In this section, we explain why we process your personal data and the legal basis for doing so.
3.1 Your personal data is processed to comply with our various legal and/or regulatory obligations
Your personal data is processed, where necessary, to enable us to comply with the laws and/or regulations to which we are subject, including real estate, banking and financial regulations.
3.1.1 We use your personal data to:
- monitor and report risks (financial, credit, legal, compliance or reputational risks etc.) that the BNP Paribas Group could incur in the context of its activities;
- record transactions for accounting purposes;
- prevent, detect and report risks related to Corporate Social Responsibility and sustainable development;
- detect and prevent bribery;
- comply with the provisions applicable to trust service providers issuing electronic signature certificates;
- exchange and report different operations, transactions or orders or reply to an official request from duly authorized local or foreign financial, tax, administrative, criminal or judicial authorities, arbitrators or mediators, law enforcement, state agencies or public bodies.
3.1.2 We also process your personal data for anti-money laundering and countering of the financing of terrorism purposes
As part of a banking group, we must have a robust system of anti-money laundering and countering of terrorism financing (AML/TF) in each of our entities managed centrally, as well as a system for applying local, European and international sanctions.
In this context, we are joint controllers with BNP Paribas SA, the parent company of the Group (the term "we" in this section includes BNP Paribas Real Estate Advisory & Property Management UK Limited and BNP Paribas SA).
The processing activities performed to meet these legal obligations are detailed in Appendix 1 “Processing of personal data to combat money laundering and terrorist financing”.
3.2 Your personal data is processed to perform a contract to which you are a party or pre-contractual measures taken at your request
Your personal data is processed when it is necessary to enter into or perform a contract to:
- evaluate if we can offer you a product or service and under which conditions
- provide you with the products and services subscribed to under the applicable contract;
- manage existing debts (identification of clients with unpaid debts);
- respond to your requests and assist you.
3.3 Your personal data is processed to fulfil our legitimate interest or that of a third party
Where we base a processing activity on legitimate interest, we balance that interest against your interests or fundamental rights and freedoms to ensure that there is a fair balance between them. If you would like more information about the legitimate interest pursued by a processing activity, please contact us using the contact details provided in section 2 “HOW CAN YOU CONTROL WHAT WE DO WITH YOUR PERSONAL DATA” above.
3.3.1 In the course of our business activity of real estate, we use your personal data to:
- manage the risks to which we are exposed:
- we keep evidence of operations or transactions, including in electronic evidence;
- we monitor your transactions to manage, prevent and detect fraud;
- we carry out the collection of debts;
- we manage legal claims and defence our position in the event of litigation;
- we develop individual statistical models in order to help define your creditworthiness.
- enhance cyber security, manage our platforms and websites, and ensure business continuity.
- use video surveillance to prevent personal injury and damage to people and property.
- enhance the automation and efficiency of our operational processes and client services (e.g., automatic filling of complaints, tracking of your requests and improvement of your satisfaction based on personal data collected during our interactions with you such as phone recordings, e-mails or chats).
- carry out financial operations such as debt portfolio sales, securitizations, financing or refinancing of the Group.
- conduct statistical studies and develop predictive and descriptive models for:
- commercial purposes: to identify the products and services that could best meet your needs, to create new offers or identify new trends among our clients, to develop our commercial policy taking into account our clients' preferences
- safety purposes: to prevent potential incidents and enhance safety management;
- compliance purposes (e.g., anti-money laundering and countering the financing of terrorism) and risk management;
- organising contests, lotteries, promotional operations, conduct opinion and client satisfaction surveys.
3.3.2 We use your personal data to send you commercial offers by electronic means, post and phone
As part of the BNP Paribas Group, we want to be able to offer you access to the full range of products and services that best meet your needs.
Once you are a client and unless you object, we may send you marketing materials relating to our products and services and those of the Group provided these are similar to those you have already subscribed to.
We will ensure that these commercial offers relate to products or services that are relevant to your needs and complementary to those you already have to ensure that our respective interests are balanced.
We may also send you, by phone and post, unless you object, offers concerning products and services of the BNP Paribas Group as well as those of the Group and our trusted partners.
Finally, and with your consent, we may also send you commercial offers electronically concerning the products and services of the entire BNP Paribas Real Estate Group.
3.3.3 We analyse your personal data to perform standard profiling to personalize our products and offers
To enhance your experience and satisfaction, we need to determine to which client group you belong. For this purpose, we build a standard profile from relevant data that we select from the following information:
- what you have directly communicated to us during our interactions with you or when you subscribe to a product or service;
- resulting from your use of our products or services such as those related to your accounts including the balance of your accounts, regular or atypical movements, the use of your card abroad as well as the automatic categorization of your transaction data (e.g., the distribution of your expenses and your receipts by category as is visible in your client area);
- from your use of our various channels: websites and applications (e.g., if you are digitally aware, if you prefer a client journey to subscribe to a product, or service with more autonomy (self-care));
Unless you object, we will perform this customization based on standard profiling. If you consent, we may go further to better meet your specific needs by offering you products and services tailored to you.
3.4 Your personal data are processed if you have given your consent
For some processing of personal data, we will give you specific information and ask for your consent. Of course, you can withhold your consent or, if given, withdraw your consent at any time.
In particular, we ask for your consent for:
- tailor-made customization of our offers and products or services based on more sophisticated profiling to anticipate your needs and behaviours;
- any electronic offer for products and services not similar to those you have subscribed to or for products and services from our trusted partners;
- use of your navigation data (cookies) for commercial purposes or to enhance the knowledge of your profile.
You may be asked for further consent to process your personal data where necessary.