“Personal Data” is data that identifies you as an individual or relates to you as an identifiable individual. We may collect the following kinds of Personal Data about you:

  • Identity Data, including name, username or similar identifier, date of birth, gender, marital status, and title.
  • Contact Data, including postal address, email address, and telephone numbers.
  • Financial Data, including bank account and payment card details.
  • Identification Data, such as Social Security number, driver’s license or passport numbers.
  • Transaction Data, including details about payments to and from your bank accounts and other details of products and services you have purchased from us.
  • Device Data, including your Internet Protocol (IP) address, your login data, the domain and host from which you access the Internet, the date and time you access our online properties, browser and operating system data and the Internet address of the site from which you linked to our website.
  • Profile Data, including your username and password and your transactions, interests, communications and other preferences, feedback, and survey responses.
  • Usage Data, including data about how you use our websites and apps, products, and services.
  • Biometric data, including fingerprints, voice recordings or keystroke patterns.
  • Derived device geolocation information, such as approximate geographic location inferred from an IP address.
  • Marketing and Communications Data, including correspondence and other communications for the purposes of providing client support and your communication preferences.

We may change your data in a way that makes it unrecognizable as your Personal Data, and it will no longer be considered Personal Data. To the extent that the data we collect is not considered Personal Data under applicable law, we may use and disclose it for other purposes.

Please do not send us any sensitive Personal Data if you are not a client. This includes Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership.

If you disclose any Personal Data relating to other people (such as our clients’ beneficial owners) to us, you represent that you have the authority to do so and to permit us to use the data in accordance with this Privacy Notice.


We collect Personal Data when you choose to provide it to us, such as when you apply to open an account with us and receive banking or other services for personal, family, or household purposes or on behalf of your employer. We also collect Personal Data when you sign up to use our services or receive our publications; request marketing material to be sent to you; complete a survey or questionnaire; contact customer service or otherwise communicate with us; or provide us with feedback.

We also collect certain Personal Data automatically from your interactions with our online properties, including:

  • Through your browser or device. Certain data is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type, screen resolution, operating system name and version, device manufacturer and model, language, Internet Protocol (IP) address, and browser type and version. We use this data to ensure that our online services function properly. We may also derive your approximate location from your IP address.
  • Through your use of our apps. When you download and use one of our apps, we may track and collect app usage data, such as the date and time the app on your device accesses our servers, in order to ensure that the app functions properly and to understand how it is used.
  • Through the use of cookies and similar tracking technologies. If you interact with us online, you may encounter cookies. There will be a cookie notice you can read to learn how we use cookies and similar tracking technologies on our digital properties, including for analytics and advertising purposes. We do not currently respond to browser do-not-track signals.
  • Physical Location. We may collect the physical location of your device by, for example, using satellite, cell phone tower, or Wi-Fi signals, for fraud prevention and in order to provide you with personalized location-based services and content. You may be able to manage the collection settings of your device’s location.

In addition, we receive your Personal Data from other sources, such as third parties and publicly available sources, including, for example, social media platforms, publicly available databases, government agencies, credit reference and financial crime prevention agencies, consumer reporting agencies, specialist data and research companies, and event or joint marketing partners.


We disclose Personal Data:

  • To third party organizations and public bodies, including law enforcement agencies, to prevent and detect fraud.
  • To our affiliated and third party service providers, to facilitate services they provide to us in connection with the uses described in Section 4.
    • Our service providers may also provide such services as website hosting, data analysis, customer service, email delivery, and auditing.
  • To our affiliates, to permit them to send you marketing communications.
    • For a list of the affiliates with which we share Personal Data, along with the locations of those affiliates, please contact us.

We also use and disclose your Personal Data as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations.
    • These may include laws outside your country of residence.
  • To cooperate with law enforcement and government authorities.
    • To respond to a request or to provide information when we believe necessary or appropriate.
  • For other legal reasons.
    • To enforce our terms and conditions or other agreements with our users and customers; and
    • To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
  • In connection with a sale or business transaction.
    • We have a legitimate interest in disclosing or transferring your Personal Data to a third party in connection with a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). After the transfer is complete, if all or part of our assets are sold, then your Personal Data may be transferred to the new owner so services can continue to operate.