq, under the responsibility of Payconiq, in order to make the payment possible. ‘Split group expenses’ is a KBC service integrated in the Mobile app that allows you to share expenses with your acquaintances. This service also uses your phone’s contact list. When you use the service, KBC sends a text message with a request to the acquaintance(s) you have selected.

Partners’ products and services for platform users

If you are a platform user, you too may use some of the above-mentioned services in the KBC Mobile app. In order to be able to offer you the services, KBC needs some information from you (e.g., mobile phone number, e-mail address, date of birth). KBC keeps your personal data in order to be able to provide the service and to simplify the purchase of such services in the future. In order to avoid your having to fill in these data over and over again, KBC will keep your data for a limited period of time. If you do not use the services for a certain period of time, KBC will delete your data. You may always remove your data yourself by deleting your profile in the KBC Mobile app.

Ask Kate for help

Kate, the personal digital assistant, is a service within the KBC Mobile app.
The Regulations for the KBC Mobile app specify what you can expect from Kate and how the assistant works. If Kate is unable to assist you further, she can refer you to KBC Live.

• 'Extra convenience’

If you accept the Regulations for the KBC Mobile app, you can opt for ‘Extra convenience’ (you can deactivate this feature at any time in KBC Mobile), in which case KBC will provide you with the following services:

• your advanced digital assistant Kate proactively offers personalised assistance and can send you messages about products, services and applications offered by KBC if you use other KBC applications for which Kate has been activated. To allow assistance to be provided and hence to be able to anticipate your behaviour, wishes, risks and needs, Kate analyses the current and past information KBC has on you – personal data or information regarding you in your capacity as legal representative – and your family, such as transaction details, your use of the products, services and applications offered by KBC as well as insights gained through market analysis, general customer behaviour analysis and general analysis of the use of KBC products and services. Kate will apply these analyses to your specific individual or family situation (profiling) in order then to be able to offer a personalised service.
• If you use ‘Additional services’ in the KBC Mobile app, KBC may use the data processed in that context to provide you with ‘extra convenience’ relating to services as well. For example, KBC can proactively consult the data it shows you when you go to the Sodexo service, so that Kate can you let you know when you’re about to run out of Sodexo service vouchers. An up-to-date list of eligible additional services can be found here.
• Additional information in the KBC Mobile app or KBC Touch, such as the location where you performed a transaction, the merchant’s brand name and logo, etc. to help you understand and identify the context of the transaction as a holder of a KBC Basic Account or KBC Plus Account;
• Useful insights that may draw your attention to things that we assume you should take a look at, such as unexpected behaviour on your current account or in your expenses, or an expectation that your account is insufficiently funded.
• When you purchase certain KBC products or services, or carry out certain actions in KBC Mobile, you earn Kate Coins, KBC's digital coin. To correctly grant those Kate Coins, KBC must process your specific behaviour, or the purchase of certain products or services that allow you to earn Kate Coins in this context.
• We also need to register and display Kate Coin transactions and the balance on KBC Mobile. We keep this information until the expiry date of the Kate Coin concerned. To let you use the Kate Coins, we register the exchange of the Kate Coins for a specific benefit, e.g., a webinar, or for a cashback on the purchase of a certain product.

You can deactivate ‘Extra convenience’ at any time without affecting the functioning of the KBC Mobile app. You will still be able to ask Kate any questions you have.
KBC can also communicate with you separately from the Kate terms and conditions. In that case, personal data will only be processed if KBC has another valid legal basis for doing so.

• Ask Kate a question

You can still ask Kate any questions, even if you’ve deactivated ‘Extra convenience’. You decide how to use the service. You can ask Kate simple questions by speaking or typing them in the chat function about banking and insurance matters and about other products, services and applications offered by KBC. To answer your questions, Kate uses the necessary, limited personal data. If you don’t ask Kate anything, no personal data will be processed for the digital assistant. Answering some questions might require a more comprehensive analysis of personal data. This will only occur if you opt for ‘Extra convenience’.

Expense management for business owners

The KBC Mobile app and KBC Touch provide holders of a KBC Company Account with the ‘send expenses’ service (when activated), which gives you an overview of anticipated expenses on the account based on your transaction data.

Support and advice for businesses

For the more complex needs and requirements of SMEs and Corporate Banking customers, KBC offers specific support and advisory services such as, for example, on growth strategy or the optimal approach to working capital. To this end, KBC processes your personal data related to your business, such as product ownership, product usage and transactions.

In addition to compliance with statutory duties, the performance of a contract and consent, KBC Bank NV and the KBC Group as commercial undertakings have certain ulterior legitimate interests on the basis of which they process personal data. These are inspired by the need to function as a business and to enable new initiatives to be developed and offered to customers. In that regard, KBC ensures that the impact on your privacy is kept to a minimum and that, in all events, KBC’s legitimate interests remain proportionate to the impact that upholding them has on your privacy. Nonetheless, if you harbour an objection to this use being made of your data, you may exercise your right to object. KBC will respect your objections unless KBC has compelling reasons for not doing so.

There are various situations in which KBC processes personal data:

Risk management, security and measures to prevent fraud
Identification and prevention of major risks, such as the risk of fraud, cyber and credit risks, based on in-depth data analysis

• KBC Bank NV uses your personal data, including transaction data, to conduct studies, create models and generate statistics for various purposes: regulatory reporting, more effective internal control, fraud analysis and combating fraud, risk analysis, security and other non-commercial purposes.
• KBC develops risk signals. Your behaviour influences the risk signals. If KBC detects from internal or external sources that you are in arrears with the repayment of a credit, that you are misusing your payment or credit card, that you are part of a collective debt repayment scheme, that you gamble heavily, that you are involved in a fraud case or a money laundering case, that you are providing your cooperation to terrorism, weapons or human trafficking, etc., this will be identified as a risk signal, which may have considerable consequences. A result may be that KBC won’t give you credit or that a local branch cannot decide on a credit, that an employee must consult the compliance department before dealing with you, that KBC doesn’t want to do business with you or decides to terminate the relationship.
• KBC can use your personal data to prevent, detect and investigate fiscal fraud in conjunction with (Belgian) payment systems and providers of other payment services.
• Data processing may be carried out in order to guarantee the safety, security and monitoring of persons and goods.
• Personal data, including biometric data can be used for various purposes, including to detect and put a stop to fraud and cyber risks. For example, every time you add a KBC Debit Card in the Payconiq by Bancontact app, Bancontact Payconiq Company sends data such as the card number and IP address to KBC through a secure channel, which KBC can then analyse further.
• KBC shares the personal data (including subsequent updates) of the legal representatives and ultimate beneficial owners of any company that is a KBC customer with other banks where that company is a customer or wants to become a customer. Subject to the same conditions, KBC can also receive personal data about the legal representatives and ultimate beneficial owners from other banks. The purpose of this exchange is for every bank to have the most up-to-date KYC data of its customers. This is how KBC Bank NV contributes to the fight against fraud and money laundering. Moreover, it may simplify and accelerate the customer onboarding process for both the company and the bank. KBC Bank NV cooperates with Isabel and other associated Belgian banks in this regard.
• When you purchase certain KBC products or services, or carry out certain actions in KBC Mobile, you earn Kate Coins, KBC's digital coin. To correctly grant those Kate Coins, KBC must process your specific behaviour, or the purchase of certain products or services that allow you to earn Kate Coins in this context.
• We also need to register and display Kate Coin transactions and the balance on KBC Mobile. We keep this information until the expiry date of the Kate Coin concerned. To let you use the Kate Coins, we register the exchange of the Kate Coins for a specific benefit, e.g., a webinar, or for a cashback on the purchase of a certain product.

Use of personal data for the KBC organisation

Use of personal data for internal and regulatory reporting and internal control, and to defend rights and communicate as a company

• KBC may utilise personal data for the administration, (risk) management and oversight of the KBC Group’s organisation, such as the legal department (including dispute management and legal risks), risk management (such as general credit risk and insurance risk calculations vis-à-vis customers and groups of customers worldwide), risk functions (e.g., Compliance, for all duties not strictly required by law but that are in fact necessary or useful) and inspections, complaints management and internal and external audit. We retain personal data for possible future evidential use. Storage may be entrusted to outside third parties.
• KBC may utilise personal data to support and simplify the processes of customers beginning to use, using and ceasing to use products and services, including avoiding resubmitting information you’ve already submitted. To avoid your having to go through an entire ID verification process if you want to become a customer elsewhere in the KBC Group. Thus, KBC Bank NV may pass on details of your identity to other companies in the KBC Group in order to speed up their process of verifying your identity.
• KBC may also utilise personal data for determining, exercising, defending and preserving the rights of KBC Bank NV or persons whom it might represent (e.g., in disputes).
• KBC can use your personal data to create synergy, increase efficiency and produce other benefits for its organisation and processes. For instance, KBC can combine aggregate data from customers with publicly available data to optimise the integration of KBC bank branches and independent KBC Insurance agencies.
• KBC processes personal data for internal reports and reports required by the authorities, for risk management, for the organisation of internal controls, but also to defend KBC’s rights and to communicate as a company.
• KBC may also collate personal data that KBC entities have at their disposal for creating segments (such as private individuals, businesses and private banking).
• To provide you with good service, it is important for us to share information within the organisation and to group that information together in the hands of (central) relationship managers, for instance in a CRM application to maintain your customer overview.
• KBC cooperates with preferred third-party service providers for its range of banking and insurance products (see 3.2). To be able to screen and later contact possible future merchants, KBC collects identification and contact details of these potential trading partners. The data may have been communicated to KBC in response to a business event or published on social media or be publicly available.
• KBC keeps the contact details of journalists obtained directly or indirectly, so that KBC can contact them at the appropriate time. For example, to contact the press in case of news updates.
• KBC is an international organisation that works and communicates in Belgium’s national languages, English and various other languages. Translations are essential in that regard. Many of the source texts and translated texts contain personal data. KBC Language Service deletes these data at the latest 90 days after the translation.
• KBC wants to offer its customers a personalised customer experience, irrespective of the channel the customer has selected (branch, KBC Live, KBC Mobile app, Kate). Information you share with a staff member may be stored in the customer relationship management system for retrieval at a later date or in another channel.

Linked to the provision of certain services

Personal data is processed to support ICT systems and software, improve processes, coach staff and improve services

• While apps are being developed, tests need to be carried out using personal data, including the final acceptance test before an app can be put into production Where necessary, this may be done in conjunction with third parties appointed by KBC.
• If KBC investigates issues in applications, it may process personal data for that purpose.
• Incident management solves issues at customer level. When IT systems’ integrity has been compromised, KBC can resolve issues by recreating missing factors, as part of which KBC processes personal data.
• KBC may use personal data in evaluating, simplifying, testing or improving its processes, digital apps and standard-form documentation and to optimise promotional campaigns, simulation exercises and online sales, such as by using information from cookies (e.g., preference settings and click and browsing behaviour on our website) to follow up on a simulation left uncompleted, statistics or a satisfaction survey.
• KBC uses services provided by third parties (infrastructure management) that monitor, investigate and, where necessary, restore the performance of KBC infrastructure and software. During these processes, personal data may temporarily be visualised as a technical object. KBC concludes contracts by way of security and provides for technical security both internally and externally to minimise the processing of personal data and maximise security.
• KBC records telephone conversations for purposes related to training and coaching its staff and improving the quality, security and oversight of processes, for brief periods of one month.
• The dealings of KBC’s ‘Corporate Mergers & Acquisitions’ team (M&A) extend over all and any types of KBC products and services. It is possible that, in the process of acquiring or disposing of some part of its business or another, KBC might exchange personal data with companies in the KBC Group and third parties.
• Even though there might be no legal obligation to verify the Central Individual Credit Register, KBC always does so when lending to consumers.
• KBC processes personal data, including transaction data in order to gauge your knowledge and experience in relation to investments with a view to protecting investors (MiFID).
• To ensure each property estimate is as accurate as possible, KBC performs a few calculations (such as the construction area, roof surface and volume) based on the address (obtained from the Land Registry or purchased) for every property having an address in Belgium. These calculations can be enhanced using data collected through specialised third parties (such as Vansteenlandt). These property estimates are used for the ‘My Real Estate Dashboard’ service or for third-party services, or in the context of potential mortgage lending.
  

Developing models for customer comfort and for marketing purposes

Support of commercial activities based on in-depth data analysis

• Insight gained from analytical models allows KBC to build customer profiles. KBC then adjusts the model both to you as an individual or at the level of your family and may also, exceptionally, apply it to another person for the following purposes:
  • Gathering data from different companies of the KBC Group in these analytical models makes it possible to obtain data-driven insights that support the KBC Group in making strategic choices; and
  • Developing commercial policies, taking into account customers’ behaviour and wishes.

Profiling for marketing purposes

Use of data for personalised commercial messages about KBC products and services

• Profiling to personalise and steer direct marketing. KBC Bank uses them to offer customers, prospects or platform users KBC’s and KBC partners’ products and services (see 3.5.3) or to determine the commercial policy for a particular person.

Ensuring the best possible customer experience

• Customisation of product and service offers by both itself and third parties.
• KBC uses personal data to send you messages or to contact you in connection with services you’ve requested from KBC or from a third party through the KBC Mobile app, for instance to remind you to repay your outstanding credit card balance before the due date. You can disable these messages in the KBC Mobile app (under Profile/Notifications).
• When you fill in a KBC Bank NV form, we naturally process the data needed to administer the process that you completed it for. This means that data you enter during a simulation may be stored in the meantime, saving you having to enter it again if you interrupt the process or want to start again later.
• If you started a simulation or sales process but stopped before completing it, we may contact you to see what went wrong and whether we can help; i.e., technical and administrative support for that specific process.
• KBC can use your ‘being a customer’ to determine the preferred channel (branch, KBC Live, the KBC Mobile app, etc.) that it will use to get in touch with you. You can of course still choose how you want to contact KBC.
• KBC may text you to confirm an appointment or remind you that you’ve missed an insurance policy renewal or a loan repayment or that your account is insufficiently funded for a payment order to be executed. You can switch these notifications off in the menu for managing your text message settings.
• Communication via the KBC Mobile app’s start screen
• In the case of customised service in digital assistant Kate, profiling occurs based on the contract that the customer has signed with KBC to this end (see 3.2).
• Digitisation of KBC services and products to improve their accessibility and user-friendliness with additional personalised information
• KBC processes customer profiles to be able to send relevant messages and information.
• Information regarding your investment profile may be exchanged between KBC Group entities, as well as insurance agents, for the provision of investment or insurance advice, so as to avoid you having to provide the same information again in the context of an advisory meeting, depending on the delivery channel chosen, and to ensure uniformity and consistency of the profile.

Product and service offering

Data processing needed to offer (digital) solutions and determine the relevant KBC strategy

• KBC can use your personal data to make you a better offer than at present or to give you a commercial discount. KBC calculates the commercial discount for all customers, irrespective of any specific request. To this end, KBC analyses the behaviour and a few relevant characteristics of the customer based on customer profiles.
• To be able to respond effectively to other customers or prospects (such as when preparing simulations or tenders) and where KBC Bank NV makes unsolicited offers in bespoke form, it can occur that, in the form of carefully shielded underlying processes, it may look at your customer profiles. There is naturally no question of your personal data being divulged to anyone in this context.
• Creation of profiles to tailor KBC’s commercial and product strategies to customers’ behaviour and wishes.
• Preparation of internal reports on the use of processes and products by customers and platform users to evaluate and determine KBC’s commercial and product strategies. In this case, personal data is aggregated to the extent possible.

Offer of aggregated insights

• KBC may aggregate personal data to assess rapidly changing consumer behaviour and thus predict economic trends, to produce reports for internal use.
• KBC Bank NV anonymises your data so that they can be publicised, for instance if, on the occasion of Batibouw it wants to publish statistics on the numbers of home loans applied for or granted. KBC Bank NV may at the same time carefully draw anonymised insights from personal data and subsequently offer those insights to the market. KBC may provide these aggregated reports as a service or make them available free of charge to organisations in its social role and to partners in order to provide insight into the purchase of their services through KBC channels. This enables these third parties to further refine their offer or strategy.

Mobilisation of appropriations

• If a credit claim is mobilised from a credit agreement, we may disclose the obligations and, based on legitimate interest, the necessary details of the borrower and guarantor concerned to the transferee for the management of the claim. Mobilisation of credit claims is effected, among other things, in the form of securitisation, assignment of receivables and in the context of covered bonds. The recipient guarantees the confidentiality of the data.
• KBC Bank NV may disclose information about the credit agreements and the way in which they are executed to:
  • all stakeholder third parties with a legitimate interest (such as the National Bank of Belgium) or third parties to whom the credit agreement may be transferred or assigned;
  • parties that can assign a rating to relevant securitisation transactions.
• To improve the operation of market forces when credit agreements are converted into securities, the European Central Bank and the EU authorities impose reporting requirements. These reports are not by named individual but by contract detail (such as number of borrowers, term and due date of the credit, outstanding credit amount, payment arrears, characteristics of the mortgaged pledge). This information must be made available to investors in these financial instruments (often designated as Asset-backed securities or Residential mortgage-backed securities). You will find more on this on the website of the European Central Bank: www.ecb.int (keyword: loan-level).

Corporate customers

• KBC sends messages to its corporate customers, which may be for informational purposes. These messages may include a call to action. In order to reach these customers, KBC sends the message to the representatives designated by the company. For the calculation of the corporate customer’s profile, KBC only uses the company’s data and not the representatives’ personal data.
• KBC may also send advertising messages addressed to the company which also involve the processing of the representatives’ data. Representatives may object to this use.

You can read more about consent for direct marketing in 3.5.2.

KBC will request your consent to process:

• PSD2 data that you have personally added in KBC applications such as the KBC Mobile app for commercial models and profiles;
• geolocation data (unless expressly stated otherwise);
• data entered by you in a simulation or competition entry form in order to send you advertising messages;
• underlying data of a form that needs to be completed with certain information for KBC to be able to process the form, in which case KBC will generally ask you to check the data’s accuracy;
• your contact details as representative of your company when we transfer them to, for example, Cashforce;
• biometric data used for identification purposes;
• to answer questions asked by third parties, unless there is another legal basis for doing so, such as a statutory duty;
• KBC will request your explicit consent for the processing of health data;
• to send notifications from the browser regarding the Private Banking newsletter. Each notification includes information on how to withdraw your consent. If you are no longer able to make your own wishes and needs known, a carefully drafted lasting power of attorney can guarantee that your personal wishes and needs are translated correctly from a lawful point of view, including in banking matters. KBC will respect that expression of your will and your appointed proxy holder.

KBC may request your consent through all possible channels, such as the KBC Mobile app’s start screen, Kate or e-mail

As a commercial enterprise, KBC Bank NV is keen to be able to suggest a wide range of financial and non-financial products and services to you. It may do so in response to explicit requests or where it has an idea that you might be interested in or could benefit from a given product or service. KBC Bank NV.

We can reach out to you with this information in all sorts of ways: through KBC bank branches and insurance agencies, over the Internet and in apps, in the KBC Mobile app’s start screen, by sending push messages from our KBC Mobile app, by e-mail, post or telephone, via Kate, and at events. In addition, the constant flow of new technologies gives KBC Bank NV new ways it can embrace to serve you better. KBC is at pains to ensure that information is provided in a way that’s clear and will choose the most appropriate channel to ensure the inconvenience of being disturbed is kept to a minimum.

If KBC Bank NV knows the age, it does not make commercial offers of its own to young persons aged under 16 unless a legal representative of theirs has consented.

Only one of the various options listed under 3.5.1 and 3.5.2 applies to you as a customer. From the moment you receive a proposal to opt for the Direct Marketing contract as set out in 3.5.1, only that situation will apply to you, and your choice for personalised information (3.5.2) will cease to apply. If you do not opt for the personalised agreement, you may still receive direct marketing based on a legitimate interest (see 3.5.3). If you don’t want to receive any direct marketing at all, see 2.5, which describes how to object to direct marketing.
If you are unsure as to which situation applies to you as a customer, feel free to e-mail mypersonaldata@kbc.be for help.

If you choose to enter into a personalised agreement, you will receive personalised communications from KBC. The processing of personal data is therefore essential to the performance of the personalised agreement. The personalised agreement contains information about the services offered by KBC when you opt for the personalised agreement and on how this agreement works.

3.5.1.1 Who is offering the personalised agreement?

KBC Bank, CBC Banque, KBC Asset Management and KBC Insurance (hereinafter: ‘KBC’) have joined forces in order to make you proposals and contact you for advertising purposes in as personalised a manner as possible. These entities can share your personal data with each other for this purpose, to the extent that this is necessary and relevant in order to send you personalised commercial messages. This exchange is also possible if you are not, or no longer, a customer of one of these entities. This enables KBC to approach you based on the overall profile it has compiled of you. This is important in order to ensure that KBC makes you relevant commercial proposals based on your specific situation.
For this purpose, these entities act as joint data controllers. In order to exercise your rights, as described in the general data protection statement, you can contact KBC Bank, CBC Banque, KBC Asset Management or KBC Insurance.

3.5.1.2 What are KBC’s legal grounds for using your personal data?

KBC will only use your personal data for personalised services if you have chosen to enter into this agreement.
KBC invokes contract performance as a basis for delivering Kate Deals and personalised services, as described in the personalised agreement. This concerns:

• analysis and use of personal data in order to create a profile of you and subsequently be able to send you personalised commercial offers and messages. You can find more information about this under point 3.2;
• analysis and use of personal data in order to display Kate Deals to you on a personalised basis and to customise this data at the participating merchant’s request. You can find more information about this under point 3.2.
• contacting you through the most appropriate channel. You may receive commercial messages through a variety of channels (via the KBC bank branches and insurance agencies, the Internet, KBC applications, by post, e-mail, telephone, etc.).

KBC invokes permission to:

• use electronic communication channels to send commercial messages. The personalised agreement always contains a provision for the receipt of electronic communications via push notifications from KBC Mobile, or by e-mail, text, or WhatsApp message. You may choose to change your communication preferences at any time and are therefore completely free to decide how KBC sends you commercial proposals. For example, you may decide at any time to have these communications restricted to the channels of your choice, or not to receive any commercial messages electronically at all. You can make these changes in KBC Mobile (Privacy > Commercial Settings), KBC Touch (Profile > Privacy > Commercial Settings), KBC Live, or at any KBC branch. Even you choose not to receive any electronic communications at all, you can still benefit from the personalised services.
• sending you personalised offers based on your click and browsing behaviour on KBC websites and in KBC applications. KBC respects your privacy preferences and will only store this data if you have given the required cookie consent.

3.5.1.3 What type of data processing is needed in order to provide the requested services?

In order to be able to deliver the services described in the personalised agreement, KBC must be able to predict your behaviour, needs and requirements.

KBC uses all personal data (including transaction data, data obtained from third parties, data obtained from public sources such as the Belgian Official Journal, data and information gathered during conversations with you at the branch or other contact moments, etc.) it possesses on you and any insights it obtains based on general market analysis. KBC combines this data with other data and information relating to your family, business, etc.

KBC may make highly personalised commercial proposals to you, tailored to your needs and interests, by applying this analysis to your individual or family situation (i.e. profiling).

Data processing in the context of personalised commercial messages

KBC conducts in-depth profiling as part of the personalised agreement in order to be able to tailor the advertising messages to your needs. This is because KBC’s intention is to send you commercial messages tailored to your situation as much as possible.

These commercial messages might focus on:

• KBC’s products and services and those of carefully selected partners with whom KBC works in order to provide their services through KBC (e.g., Payconiq, partners for additional services such as 4411, De Lijn, Kinepolis, etc.). You can find an up-to-date list of KBC’s partners at this link. This list is regularly updated by KBC;
• both financial products (including loans, credit cards, insurance products, etc.) and non-financial products (including Kate Deals, purchasing train tickets, ordering service cheques, etc.).
  KBC generally sends these commercial messages to you directly, rather than through its partners. This ensures that KBC can minimise data processing by its partners. KBC has also made contractual arrangements with its partners, in which they confirm that they will comply with the privacy rules.

Data processing in the context of Kate Deals

Calculation and execution of cashbacks

KBC uses the transaction data to calculate and execute the cashbacks you are entitled to. For instance, based on your purchases, KBC can see which Kate Deals you actually redeemed.

KBC works with a number of participating merchants.

• Personalisation of Kate Deals at the request of the participating merchant

These participating merchant can determine whether or not they want to limit their deal to certain customers, based on a set of predefined parameters. This enables participating merchant to more accurately determine the target audience for their Deal. For example, they might decide to limit their deal to customers who have made purchases from them over the past three, six or nine months (or those who just fall short of this mark) or solely to customers who live or shop in a particular province. In order to be able to deliver these parameters, KBC checks your personal details. The transaction details are also reviewed for some of these parameters.

Personal data that may be processed in this context includes transaction data, place of residence, gender, age, household composition, as well as profiles derived by KBC (from customer data), for example, hobbies and what customers do in their spare time. This data is processed either separately or combined. KBC does not pass on this personal data directly to the participating merchant, but instead uses it to determine the group of customers that get to see the deal.

In the context of personalisation requested by the participating merchant, KBC and the participating merchant concerned are jointly responsible for processing the relevant data. Feel free to contact KBC if you have any questions about exercising your rights (as described in the general data protection statement). The data protection statement is available at www.kbc.be/privacy. You can also obtain a copy at your bank branch or from your intermediary.

Since KBC automatically selects for which Kate Deal you are eligible based on the parameter(s) communicated by the participating merchant, some of these decisions may be made automatically. You can read more about how automated decisions are made in the Annex to the KBC Data Protection Statement – automated decision-making.

• Anonymised statistics

KBC sends anonymised data to the participating merchants regarding their Deal, as it was published on the Kate Deals Platform.

Personalisation to show Kate Deals in the most relevant order

The Kate Deals displayed on the Kate Deals Platform have been personalised. Personalisation is a feature of the Kate Deals Platform intended to ensure that the Kate Deals published on the Kate Deals Platform are as closely aligned as possible to your needs and preferences.

KBC creates a profile of you to help personalise the Kate Deals and determine how and in which order they are presented to you. This allows KBC to present you with the Kate Deals that are most relevant to you.

KBC bases this profile on your transaction data, which shows the sectors (e.g., fashion, leisure, etc.) and locations that may be of interest to you. KBC also looks at other personal data, such as your name and address. If you have given permission for KBC Mobile to use your location, KBC will use it to show Kate Deals located near you. If you have consented to the use of cookies, KBC also keeps track of your click and browsing behaviour (e.g., what Kate Deals you have viewed) on the Kate Deals Platform in order to improve the Kate Deals’ relevance.

KBC and the TradeTracker partner platform join forces

To know if you are entitled to a Deal via an external partner, and for the calculation and execution of the cashback, KBC and the partner platform (TradeTracker) need to be able to see if you made a purchase using the unique link on the Kate Deals Platform and for what amount. KBC and the partner platform must also detect any fraud in connection with the Kate Deals via external partners in time.
KBC and TradeTracker are joint controllers for these purposes. Feel free to contact KBC if you have any questions about exercising your rights (as described in the general data protection statement). The data protection statement is available at www.kbc.be/privacy. You can also obtain a copy at your branch or from your intermediary.
The types of personal data processed by the partner platform in this context are traffic data (including IP addresses), where appropriate linked to your purchase (amount and time).

If you have previously consented to receiving personalised commercial messages, this consent will remain valid until you have made a choice regarding the Direct Marketing contract.

If you give explicit consent to receive personalised commercial messages, KBC can make proposals tailored perfectly to your individual situation. You will no longer receive scores of adverts that are of no interest to you. Your consent applies specifically to personalised commercial messages and is unrelated to the processing of personal data in the context of Kate Deals. In this regard, KBC uses your entire personal data (including transaction details and information obtained from third-party sources (such as financial institutions), public sources like the official gazette, the results of discussions at your branch and other contacts). This data is collated along with details of your family and business, and so on, so that KBC is really in a position to provide you with commercial messages tailored to you. You can withdraw your consent at any time, just as easily as you gave it.

Your consent to receiving personalised commercial messages is valid for each of KBC Insurance, KBC Bank, KBC Asset Management, CBC Banque, KBC Securities and KBC Autolease. As regards KBC Autolease, your consent only applies to services that it provides directly to private individuals. These KBC entities are then able to share your data with one another. Such exchanges are also possible if you’re not or you are no longer a customer of any KBC company. This enables KBC companies to look into your situation and proactively suggest alternatives aimed at your specific situation.

You receive the messages directly from KBC and not from the partners KBC works with. These partners are listed in 3.5.1.1 and 3.5.1.2. This ensures that data processing by these partners is limited and they only receive data about you if you personally express interest in the information. KBC has made contractual arrangements with the partners, in which the partners confirm that they will comply with the privacy rules.
Subject to your explicit consent, KBC may send you commercial messages about financial products and services and about non-financial products and services. KBC offers a separate choice for both.
Platform users and prospects cannot opt for personalised commercial messages.

3.5.2.1 Commercial messages about financial products and services (occasionally referred to as ‘personalised information’)

Your separate consent applies to messages about financial products and services from KBC and from carefully selected partners that offer products or services in the general fields of banking and insurance. Those partners must at all times meet the following criteria:

• They must be a provider of financial services or an insurance company. Financial service providers include banks, credit institutions, wealth managers, funds, stockbrokers and lease companies in as far as their offering to private individuals is concerned.
• If legally required, the partner has to be licensed for the financial service or insurance that KBC is offering.
• The messages contain information on products and services from the general fields of banking and insurance such as savings products, investment funds, lending and insurance (both property cover and life insurance).

A list of our current financial partners can be found at www.kbc.be/partners. This list is regularly updated by KBC.

3.5.2.2 Commercial messages about non-financial products and services

Your separate consent applies to messages about non-financial products and services from KBC and from carefully selected partners with whom KBC cooperates in order to offer you their services through KBC. The messages may relate, for example but not exclusively, to the Additional Services that KBC offers in the KBC Mobile app, such as selling tickets or offering new Kate Deals in Kate Deals.

The messages concern non-financial products and services outside the general fields of banking and insurance.

More information about partner services offered by KBC is available at www.kbc.be/partners. This information is updated by KBC on a regular basis.

If you do not want to receive a highly personalised offer, you should not opt for the Direct Marketing contract or consent to receiving personalised commercial messages.

Nevertheless, you may occasionally still receive offers and advertising from KBC Bank NV (e.g., in the KBC Mobile app’s start screen or by e-mail, push notification or text message): based on its legitimate interest, KBC sends offers on the basis of a limited number of data (such as who you are and where you live, your date of birth, your marital status, your contact details, family relationships, the apps and products you use, or any lack of interest on your part in certain products).

These limited personalised commercial messages may concern:

• financial products and services from KBC Bank NV or KBC Insurance and KBC Asset Management; niet-financiële producten en diensten van KBC en van zorgvuldig geselecteerde partners in bijvoorbeeld de Extra diensten in KBC Mobile, zoals de verkoop van tickets. Meer informatie over de partners vind je op www.kbc.be/partners .

Subject to your separate consent for the electronic channels (e-mail, push messages and SMS/WhatsApp), KBC may send you advertising on all products through these channels. In the absence of your consent, we will limit ourselves to advertising on products similar to those you already own. You can manage your consents in the KBC Mobile app, via KBC Live or at your branch.

You can object to direct marketing as set out in 2.5, in which case you will no longer receive personalised advertising.

In order to be able to send you the appropriate message through the correct channel, KBC may also call on other service providers. For this purpose, KBC may cooperate with communication and marketing agencies, and similar companies such as social media players (e.g., Google, Facebook, Instagram, WhatsApp). Sometimes KBC only uses information it has about you or your personal profile information held by them. In other cases, KBC combines those data. Depending on the type of cooperation, they may be processors or controllers (see points 5.2 and 5.3).

KBC uses platform users’ personal data to conduct direct marketing campaigns (e.g., the KBC Mobile app’s start screen or by e-mail, push notification or text message) based on a legitimate interest. This may include services offered through the KBC Mobile app, including Kate Deals, and KBC Bank NV payment solutions. For this purpose, KBC processes the limited set of personal data that the user registered when they activated the use of the KBC platform (surname and first name, address, date of birth, mobile phone number and e-mail address). If the user agrees to the use of cookies, KBC can also send offers based on click and browsing behaviour. Platform users can exercise their right to object to direct marketing, in which case they may still see an advertising message but it will be a general advertising message, for which KBC does not process customers’ personal data.

KBC may send you offers based on your usage patterns on its websites and apps, provided that you consent to the collection of these cookie data and them being used for sending personalised commercial messages. The cookie consent determines which offer KBC can send you. Your cookie data may be combined with other personal data according to the conditions set out under 3.5.1, 3.5.2 and 3.5.3.

KBC uses prospects’ contact details to conduct direct marketing activities. Commercial messages by e-mail are sent only with the recipient’s prior consent. Telephone marketing is always based on a legitimate interest, and KBC respects anyone who is listed on the Do-Not-Call Registry.

You can always choose not to activate the personalised agreement or not to opt for personalised information if you only wish to receive general advertising messages. If you no longer want to receive any advertising at all, you can object to direct marketing. For instructions, see paragraph 2.52.4.

KBC Bank NV does not sell or hire your personal data to third parties for their own use, unless you opt for this yourself by giving your consent or in the context of a service.

The types of data that KBC Bank NV processes are explained below.

KBC Bank NV sometimes processes information that is a matter of public record.

• This might include data that are subject to a reporting duty such as you being appointed a company director;
• Data you personally place in the public domain such as information on your website, in your blog or via your publicly accessible social media profile, information publicly available on the Internet, or information about you that KBC Bank NV has obtained from third parties (e.g., family members);
• Data that is in the public domain, say, because it is common knowledge in your area or because it has appeared in the press. Information from sources such as the companies register and Graydon also fall into this category.

KBC Bank NV may also receive personal data via third parties, for example, but not exclusively, by buying it or obtaining it from the Belgian Land Registry (Kadaster) or from companies such as Blacktiger,, HIS Markit Group Limited, GIM or Graydon, business organisations, etc. that are responsible for making sure that they gather the relevant information lawfully and pass it on to KBC.

In addition, KBC receives personal data from third parties on the instructions of its customers (e.g., account information from an account held at another bank in connection with the provision of account information services).
KBC uses that publicly available data and information from third parties for all processing for all purposes set out by KBC Bank NV in this data protection statement.

If KBC Bank NV wants to identify your location (i.e., geolocate you), KBC will always inform you accordingly and will ask for your consent where appropriate, for instance when you visit certain pages on its websites or if you use a KBC app or technology such as beacons.

KBC Bank NV may send you a message for which your location is important. Or, if you’re at a KBC event, the background in the KBC Mobile app might be modified accordingly, for example. It’s also possible that when you enter a shop, the KBC Mobile app will draw your attention to the fact that in this shop you can pay using MobilePay.

In order to offer you this service, KBC may use a geolocation service provider, such as Google. Google has a privacy policy of its own. You can read it in detail at www.google.com/policies/privacy. We recommend that you take the time to read it. KBC Bank NV can also use the details of your location to construct global models and analyses.

Moreover, we are aware of what your location is on the basis of things like your IP address and your telephone’s technical readings. This information can also be important in relation to things like detecting credit card fraud and improved data protection.

When you contact KBC Bank NV staff at a branch or by telephone, chat or via Kate, this may be registered:

• to constitute a record of contacts between bank and customer;
• so that there is a (short) record of the contact;
• to enable staff to prepare ‘to do’ lists of tasks identified during the conversation;
• to provide you with better service in the future.

Even if you are not a customer, KBC Bank NV will store the information you provide. That information can be used if you subsequently become a customer.

In adopting this approach, KBC Bank NV seeks to avoid your having to constantly provide the same information or answer the same questions. It also allows KBC to improve continuity in the services provided to you.

If you contact KBC Bank NV by e-mail or have digital communication channels that are used by KBC Bank NV (e.g., KBC Touch or the KBC Mobile app), it can use these channels to send you mandatory and official notices, in which case KBC will notify you by push notification.

KBC works on the assumption that correspondence sent to staff members in their capacity as KBC employees (at a branch or on its fax or to a job-linked or personal KBC e-mail address, etc.) is business-related and that KBC is entitled to read it in the context of:

• their duties;
• the production of evidence;
• workplace checks;
• security;
• fraud prevention;
• service optimisation and/or continuity, including the use of automated text analysis and editing to help KBC staff correspond with you quickly and efficiently.

As a customer, you have a variety of ways to get in touch with KBC. For instance, you can contact our commercial staff in the branch network or at KBC Live, contact centres and helpdesks, Private Banking branches, our inheritance experts, the Bolero Call Centre and the dealing room.

Various applications can be used for this purpose. For example, you can call a KBC employee, in certain cases you can start a chat or you may receive an invitation to an online meeting (e.g., in Microsoft Teams). When attending an online meeting, you always have the option to share your screen or enable your camera at your own discretion.

KBC Bank NV may listen in to or record conversations. You will be informed of this at the start of the conversation (e.g., verbally or in a pop-up message on your screen). By taking part in a telephone or video call, you expressly agree to it possibly being recorded.

KBC listens in to or records conversations for various purposes:

• For training and coaching of staff or to improve the quality or security and monitoring of processes. These recordings are kept for a period of one month; due to technical reasons, they may be stored in our back-up files for slightly longer.
  • Production of evidence:
    • In the context of legal duties intended for the protection of investors (MiFID II), KBC Bank NV is required to record and retain telephone conversations and electronic communications that could result in transactions in investment products. KBC Bank NV therefore records the conversations and electronic communications of staff whose work duties relate to investments. If you talk to these experts, specialists or relationship managers or communicate with them electronically, we record it. For evidential purposes and in order to comply with the legal obligations under MiFID II, KBC Bank NV keeps these recordings for ten years. If a dispute arises, KBC will keep them for as long as it needs to defend itself. You can request a copy of this recording.
    • KBC attaches a great deal of importance to secure online banking. To that end, KBC set up the Cybersecurity Service Secure4u, which is available 24/7. There you can report (alleged) abuse, after which KBC will investigate the report and possibly contact you by telephone. KBC may then ask you, for example, to lodge a complaint with the police. KBC also records this telephone call for any subsequent juncture.
  • Service provision:
    • KBC Bank NV may also use automated analyses of conversations to speed up and improve its services. Telephone, video and chat conversations, for instance with Kate, together with other communications and the emotions expressed in them, can then be used in the development and training of artificial intelligence. Artificial intelligence could ultimately allow written or spoken customer communication to be fully automated. Artificial intelligence can support KBC staff and increase KBC’s ease of access. The link to personal data is severed as quickly as possible when developing and training artificial intelligence. To check and improve the quality of verbal chat conversations with Kate, KBC converts the conversation into text. KBC only keeps the original conversation for one month and the anonymised transcription for one year.

KBC Bank NV may use CCTV in and around the offices and premises where it operates. In the case of security cameras, KBC Bank NV observes the special rules that apply. If a security camera is present, KBC informs you by means a clearly visible sticker, for instance. In addition, KBC Bank NV in all events adheres to the ‘besafe’ guidelines issued by the Security & Prevention General Directorate of the Federal Public Service for the Interior (www.besafe.be).

KBC generally keeps images recorded by security cameras in and around KBC Bank NV premises (identified with a sticker) for no more than one month. They may be kept for longer:

• if the recorded images serve as evidence of certain dealings or may depict a criminal offence or unruly behaviour;
• as evidence of damage or in order to identify an offender, trouble-maker, witness or victim;
• where a right of access is exercised, for as long as necessary to respond to the request;
• at locations that present an increased security risk, in which case the period is three months.
• If you have questions about CCTV images, you can contact the CCTV Contact Centre at Egide Walschaertsstraat 3, 2800 Mechelen, or at CCTV@kbc.be.

KBC offers you account information services and payment initiation services, giving KBC access to the balance and transaction information of the accounts you hold with another bank. This is subject to the condition that such payment accounts are accessible online. The account information, which only becomes accessible after you have activated the service, is used by KBC to carry out the requested service. If there are difficulties in connecting KBC to the account- olding bank, limited account information may be exchanged to resolve those problems.

KBC may also use the transaction data obtained to carry out its anti-money laundering and embargo inspections, to monitor and prevent payment fraud and to draw up the required reports. Such activities are mandatory, in accordance with applicable legislation.

If you consent to the use of transaction details from other banks, KBC may also ultimately use this data from other financial institutions to benefit its commercial and service models and its profiling, such as for providing the proactive version of Kate (if you opted to use this). Based on that data, the bank can offer you an even more accurate and personalised service. You may withdraw this consent at any time by toggling ‘Data from other banks’ under ‘Profile’, ‘My privacy’, in the KBC Mobile app.

For instance, if you have a company or children, for example, you agree that KBC Bank NV can also keep a record of those relationships and process the details of any associated persons. We may also process personal data of parties we have no direct relations with but who are involved in a relationship with us, such as being the beneficiary under a life insurance policy or as usual driver under a car insurance policy or as witness to an accident. If you provide information about your family members or related persons, we ask you to inform them of that fact (e.g., of a change of address that you’ve forwarded to us). If needed in order to properly provide services to your family, we may also report limited details on you to your family members, so as to avoid overinsurance for your family.

If you provide information about your family members (e.g., a change of address) or related persons, we ask you to inform them of that fact. For example, when you create a group in the ‘Split group expenses’ payment service, you are required to inform the people you invite to the group that you will share their phone number with KBC for this purpose.

This has the following implications for legal entities:

• Please note that legal entities may only provide us with personal data of natural persons associated with them if those persons are sufficiently informed of this and, where necessary, have given their consent
• The legal entity accordingly indemnifies KBC Bank NV in respect of all liability in this regard (vis-à-vis those concerned). For example, the company is responsible for complying with the data protection legislation when it submits lists of users for online applications or of beneficiaries of employee profit-sharing bonus programmes.

Only persons with appropriate authorisation can access personal data, and then only if that data is relevant to the performance of their duties.

In principle, within KBC Bank NV and the KBC Group, your personal data will only be processed and viewed by certain departments that:

• you have, had or want contacts or contracts with;
• need to be involved in the provision or aftercare of services;
• fulfil legal requirements (at group level) or requirements imposed by regulators or stemming from corporate governance principles;
• are tasked with preventing fraud, including money laundering, by employees and customers.

Some examples:

• When we are notified of the death of a customer of KBC Bank NV who is also a customer of other KBC entities in Belgium, we also inform those other entities.
• For direct debit mandates, you may take certain steps to block them (e.g., blocking the instruction or imposing a maximum limit). If you take such a step in respect of a direct debit in favour of a KBC company, KBC Bank NV may inform that company of the fact. The KBC company concerned can then more effectively assess the status of your direct debit instruction.

The individuals who are authorised to consult your data are moreover bound by a strict professional duty of confidentiality and must abide by all technical instructions to ensure the confidentiality of your personal data and the security of the systems in which the data is held.

KBC Bank NV uses the services of several processors to process personal data. These are companies that process data on the instructions of KBC Bank.

For the processing of personal data, KBC Bank NV makes use of a processor within the KBC Group based in the European Union, namely KBC Group NV and KBC Global Services NV. Processing is carried out in Brno, Sofia or Varna, for instance, by the Shared Services Centre, branches of KBC Global Services NV in the Czech Republic or Bulgaria.

Some of the data processing performed by KBC Group NV and KBC Global Services NV on behalf of KBC Bank NV relates to oversight and support functions (at group level) such as financial reporting, the compliance function, the internal audit function, the inspection and risk function, anti-money laundering checks, complaints management, marketing support, support for invoicing, money transfers, credit processing and ICT management for the KBC Group.

For ICT management, KBC uses KBC Global Services NV, sometimes in conjunction with other processors within and outside the KBC Group.

KBC also uses the services of 24+ NV (www.24plus.be):

• as a contact centre through which you can get in touch with us;
• as a contact centre to get in touch with you on behalf of KBC for the purpose of making an appointment or conducting a satisfaction survey, to inform you about ‘personalised information’ and to invite you to make a choice;
• to log data into KBC apps;
• for administrative processing on the instructions of KBC;
• to provide information to the tax authorities and the police;
• to conduct an advisory meeting following a death, and to register next of kin, heirs, legal representatives and beneficiaries in the persons database..

Examples include making appointments for branches, answering telephone enquiries, handling e-mails, and processing and executing online applications.

KBC works together with Everyone Invested, a subsidiary of KBC Asset Management NV, to analyse the conformity of individual investment portfolios with the KBC Investment Strategy. KBC exchanges anonymised data regarding the investment portfolios with Everyone Invested for this purpose.

KBC Bank NV uses specialist third parties in Belgium and abroad to perform some processing operations, such as payments.

This concerns:

• SWIFT (www.swift.com) with headquarters in Belgium and establishments in many countries, for the global message exchange;
• Equens Worldline SE (www.equensworldline.com), Mastercard (www.mastercard.com), Idemia (www.idemia.com) and, in certain cases, Bancontact Payconiq Company NV (www.bancontact.com) for payments and (credit) card transactions worldwide;
• Custodians and subcustodians of financial instruments worldwide that are subject to local financial regulations;
• institutions for the settlement and clearing of payments and securities transactions, such as the CEC (www.nbb.be) (payment systems) and Euroclear;
• transport companies (for cash and other valuables) and security firms;
• consumer credit intermediaries (i.e. instalment loans);
• entities that support KBC in complying with its anti-money laundering obligations, for example by developing and using money laundering detection models;
• Batopin NV(www.batopin.be), a network of bank-neutral ATMs, also for updating your electronic ID card details;
• Appbot Pty Ltd (www.appbot.co), for monitoring and analysing feedback from users of KBC apps;
• Renta Solutions NV for typical leasing platforms in automating vehicle ordering, vehicle registration and delivery (Order Register Deliver), maintenance, electronic invoicing (REI rS Electronic Invoice).
  

KBC Bank NV may also directly or indirectly (e.g., through KBC Group NV) engage the services of other processors, such as:

• consultants;
• third-party business introducers to fulfil its general duty of vigilance as laid down by law:
  • The obligation to identify and verify identities
  • The obligation to identify the customer characteristics and the purpose and nature of the business relationship
  • The obligation to update information
• market research agencies such as Ipsos (www.ipsos.com), Profacts (www.profacts.be), GFK (www.gfk.com), Check market (www.checkmarket.com.), iVOX (www.ivox.be) and Intrinsiq (www.intrinsiq.be), for issuing invitations and carrying out surveys;
• ICT and ICT security service providers like Microsoft, Cognizant, IBM, Amazon and HP, and specialist fintech and artificial intelligence companies such as Onfido for facial recognition during the customer onboarding process;
• marketing and communication agencies and similar companies, whereby KBC uses personal profile information on you that is held by them, along with the data it holds on you, to be able to make targeted offers to you via their channels (e.g., Google, Facebook, etc.);
• companies that support KBC in identifying and analysing your user behaviour in our apps and on our websites (e.g., Adobe, Dynatrace). In preparation for the analysis of Adobe Data Analytics, KBC may rely on the services of Amazon Web Services – Cloud Computing Services. The transfer and processing of personal data from, to and in Amazon Web Services is encrypted;
• companies specialising in information archiving and access, such as Doccle (Doccle stores information on all our customers, including those that haven’t opted for digital record-keeping). Doccle uses Amazon Web Services – Cloud Computing Services);
• companies specialised in scanning digital documents in order to digitise files with associated info.
• companies specialising in solvency investigations;
• companies specialising in specific services that KBC uses when offering services to its customers, such as Meeco for offering the Digital Safe in the KBC Mobile app;
• printers for printing and the addressing of news magazines, cheques and transfer forms, badges, among other items;
• freelance translators and translation agencies;
• social media management tools (CX Social);
• sworn real estate experts;
• communications agency Motisha BV www.motisha.com;
• companies providing Platform as a Service (PaaS) and Software as a Service (SaaS) in the cloud, such as:
  • the Microsoft Dynamics CRM app used by KBC to maintain customer overviews;
  • VEE24’s video chat app for enabling digital communication with KBC;
  • the storage services of Microsoft Azure or Amazon, on which KBC can place its own platforms or software that process and store your personal data;
  • security services that screen Internet or e-mail traffic with KBC for cyberattacks or phishing scams;
  • TreasurUp, with whom KBC exchanges the contact details of company representatives to enable forex transaction analysis;
  • Nomios Belgium NV to set up a secure network connection between KBC entities worldwide based on SD WAN technology;
  • applications that facilitate and automate call recording, where appropriate, for instance as offered by Luware.
  •  …

As a data controller, KBC may – in addition to using other processors – use other service providers or third parties, such as lawyers, notaries public or doctors, who themselves are data controllers.

This is, for instance, the case for KBC Securities Services, which is a part of the KBC Group. KBC Securities is the controller of your personal data when providing services in its capacity as a broker or custodian of securities. To this end, KBC Securities Services works with other third parties such as asset managers and private bankers. They in turn offer their own services, such as investment advice, and therefore also act as a controller of your personal data. When that is the case, another – usually shorter – data protection statement may apply since the service is also more limited. If you purchase a service from KBC that is covered by a shortened or non-standard data protection statement, you will be duly advised of this. The most recent version of the statement applying to services provided by KBC Securities Services can be viewed at www.kbcsecurities.com.

KBC can outsource the collection of arrears on, say, a loan, to specialised companies that themselves are data controllers.

KBC also distributes its own products and services in conjunction with third parties that refer their customers to KBC, for example for a loan. They do not act as intermediaries in that regard and only pass on to KBC the personal data needed to prepare tenders or simulations. The third parties are responsible for passing on the personal data. The third parties have access to a dashboard to track purchases of products.

As a bank-insurer, KBC Bank NV cooperates with KBC Insurance, with both companies acting as data controllers with respect to personal data. Specific information regarding the controllers for the direct marketing domain is provided under 3.5.

KBC can itself act as a third-party business introducer for, for example, Payconiq, Belgian Mobile ID (itsme). KBC then processes personal data as data controller. KBC transfers this personal data to the third party. Likewise, a third party may act as a third-party business introducer for KBC.

When a mortgage expires and mortgage renewal is needed, KBC will call upon the services of a notary public. KBC provides the notary public with the national registration number(s) of the borrower(s), a copy of the original registration model, the first authenticated copy of the deed or other useful information that allows the notary public to renew the mortgage registration.

When, as a merchant, you want to install an electronic payment terminal and you ask KBC to act as an intermediary in that regard, KBC will pass on your contact details to Equens Worldline SE.

In certain specific cases, processors whose services KBC engages (see 5.2.3) may nevertheless act as controllers for the processing of KBC data. One such case is Microsoft, which also processes personal data for activities beyond the limited scope of a processor, such as billing, internal remuneration, internal reporting and internal organisation, fraud prevention and security of their services, service improvement, financial reporting, and compliance with legal obligations applicable to them. KBC has entered into the necessary contractual arrangements with Microsoft to ensure compliance with the relevant data protection safeguards.

KBC can also cooperate with third parties such as Xerius Ondernemingsloket vzw. Xerius helps you to start up a business. During that process, Xerius may put you in touch with KBC to get your business account opened. Xerius then sends identification details to KBC. Xerius does this with your consent.

As a customer, you can ask for your balance and transactions via so-called virtual ‘Voice Assistants’ (Alexa, Google Assistant, etc.). In order to do this, you must first give KBC your consent to transfer the necessary account information to that service. The further processing, such as the electronic pronouncement of your balance by the service, is carried out entirely by the third party that provides the service to you. KBC is not responsible for that.

KBC acts as a processor of your personal data on behalf of third parties further to the execution of orders at a number of stock exchanges or when acting as a broker. This is, for instance, the case for KBC Securities Services. KBC acts as a processor for certain third parties with respect to the Additional services as set out under 3.2. KBC Bank NV acts as a processor for KBC Insurance NV for the distribution of their products.

KBC Bank NV ensures that strict rules are followed and that the processors concerned:

• only have the data they need in order to perform their tasks;
• have given KBC Bank NV a commitment that they will process this data securely and confidentially and only use it for carrying out the instructions given to them.

KBC Bank NV will not be liable if these processors (according to law) disclose customers’ personal data to local authorities or if incidents occur at those processors despite the measures they have taken. KBC ensures that the European data protection standards for personal data are applied worldwide within companies belonging to the KBC Group and their branches. KBC also ensures that companies and corporate branches of the KBC Group take appropriate measures to protect the data of legal persons. KBC Bank NV takes internal technical and organisational measures to prevent personal data finding its way into the hands of, or being processed by, unauthorised parties or being accidentally altered or deleted.

Strict security measures are in place to protect premises, servers, the network, data transfers and the data itself, and extra checks are also carried out by a specialist department in this regard.

To make online banking and investment services as secure possible, security experts at KBC continuously analyse cyber-criminal activity so that they can hone the relevant security measures accordingly. Find out more at www.kbc.be/secure4u.

Together with you, we need to be aware that information shared by e-mail can sometimes be intercepted and, where possible, we must aim to use a different means of communication or to limit the amount of information sent.
KBC websites and apps may contain links to websites or information of third parties. KBC Bank NV does not check such websites or information. Parties offering these websites or this information may have their own privacy policies in place, which we advise you to read. KBC is not responsible for the content of those websites, their use or their privacy policy.

KBC Bank NV sometimes facilitates the publication of information (including personal data) via social media such as Twitter and Facebook. Bear in mind that these channels have their own terms of use, with which you must comply. Publishing data on social media may have (undesirable) consequences, including for your privacy or that of persons about whom you share data. You may not be able to delete such published information quickly. You should therefore assess the consequences yourself as the decision to disclose data on such media ultimately lies with you. KBC does not accept any responsibility in that regard.

KBC uses your personal data where KBC has a clear aim in mind. Once that aim no longer exists, we delete the data.

The period for which your personal data has to be retained is defined by law (usually till ten years after the end of a contract or execution of a transaction. For commercial claims it is 30 years after the end of a contract or execution of a transaction). The period can be longer where needed for the exercise of our rights. If no retention period is stipulated by law, it can be shorter.

For some applications, a more extended time horizon may be necessary, such as for carrying out surveys and risk and marketing models. Some insights only get clearer once they are viewed over a longer time span. This can result in the retention period being extended by ten years on top of the standard periods. As has been stated, KBC will in all cases sever connections to individuals as quickly as possible and work only with aggregated or anonymised data.
Information that you personally registered in the KBC Touch application ‘Profile yourself’ or that was registered at the branch, with the agent or in KBC Live, for example, is retained by KBC for five years.

Personal data on prospects is used by KBC for a maximum of five years unless, in the meantime, there has been contact with the prospect. In that case, a new maximum five-year period starts. Prospects can always ask for their personal data to be removed.

The law in some countries outside the EEA (like the United States of America or India) doesn’t always afford the same level of data protection as in EEA member states. Where a non-EEA country is viewed by the European Commission as not offering an adequate level of protection, KBC Bank can cover the deficiency by, say, agreeing the required contractual guarantees with those third parties (such as a model approved by the European Commission), providing control mechanisms and implementing technical and organisational measures.

The transfer of personal data to countries outside the European Economic Area or to international organisations was screened by KBC. This transfer either takes account of the European Commission’s list of safe countries or is based on reasonable and sufficient security measures or falls under a specific derogation from the GDPR.

The most important aspects of international data transfer are explained in more detail below. Feel free to e-mail mypersonaldata@kbc.be if you have any questions.

KBC may export some personal data relating to Corporates (e.g., contact details of representatives) to its foreign branches in Hong Kong, China, Singapore and the US, provided the corporate client also operates in the country in question.

KBC always opts for the processing of personal data to take place within the European Union. Given the nature of certain processes (for example, when round-the-clock support is required), in some cases personal data may be transferred to processors outside the EEA.

Even if the data centre is located within the EEA, access from outside the EEA may still be possible in some cases (e.g., in case of technical problems, or when round-the-clock support is required). This is also considered data transfer outside the EEA.

For some processes, the processors’ data centres may be located outside the EEA or accessed from outside the EEA, as is the case for the United States of America. Some examples (as at 16 September 2022):

Similarly, when data is transferred to another controller in a country outside the EEA, these transfers are screened by KBC and the necessary measures are applied.

Some examples of controllers outside the EEA that may receive personal data from KBC as at 16 September 2022):

As KBC Bank NV has to comply with its confidentiality obligations and with the data protection legislation, it may only answer queries from third parties if they arise pursuant to a legal requirement or a legitimate interest, doing so is a prerequisite for performing the contract or the data subject has given their permission. In the last case, it actually advises requesting the information directly from the data subject.

KBC Bank NV declines liability if, as a result of foreign legal obligations, the lawful recipients of personal data require to pass personal data about customers on to local authorities. Or if they process personal data without an adequate level of security.

KBC Complaints Management provides answers to the questions posed by Ombudsfin, the ombudsman for banking.

If you as third party have queries about customers, for example because you work for the police or are a notary public or lawyer, you can contact KBC’s Third-Party Enquiries department, Brusselsesteenweg 100, 3000 Leuven. This specialist department will answer your query subject to bank secrecy obligations and the privacy laws. KBC Bank branches and other departments will therefore refer you to that department.

There are certain aspects of (technical) data processing over which KBC Bank has no, or at best insufficient, influence and for which it cannot guarantee total security. Examples include the Internet or mobile communications (such as smartphones).

If hackers are active, KBC Bank NV does not always succeed in defeating their cyber-attacks in time. It sometimes does not even know that it is happening, for example if a hacker manages to obtain your identification details by installing illegal software on your computer (spyware) or by creating a fake website (phishing). You will find more information on secure online banking at www.febelfin.be (safe online banking).

KBC Bank NV therefore suggests that you regularly take a look at the KBC website for information on safe online banking:
www.kbc.be/secure4u. This site always contains the most up-to-date tips and recommendations to keep you secure online.