1. Introduction
ABN Noordvest Bank (“the Bank,” “we,” “us,” or “our”) is committed to maintaining the confidentiality, integrity, and security of your personal and financial information. This Privacy Policy outlines how we collect, use, store, disclose, and protect your data in full compliance with the General Data Protection Regulation (GDPR), as implemented under Dutch law, including the Dutch GDPR Implementation Act (Uitvoeringswet AVG) and other applicable European data protection frameworks.
Our services are strictly private, by invitation only, and offered exclusively to qualified High-Net-Worth Individuals (HNWI), Ultra-High-Net-Worth Individuals (UHNWI), family offices, and institutional entities. All personal data is handled with the highest level of discretion and processed solely for lawful and specified purposes related to the provision of our bespoke banking and advisory services.
2. Information We Collect
We collect only the information necessary to provide bespoke financial services, comply with regulatory obligations, and manage risk appropriately. The types of information we collect include:
2.1 Personal Identification Information
Full legal name
Date of birth
Social Security Number / Tax Identification Number
Government-issued identification (e.g., passport, driver’s license)
2.2 Contact & Communication Data
Physical and mailing addresses
Email addresses
Phone numbers
Preferred communication channels
2.3 Financial Information
Bank account and investment portfolio details
Source of wealth and income
Credit history and liquidity status
Lending history and risk profile
2.4 Due Diligence & Compliance Data
KYC/AML documents
FATCA/CRS declarations
Beneficial ownership structures
Legal entity information
2.5 Digital Interaction Data
IP addresses
Device information
Login credentials and access logs (for digital platforms)
Communications history, including emails, messages, and call recordings (where permitted)
3. How We Use Your Information
We use the information we collect for lawful business and compliance purposes, including:
Client onboarding and identity verification
Providing tailored financial and banking services
Performing credit, risk, and legal assessments
Complying with legal, regulatory, and tax obligations
Preventing fraud, money laundering, and other financial crimes
Communicating updates, performance insights, and strategic advice
Conducting internal analytics and operational enhancements
4. Legal Basis for Processing
We process your personal data under the following legal bases:
Contractual Necessity – to fulfill our agreements with you.
Legal Obligation – to comply with applicable laws and regulations.
Legitimate Interest – to manage our business effectively and safeguard client trust.
Consent – where required, for specific marketing or data-sharing purposes.
For clients subject to the GDPR, we ensure that all data processing adheres to Articles 6 and 9 of the regulation.
5. Information Sharing and Disclosure
We do not sell, rent, or trade your personal information. Information is disclosed strictly under these conditions:
5.1 Internal Use
Shared among authorized departments within the Bank on a need-to-know basis, bound by strict confidentiality.
5.2 Third-Party Vendors
Secure sharing with trusted third-party service providers (e.g., custodians, auditors, IT vendors), bound by data protection agreements and confidentiality clauses.
5.3 Legal & Regulatory Disclosure
When required by law or requested by regulatory bodies (e.g., IRS, SEC, FINRA, FATF-compliant bodies).
5.4 International Transfers
For clients or services outside the U.S., personal data may be transferred across borders, but always in compliance with the applicable laws (e.g., GDPR Standard Contractual Clauses, U.S.-EU Data Privacy Framework).
6. Data Retention
We retain client information only for as long as is necessary for the purposes outlined in this policy, including:
The duration of the client relationship
The period required by tax, legal, and regulatory obligations
Statutory limitation periods for legal claims
Retention periods typically range from 7 to 10 years after relationship termination, unless longer periods are required by law or litigation.
7. Data Security Measures
We employ industry-leading physical, digital, and procedural safeguards to protect your information, including:
256-bit AES encryption for all stored data
SSL/TLS for all communications
Biometric and multi-factor authentication
Access controls and audit logs
Encrypted offsite and cloud backups
Regular third-party penetration testing and vulnerability scans
Employee training and access limitation by role
8. Your Rights
Depending on your jurisdiction, you may have the following rights concerning your data:
8.1 United States (including California residents)
Right to know what data we collect and how we use it
Right to access and receive a copy of your data
Right to request deletion of personal data (subject to legal exceptions)
Right to opt out of data sharing for non-essential services
8.2 European Union (GDPR)
Right to access, rectify, or erase your data
Right to restrict or object to processing
Right to data portability
Right to lodge a complaint with a supervisory authority
To exercise any of these rights, please email us at support@firstelitetrust.com. Verification of identity will be required.
9. Cookies and Online Tracking
Our digital platforms may use cookies or other tracking technologies to enhance user experience, optimize site performance, and maintain session security. We do not use behavioral advertising, third-party analytics sharing, or remarketing tools.
You may control cookie preferences via your browser settings.
10. Children’s Privacy
Our services are not directed to, and we do not knowingly collect data from, individuals under the age of 18.
11. Changes to This Privacy Policy
We reserve the right to amend this Privacy Policy at any time. Clients will be notified of significant changes through direct communication or system notices. Continued use of our services after any updates constitutes acceptance of the revised policy.
12. Contact and Queries
For questions, data requests, or complaints regarding this Privacy Policy, please contact:
ABN Noordvest Bank
Privacy Compliance Office
Dam 27, 1012 JS Amsterdam, Netherlands
Email: support@noordvest.com