Data Protection

Privacy Statement

This is our Privacy Statement. It explains how we obtain, use and keep your information safe when it is supplied using the Santander International website (www.santanderinternational.co.uk), and Online Banking site for Personal and Corporate customers. Your personal data is data which by itself or with other data available to us can be used to identify you. In this Privacy Statement ‘we’ or ‘Santander International’ means Santander Financial Services plc, Jersey Branch and Santander Financial Services plc, Isle of Man Branch. We are the data controller of information you provide to us. You can contact our Data Protection Officer (DPO) at 13 - 15 Charing Cross, St Helier, Jersey JE2 3RP, Channel Islands if you have any questions.

Santander International is committed to keeping your personal information safe and confidential both online and offline.

The types of personal data we collect and use

1. The types of personal data we capture and use will depend on what you are doing on this site. We will use your personal data for the reasons set out below and if you become a customer we will use it to manage the account, policy or service you have applied for and we will provide you with a separate Privacy Statement specifically in relation to that as part of the online application journey. Some of the information relevant to that is included in this Privacy Statement for consistency.

Examples of the personal data we use may include:

• Full name and personal details including contact information (e.g. home address and address history, email address, home and mobile telephone numbers);
• Date of birth and/or age (e.g. to ensure that you are eligible to apply for a product or service);
• Financial details (e.g. salary and details of other income, and details of accounts held with other providers if you apply for a product or service with us);
• Records of products and services you have obtained or applied for, how you use them and the relevant technology used to access or manage them (e.g. mobile phone location data, IP address, MAC address);
• Information from credit reference or fraud prevention agencies, electoral roll, court records of debt judgements and bankruptcies and other publicly available sources as well as information on any financial associates you may have if you apply for a product or service with us;
• Family, lifestyle or social circumstances if relevant to the product or service you apply for (e.g. the number of dependants you have);
• Education and employment details/employment status for credit and fraud prevention purposes if you apply for a product or service with us; and
• Personal data about other named individuals as required. Where you provide the personal data of others you must have their authority to provide their personal data to us and share this privacy policy and any related data protection statement with them beforehand together with details of what you have agreed on their behalf.

Providing your personal data

We will tell you if providing some personal data is optional, including where we ask for your consent to process that personal data. In all other cases, if you fail to provide the requested personal data, we may be unable to process or respond to your application, query or service.

Monitoring of communications

Subject to applicable laws, we will monitor and record your calls; emails; text messages; social media messages; and other communications in relation to your dealings with us. We will do this for regulatory compliance; self-regulatory practices; crime prevention and detection; to protect the security of our communications systems and procedures; to check for obscene or profane content; for quality control and staff training; and when we need to review a record of what has been said or written. If you take out an account or service with us, we may also monitor activities on your account/service where necessary for these reasons and this is justified by our legitimate interests or our legal obligations.

International transfers

In some instances your personal data may be transferred outside the Isle of Man, Jersey and the European Economic Area (‘EEA’). While some countries have adequate protections for personal data under applicable laws, in other countries steps will be necessary to ensure appropriate safeguards apply to it. These include imposing contractual obligations of adequacy or requiring the recipient to subscribe or be certified with an ‘International Framework’ of protection. Further details can be found in our ‘Using my personal data’ booklet.

Using your personal data: the legal basis

We will process your personal data:

1. As necessary to perform your contract with us for the relevant account, policy or service, to take steps at your request prior to entering into it, to decide whether to enter into it, to manage and perform that contract, to update our records, to trace your whereabouts to contact you about your account and recovering debt;
2. As necessary for our own legitimate interests or those of other persons and organisations, e.g
   1. For good governance, accounting, and managing and auditing our business operations;
   2. To search at credit reference agencies if you are over 18 and apply for credit;
   3. To monitor emails, calls, other communications, and activities on your account;
   4. For market research, analysis and developing statistics; and
   5. To send you marketing communications and do marketing in-branch, including automated decision making relating to this.
3. As necessary to comply with a legal obligation, e.g.:
   1. When you exercise your rights under data protection law and make requests;
   2. For compliance with legal and regulatory requirements and related disclosures;
   3. For establishment and defence of legal rights;
   4. For activities relating to the prevention, detection and investigation of crime;
   5. To verify your identity, do credit checks, fraud prevention and anti-money laundering checks; and
   6. To monitor emails, calls, other communications, and activities on your account.
4. Based on your consent, e.g.:
   1. When you request us to disclose your personal data to other people or organisations such as a company handling a claim on your behalf or otherwise agree to disclosures;
   2. When we process any special categories of personal data about you at your request (e.g. your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning your health, sex life or sexual orientation); and
   3. To send you marketing communications where we have asked for your consent to do so. You are free at any time to change your mind and withdraw your consent. The consequence might be that we cannot do certain things for you.

Sharing of your personal data

Subject to applicable data protection law we may share your personal data with:

• The Santander group of companies* and associated companies in which we have shareholdings;
• Sub-contractors and other persons who help us provide our products and services;
• Companies and other persons providing services to us;
• Our legal and other professional advisors, including our auditors;
• Fraud prevention agencies, credit reference agencies, and debt collection agencies at account opening and periodically during account or service management;
• Other organisations who use shared databases to do income verification and affordability checks and to manage/collect arrears;
• Law enforcement bodies;
• Government bodies and agencies in the Isle of Man and Jersey (e.g. the local tax authorities who may in turn share it with relevant overseas tax authorities and with regulators e.g. the Isle of Man Financial Services Authority, the Jersey Financial Services Commission , the relevant Information Commissioner’s Office);
• Courts, to comply with legal requirements, and for the administration of justice;
• The relevant Financial Services Ombudsman;
• In an emergency or to otherwise protect your vital interests;
• To protect the security or integrity of our business operations;
• To other parties connected with your account (e.g. guarantors and other people named on the application); joint account holders will see your transactions;
• When we restructure or sell our business or its assets or have a merger or re-organisation;
• Market research organisations who help to improve our products or services;
• Payment systems (e.g. Visa) if we issue cards linked to your account; they may transfer your personal data to others to process transactions, resolve disputes and for statistical purposes, including by sending your personal data overseas; this is necessary to operate your account and for regulatory purposes; and
• Anyone else where we have your consent or as required by law.

Online applications

If you apply for an account online, before you enter any personal details into the online form, we'll tell you how your information will be used in our data protection statement relevant to that account, in the ‘Using my personal data’ booklet and sometimes in the relevant terms and conditions. You will be asked to confirm that you have read these and you will be asked to agree to our terms and conditions before your application can proceed. The data protection statement, in conjunction with the ‘Using my personal data’ booklet, includes details of the uses we may make of your data, the legal basis we are relying upon to carry out that processing, and to whom we may share your personal data with. For instance, for credit account applications like loans and bank accounts, we may pass your details to a recognised credit reference agency to help process your application.

We might occasionally send you information about accounts and services which we think would be of interest to you but only where we have your consent or if this is within our legitimate interests (see above for more details about lawful reasons). If at any time you decide you do not want us to use your contact details in this way you can tell us (contact details below).

Updating our Data Protection Statement

We may update the data protection statement from time to time. When we change the data protection statement in a material way, this will be communicated to you together with the updated data protection statement.

Business Changes

If we or the Santander group undergoes a group reorganisation or is sold to a third party, your personal information provided to us may be transferred to that reorganised entity or third party and used for the purposes highlighted in this data protection statement.

Contacting us by phone

You can call our Customer Services team on 08000 84 28 88, if calling from a UK landline or mobile, or +44 (0)1624 641 888, if calling from overseas. Lines are open from 9am – 5pm UK time, Monday to Friday (except Wednesday when we open at 9.30am). To help us improve our service calls will be recorded and may be monitored, as explained in the monitoring of communications section as necessary to comply with any legal obligations and for our legitimate interests.

Contacting us by email

When you contact us, we may need to collect some personal details like your name, address and phone numbers. Please note that email is not regarded as a secure method of contacting us, therefore we advise that you keep personal information to a minimum. With this in mind, do not transmit personal data such as your account information using normal email. Consider another method if you need to share this information such as secure messaging, available via our online banking platform or by calling us.

Emails are stored on our email servers, which are secure and cannot be accessed by external parties. We store this information in line with our retention periods in order to identify trends, and for the purposes set out in the monitoring of communications section as necessary to comply with any legal obligations and for our legitimate interests. For more information on the criteria we use to determine our retention periods, see below.

Surveys and competitions

We will treat any survey or competition information you provide with the same high standard of care as we do all other customer information, using any details provided strictly within the terms of the competition and this Privacy Statement.

Using your personal information

We will tell you if we intend to use your information for marketing purposes and we will give you the opportunity to opt out if you want to (unless we need a consent – if we do we will seek one). If you receive marketing emails and do not want to in future, please use the unsubscribe link within the email and we will remove you from future campaigns.

Cookies

Cookies are small text files placed on your computer and are commonly used on the internet. We use them to:

• collect anonymous information that will help us understand visitors' browsing habits on our website
• compile statistical reports on website activity, e.g. number of visitors and the pages they visit
• temporarily store any information which you may enter in tools, such as calculators or demonstrations on our website
• in some cases, remember information about you when you visit our site. We may need to do this to provide some of our services e.g. if you use the 'Remember my ID' tool when logging on to Online Banking

We use cookies to enable us to perform our contract with you (e.g. if you apply for a product online or are an online banking customer) and for our legitimate interests (e.g. to help us improve our service). We will request your consent for using non-essential cookies. We do not use cookies to track your use of the internet after you leave our sites, nor do we store any personal information in them that could identify you to other people.

To understand more about the kind of cookies we use and how you can control and delete cookies please visit our Cookie Policy page.

Automated decision making and processing

Automated decision making involves processing your personal data without human intervention to evaluate your personal situation such as your economic position, personal preferences, interests or behaviour, for instance if you have accounts with us, in relation to transactions on your accounts, your payments to other providers, and triggers and events such as account opening anniversaries and maturity dates. We may do this to decide what marketing communications and marketing in-branch is suitable for you, to analyse statistics and assess lending and insurance risks. All this activity is on the basis of our legitimate interests, to protect our business, and to develop and improve our products and services, except as follows; when we do automated decision making including profiling activity to assess lending and insurance risks, this will be performed on the basis of it being necessary to perform the contract with you or to take steps to enter into that contract. Further details can be found in our ‘Using my personal data’ booklet.

Criteria used to determine retention periods (whether or not I become a customer)

The following criteria are used to determine data retention periods for my personal data:

• Retention in case of queries. You will retain my personal data as long as necessary to deal with my queries (e.g. if my application is unsuccessful or for a sensible period in order for you to reply to my online query and then deal with queries I raise upon receipt);
• Retention in case of claims. You will retain my personal data for as long as I might legally bring claims against you; and
• Retention in accordance with legal and regulatory requirements. You will retain my personal data after my account, policy or service has been closed or has otherwise come to an end based on your legal and regulatory requirements.

Your rights under applicable Data Protection law

If we hold personal data about you then your rights are as follows:

• The right to be informed about processing of your personal data;
• The right to have your personal data corrected if it is inaccurate or incomplete;
• The right to object to processing of your personal data;
• The right to restrict processing of your personal data;
• The right to have your personal data erased (the “right to be forgotten”);
• The right to request access to your personal data and information about how we process it;
• The right to move, copy or transfer your personal data (“data portability”); and
• Rights in relation to automated decision making including profiling.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

You have the right to complain to the relevant Information Commissioner’s Office. They have enforcement powers and can investigate compliance with data protection law. Further information is available via their websites - Jersey: www.oicjersey.org; Isle of Man:www.inforights.im; UK: https://ico.org.uk/;

For more details on all the above you can contact our DPO or request the ‘Using my personal data’ booklet by asking for a copy in branch, online or over the telephone.

Data anonymisation and aggregation

Your personal data may be converted into statistical or aggregated data which cannot be used to identify you, then used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described above.

*Group companies

The Santander group of companies includes but is not limited to Banco Santander S.A., SCF Madrid, S.A.; Santander UK Group Holdings plc, Santander UK plc, Santander Financial Services plc, Santander UK Santander Consumer (UK) plc trading as Santander Consumer Finance; Santander Insurance Services UK Ltd.

Legal statement about this Privacy Statement

This Privacy Statement is not designed to form a legally binding contract between Santander International and users of our website or online services.

Contacting us about our Privacy Statement

Please contact our Customer Services team or our DPO who will help you.

Links to other websites

Certain hyperlinks in our website may lead you to websites which are not under the control of Santander International. When you activate these, you may leave the santanderinternational.co.uk website. These links are provided solely for your convenience and do not represent any endorsement or recommendation by Santander International.

Santander International accepts no responsibility or liability for the contents of any website to which a hyperlink exists and gives no representation or warranty as to the information on such websites. Santander International accepts no responsibility or liability for any loss arising from any contract entered into with any website to which a hyperlink exists.

No liability for unavailability

Santander International accepts no liability for any loss that may arise if the goods or services advertised within this website become unavailable.

Customer responsibility

It is your responsibility to ensure that your computer or any similar device is protected against computer viruses and malware. Santander International accepts no responsibility for any loss you may suffer as a result of accessing and downloading information from this site.