Declaration of Privacy Policy

　　The following sections explain how and for what purposes Shanghai Pudong Development Bank Co., Ltd, London Branch will use your personal information.

　　Using your personal Information

　　We currently may hold personal and financial information about you and may obtain or receive such information about you in the future. The information we process about you will be obtained from various sources including:

　　？ directly from you;

　　？ from your dealings with any member of the Group including from the transactions and operation of your accounts and services; and

　　？ from other organisations including credit reference and fraud prevention agencies.

　　We may link information concerning your accounts with us to information relating to products and services we provide to you.

　　Such information may also include sensitive personal data, such as information relating to your health, criminal convictions or proceedings. However, we only hold such data where we need to for the purposes of the product or services we provide to you or where it is in our normal course of business to do so.

　　Uses of your information

　　We will use your information:

　　？ to make credit decisions about you and anyone to whom you are linked financially (which may involve credit scoring);

　　？ managing credit and credit-related facilities;

　　？ to consider and implement business, product and technology developments;

　　？ to undertake statistical analysis, financial risk assessment, money laundering checks (which may include telephoning you), compliance and regulatory reporting, fraud prevention and recovering debt;

　　？ to help us identify products and services which may be of interest to you (unless you have asked us not to); and

　　？ systems testing and development.

　　Confidentiality

　　We will disclose information outside Shanghai Pudong Development Bank Co., Ltd, London Branch only:

　　？ if compelled to do so by law;

　　？ if appropriate, where you have provided your consent (which is not necessarily required to be in writing);

　　？ where we have a public duty to disclose the information;

　　？ to our agents or subcontractors for operational reasons;

　　？ to third parties, such as affinity partners, who have introduced your custom to the Bank - we may pass back to the introducer information to enable administration of any payment or settlement, or of any benefit to you under the affinity agreement;

　　？ to any persons, including, but not limited to, insurers, who provide a service or benefits to you or for us in connection with your account(s);

　　？ to licensed credit reference agencies and fraud prevention and other agencies;

　　？ where we need to do so to comply with the requirements, codes or recommendations of any of our regulators;

　　？ to confirm your identity for money laundering purposes, which may include checking the electoral register;

　　？ to any person to whom we will or intend to transfer our rights or obligations; and

　　？ to any subsidiary of the Bank or holding company thereof from time to time and each subsidiary from time to time of any such holding company.

　　Fraud prevention agencies

　　We may disclose your information to licensed credit reference agencies to help make financial decisions (this will be during the application process and on an on-going basis, to decide whether to continue to make products or services available to you or adjust any level of credit) for you and anyone with whom you are linked financially – our enquiries or searches may be recorded – and credit reference agencies may supply us with financial information. If you make several credit applications within a short time, this may temporarily affect your ability to obtain credit.

　　Credit reference agencies

　　We may also disclose information to licensed credit reference agencies about how you conduct your account(s) and this information may be shared with other financial institutions to help make financial decisions about you and anyone with whom you are linked financially. If you borrow and do not repay in full and on time, we may tell credit reference agencies who will record the outstanding debt.

　　If false or inaccurate information is provided by you or on your behalf, if we suspect fraud or if fraud is identified, details will be kept in our records and also passed to fraud prevention agencies, law enforcement agencies and other organisations involved in crime and fraud prevention which may access and use this information. We and those other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

　　？ checking details on applications for credit and credit related or other facilities;

　　？ managing credit and credit related accounts or facilities;

　　？ recovering debt;

　　？ checking details on proposals and claims for all types of insurance; or

　　？ checking details of job applicants and employees.

　　Provision of services, transfer of information and regulators

　　From time to time we will engage service providers, agents and subcontractors to provide services. They will have access to, and will process, your information on our behalf to provide such services.

　　We may need to transfer your information abroad to other Group companies, service providers, agents and subcontractors in countries where they may not have data protection laws providing the same level of protection as those in the European Economic Area. 

　　In each of the above circumstances, we will ensure that your information is processed only in accordance with the applicable legislation and under strict obligations of confidentiality.

　　We may also be required to share information about you with our regulatory authorities.

　　Sharing Information about You with tax authorities

　　If we take the view that you may be required to report your income or are otherwise subject to tax in another country then we may share information about your accounts with the relevant foreign tax authority or with the UK tax authority (which may then share that information with the appropriate foreign tax authority). If, to facilitate this, we need to request information or documents from you then you must supply these to us within 30 days. If you don’t do this, you agree that we may either close your account or, if the law or other regulations requires us to do so, withhold such funds from your account as required and pass those withheld funds to the relevant tax authorities.

　　Marketing

　　We may contact you by post, phone, email, SMS text or other reasonable means to inform you about products and services supplied by ourselves or selected third parties that we consider may be of interest to you. We may also share your information with those carefully selected third parties so that they can contact you directly. You can inform us at any time if you do not want to receive marketing information.

　　We may record and/or monitor telephone calls to enhance security, to help address complaints, improve our customer service and for staff training purposes.

　　Sale or Transfer

　　If we or any other company in our Group wishes to sell or transfer all or part of its business and assets or any associated rights of interest, or to acquire a business or enter into a merger, we may require to disclose your personal data and confidential information to any potential buyer, transferee, merger partner or seller and its advisers and any other persons we may reasonably decide requires to see such information. We will ensure that your information is processed only in accordance with our instructions and under strict obligations of confidentiality. If the sale or transfer is completed the buyer, transferee, or merger partner may continue to use, process and disclose your information subject to the same provisions set out here.

　　Changes to your information

　　We need the information we hold about you to be accurate and up to date. Please help us by informing us promptly of any changes to your personal circumstances or details.

　　Your rights

　　You are entitled to a copy of the personal information we hold about you on payment of a fee. For further information on your rights under the Data Protection Act, you can contact: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or visit www.ico.gov.uk.

　　If you would like details of the agencies from which we obtain and record information about you, please write to: Shanghai Pudong Development Bank Co., Ltd, London Branch, Legal and Compliance, 19th Floor, 1 Angel Court, London EC2R 7HJ.