ESKIMO's Privacy & Cookie Statement

What do we mean by personal data?

Personal data, is any information relating to you or can be used to identify you.

As a client of ESKIMO you provide us with some of your personal data, this includes your name, telephone number, email address. It can also include Internet Protocol or IP addresses which in some circumstances can be used to identify you.

In the event that a corporate or professional party intend on becoming a client, we will also collect personal data which relates to the interested individuals of the company for example, directors, UBO, authorised representatives etc.

How do we collect your data?

Below you will find ways in which we collect your personal data:

• When you provide information by email, via the website, phone, in writing, or other means. This includes for example the information you provide during the registration, signing up for further information, entering a promotion or survey.;
• When you visit our websites, we will automatically collect information including the IP address. We also collect information about your visit, this includes the full click path and mouse movement, pages you visited, searches which were made and other page interaction information.;
• It is possible that we will receive information about you from credit rating agencies, this collection is carried out in line with the Client Agreement.;
• For Corporate clients we will also collect information which is publicly available in relation to the UBOs of the company.;
• If you visit us in person, for security we collect images of visitors using CCTV.;

What do we use personal data for?

ESKIMO may for example do the following with your personal data:

Client acceptance

It is required by law for us to verify the identity of our clients, and without this information ESKIMO could not provide its services to you. With your personal data we can for example,

• Contact you.
• Perform the relevant checks to ensure that you are eligible to become a client of ESKIMO.
• Review and check your request to become our client or to change your profile.
• Keep your details in our administration and update them when there are changes.
• Manage your profile(s) including you individual risk profile; which are based on internal client acceptance policies.

Reduce risks

We share the responsibility for the safety and stability of the financial sector. We also have a responsibility to you and all our clients. We will therefore use your personal data to reduce risks.

You might notice for example:

• If the risk on your account breaches the allowed limits we will contact you to allow you to bring this back into the allowed limits.

You might not notice much of the below but it is also done to protect you:

• We keep your IP address when you visit our site. This can be used in the event that there is a dispute as to who accessed your account or for the security of the company for example preventative measures against DDoS attacks.
• Ensure good levels of security and invest in resources that protect both you and ourselves against all kind of crimes.
• Internal quality checks, to determine possible issues, risks and testing to ensure that legislation has been properly implemented.
• Carry out the relevant regulatory reporting.
• Ensure that we remain a healthy company (risk management).

Legal obligations

There are a variety of legal obligations which ESKIMO as an investment firm must follow.

• Identification of clients: we check who you are and ensure that we have enough knowledge to allow us to offer our services.
• Provide your personal data to specific organisations which are authorised to request this information, for example the tax authorities, financial supervisors, or when we are legally obliged to share this information for example during a criminal investigation.
• We also have a number of obligations under anti money laundering legislation.

Marketing activities

At ESKIMO we like to keep you informed. For example, with emails, newsletters, offers or updates to our Mobile App.

• We can for example collect your searches within the website of ESKIMO to ensure that our FAQ are up to date with the information clients need. This information is anonymised, so no one is able to ascertain which client is asking the question.
• We use anonymised data to ensure that our marketing campaigns are effective.

If you would prefer not to receive some of this information, please feel free to contact the Service desk or unsubscribe via the button within the marketing email.

Improve and innovate

We may also use personal data for analytical research, this allows us to find better solutions and ensure that we continue to be innovative.

When we are carrying out these research activities, we use the minimal data required and do this in a way where your information is either pseudonymised or anonymised.

Google analytics

In order to ensure that the website of ESKIMO is easy to use for clients, and to assess the success of campaigns ESKIMO make use of Google Analytics. ESKIMO have signed an agreement for the use of this service and ensures that the data is anonymised as much as possible, this includes masking part of the IP address.

What personal data is collected?

Data about you

This includes your name, address, telephone number and email address. In the event you are a corporate client we will also collect information surrounding your company or foundation. If you open a minor account or a joint account, the information surrounding the secondary account holders will also be collected. We will also ask for copies of your ID and personal numbers such as your tax identification number or relevant identifiers.

Transaction history

In addition to personal data which ESKIMO have in relation to clients, we also keep a historic log concerning transaction and order history.

Contact history

We keep record of the times when you have contacted ESKIMO, this includes telephone recordings, emails or other ways you have communicated with us.

Website visits and app use

In the event that you visit the website of ESKIMO, we will also collect the IP address which is used. Should your IP address be used, for example via Google Analytics this will be done in an anonymised way.

External data sources

There are times where ESKIMO will use external data provides, such as checking with the relevant chamber of commerce or in the event a credit check is required.

In the event that ESKIMO carry out credit checks (BKR) they apply the strictest confidentiality on this information. Any individual who has access to this information does so only in the performance of their duty and the relevant data protection regulation is fully complied with. In the event you have questions of when BKR checks are carried out please contact the service desk of ESKIMO.

Sensitive personal data

Sensitive personal data include things such as tax identification number, criminal history, biometric data, political beliefs, sexuality or ethnic origin, etc. If processing sensitive personal data is necessary, there are stricter rules applied to this.

At ESKIMO we never use sensitive data related to health, religious beliefs, political or philosophical beliefs, sexual orientation or ethnic origin.

We have a legal obligation to identify our clients, therefore we require the tax identification number to do this.

How long do we store your personal data?

When you become a client of ESKIMO we will keep your personal data for the duration of our relationship, we have a legitimate business need to do so. Upon the end of the relationship we are required to keep this personal data for five years. We need to keep this to ensure that we can comply with legal obligations such as fighting financial crime or to settle any disputes or mount a legal defence.

Is your personal data used in automated decision making?

There are times for example when you change profile from a Basic to an Active or Trader or Day Trader that we will automatically screen your account against the information from the Bureau Krediet Registratie. Should there be an issue in providing the services of Debit Money, the Service Desk will contact you to inform you that you are unable to make use of the services Debit Money and how to proceed in this case.

Our view on privacy

At ESKIMO, our clients trust is fundamental to our relationship. We therefore strive to ensure that our clients have faith in the way we deal with their personal data. We take great care in ensuring that your data is safe and only processed when authorised to do so.

When we process your personal data, we always make sure that it is essential for us to do this. When possible, we will anonymise your personal data or when this is not possible, we will only use the data which is strictly necessary. For processing your personal data, we will also ensure that the concept of ‘privacy by design’ is at the heart of our development.

Our privacy policy is updated regularly, as law and regulations are continuously subjected to change, we will review the policy to ensure that it is kept up to date.