For GrønlandsBANKEN, the protection of customer data is important, and it is a natural part of the bank's daily operations to uphold the bank's duty of confidentiality. When the bank develops products and services, technical, physical, and organizational controls are implemented to protect the personal data the bank has and processes about you.
This policy describes which personal data GrønlandsBANKEN processes, and why the bank does this.
You will also be able to read about how the bank collects your personal data, with whom your data may be shared, and how long the bank stores it. In addition, the policy describes in which situations the bank uses profiling and (partial) automated decision-making, and how you can access your personal data. You will also learn how to contact the bank if you have comments or questions regarding GrønlandsBANKEN’s processing of personal data.
Which personal data GrønlandsBANKEN processes
At GrønlandsBANKEN, your personal data is divided into different categories. The personal data the bank has about you belongs to the following categories with a (non-exhaustive) list of examples:
- Basic personal data (e.g., customer number, name, contact information, personal ID number)
- Personal preferences (e.g., whether you wish to receive direct marketing materials, preferred communication language, cookie acceptance)
- Evaluations and classifications (e.g., under the AML, FATCA, or MiFID regulation)
- Agreements (all types of information related to agreements, e.g., account numbers, agreement numbers for loans, cards, property references, powers of attorney)
- Financial transactions (e.g., account deposits and withdrawals, loan payments, card payments and securities trading, the purpose and intended scope of the customer relationship)
- Communication (e.g., email correspondence and possibly recordings of telephone conversations)
- Control (e.g., IP or MAC address, log of when you identify yourself electronically in the bank’s online solutions)
One category includes types of personal data that are particularly sensitive, such as health information.
GrønlandsBANKEN will only process this type of information when relevant to a specific product or service, including insurance products.
To help the bank ensure your physical security and that of the bank’s employees, and to support the bank’s efforts to combat fraud, money laundering, and similar illegal activity, the bank uses, among other things, video surveillance in its branches.
Where appropriate, the bank also processes personal data related to individuals representing you, such as a guardian, trustee, or similar approved representative.
GrønlandsBANKEN’s purpose in processing personal data
GrønlandsBANKEN processes personal data for the different legal reasons and purposes described below. If, for any reason, you do not wish to provide GrønlandsBANKEN with the necessary personal data, or if you wish to have such data removed, this may affect the bank’s ability to offer you its services and products.
Contract fulfilment
GrønlandsBANKEN’s overall purpose for collecting and storing personal data is to be able to design, offer, and manage the bank’s products and services digitally, in its branches, or by phone, based on a contract as the legal basis.
GrønlandsBANKEN may also record and/or monitor your telephone conversations with the bank. This applies especially when you trade securities with GrønlandsBANKEN by phone, but the bank also records telephone conversations between you and your advisor and the bank’s call center.
Legal obligations
To fulfill GrønlandsBANKEN’s legal obligations, your personal data is processed for the following purposes (non-exhaustive list):
- To check and verify your identity
- To monitor and analyze how you use accounts and other banking services, so the bank can prevent and detect fraud, money laundering, and similar illegal activity
- To document and store personal data related to credit and loan facilities as well as investments in financial instruments
- To handle security requirements for online payments and account access
- To report to authorities such as the tax authorities or the Financial Supervisory Authority
- To comply with regulations and requirements regarding accounting, risk management, and statistics
The bank’s interest
GrønlandsBANKEN offers financial services with the aim of building strong and lasting relationships with its customers. Therefore, the bank processes your personal data for the following purposes (this list is not exhaustive):
- To carry out market and customer analyses to improve the bank’s products, services, and channels
- To perform direct marketing activities that can help the bank identify and suggest products and services that may be of interest to you, unless you have opted out
- To conduct customer surveys
- To perform risk analyses and collect statistics, for example to improve the bank’s credit risk models
Your consent
For some products and services, the bank may require your consent to process your personal data. In that case, you will be presented with a written declaration, separate from the bank’s product and service agreements or other matters. You will also be given a description of how you can withdraw your consent and how this will affect the specific product or service.
For example, GrønlandsBANKEN asks for your consent when you use the bank’s website, where a cookie with a unique ID is added to your web browser for web analysis purposes. This way, the bank can gather information about how the website is used. Consent is given when you accept cookies the first time you visit the bank’s website using a specific browser. GrønlandsBANKEN does not track individual users’ use of the website, and therefore does not collect or store personal data such as names, IP addresses, or email addresses in the cookies used. Read more about how GrønlandsBANKEN uses cookies here: Cookies.
Profiling and automated decision-making
In some cases, GrønlandsBANKEN uses so-called profiling. This means automatic processing of personal data to carry out analyses related to the customer’s financial situation, personal preferences, or behavior across different channels. Profiling is also used in some areas for automated decision-making, such as partially automated approval or rejection of a loan application via the internet.
How GrønlandsBANKEN collects your personal data
GrønlandsBANKEN collects the data directly from you, for example when you open an account with GrønlandsBANKEN, when you apply for a loan, or pay your bills, as well as from your activities with GrønlandsBANKEN. In addition, the bank also collects data from private and public registers, for example the Central Person Registry, tax authorities, or credit reporting agencies.
Who GrønlandsBANKEN shares your data with
GrønlandsBANKEN is legally obligated not to disclose your data except for permitted purposes, including to fulfill an agreement with you or in connection with other legally required or permitted purposes, such as reporting to authorities.
To fulfill the terms of the bank’s product and service agreements with you, the bank may need to share information about you with other companies that provide contractual services to the bank or to you. This may include banks, payment service providers, and other parties in financial infrastructures, suppliers, agents, and other parties involved in the service agreement.
Examples of situations where the bank discloses your personal data outside of GrønlandsBANKEN (non-exhaustive list):
- To authorized credit reporting agencies when you apply to GrønlandsBANKEN for a loan
- To third parties providing contractual services to the bank or to you, e.g., payment service providers, approved subcontractors, or partners acting on behalf of the bank
- To banks and payment institutions in countries in and outside Greenland when transferring money or funds at your request
- To governmental authorities, supervisory bodies, and tax authorities in compliance with GrønlandsBANKEN’s legal and regulatory obligations, such as laws on taxation, anti-money laundering, counterterrorism, and immigration
- To authorized fraud prevention agencies and similar organizations that assist in combating financial crime
Transfers to third countries
In some situations, the bank may transfer personal data to recipients outside Greenland. This primarily occurs when the bank transfers money or other assets to a recipient in a third country at your request based on an agreement. Another situation is when GrønlandsBANKEN is required to share personal data with an authority in a third country.
If GrønlandsBANKEN does not have an agreement with you regarding a transfer to a third country, one of the following conditions must be met before the bank can complete a transfer:
- The authorities have determined that the third country provides an adequate level of protection
- There are other safeguards such as standard contractual clauses or binding corporate rules
- There is specific approval from a supervisory authority
- It is permitted under applicable data protection laws
How long GrønlandsBANKEN stores your personal data
GrønlandsBANKEN only stores your personal data as long as necessary to fulfill the terms of any agreements you may have with GrønlandsBANKEN regarding products and services.
GrønlandsBANKEN also stores personal data to comply with legal requirements and requirements for retention of business information.
Even if you close your account or unsubscribe from services at GrønlandsBANKEN, the bank needs to retain some of your personal data for a certain period relating to the relevant account or service.
For example, GrønlandsBANKEN must be able to report to tax authorities and comply with legal requirements regarding anti-money laundering and accounting. Under the Anti-Money Laundering Act, information, documents, transactions, and records are stored for at least 5 years after the end of the customer relationship or the completion of a transaction, in the case of a single transaction.
If you apply for a product or service but do not enter into an agreement with GrønlandsBANKEN, your personal data will be stored for a shorter period in order to document the dialogue with the bank.
How you can control and access your personal data
You have several rights regarding the personal data that GrønlandsBANKEN processes:
- You may at any time request a copy of the personal data the bank has about you. This is usually done free of charge
- If you do not wish to receive direct marketing materials, you may notify the bank at any time by contacting your local branch of GrønlandsBANKEN
- If you discover that the information GrønlandsBANKEN has about you is incorrect, the bank will correct it as soon as it becomes aware
- You may request deletion or restriction of the processing of your personal data under certain conditions
- You may object to the bank’s processing of your personal data based on GrønlandsBANKEN’s legitimate interest as described above
- You may request a digital copy of most of the personal data you have provided to GrønlandsBANKEN, and which the bank processes in its systems. GrønlandsBANKEN can also, upon your request and if technically feasible, transfer this data directly to other companies or authorities that process your personal data
If you wish to exercise your rights, you can contact your local branch or GrønlandsBANKEN’s Data Protection Officer.
Additional information
If you have questions or wish to file a complaint about the bank’s processing of your personal data, please contact your branch or write to GrønlandsBANKEN.
You can find contact information for your local branch and further contact details here.
GrønlandsBANKEN has a Data Protection Officer. Contact: dpo@banken.gl
You also have the right to submit a complaint to GrønlandsBANKEN’s complaints officer. See the complaints guide here.
The supervisory authority for the processing of personal data is the Danish Data Protection Agency (Datatilsynet), Carl Jacobsens Vej 35, 2500 Valby, Denmark.