We respect your privacy and we are committed to protecting your personal data. This Privacy Notice will inform you as to how The cooperative investment bank look after your personal data when using any of our products, services or applications (together the “Services”) or when visiting or using our websites or mobile application (“App”).
This Privacy Notice tells you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Notice.
1. Important Information And Who We Are
Purpose of this Privacy Notice:
This Privacy Notice aims to give you information on how we collect and process your personal data when you visit our Site, or through your use of the Services and any data you may provide when you register for or use the Services, sign up for alerts or newsletters, contact us with a question or request for help, participate in any renewals, promotions or surveys.
The Site and the Services are not intended for minors below 18 and we do not knowingly collect data relating to minors.
It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice, we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements other notices and privacy notices and is not intended to override them.
TCIB is the controller and responsible for the collection of your personal data through the App.
Data Protection Officer:
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
If you have any questions or complaints about this Privacy Notice or our privacy practices, please contact our DPO in the following ways:
For EU resident, you have the right to make a complaint about the way we process your personal information to the Information and Data Protection Commissioner (IDPC), Malta's supervisory authority for data protection issues (idpc.in). We would, however, appreciate the chance to deal with your concerns before you approach the IDPC, so please feel free to contact us in the first instance.
Changes to the Privacy Notice and your duty to inform us of changes:
We keep our Privacy Notice under regular review. This version was last updated on the date above written. If we change our Privacy Notice and you have already registered with us we will let you know in advance by email.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The Site and App may include links to third-party websites, plug-ins and applications ("Third Party Sites"). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these Third-Party Sites and are not responsible for their privacy statements. When you leave our Site or App, we encourage you to read the privacy notice of every Third Party Site you visit or use.
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth and gender, a visual image of your face, tax identification number, national identity cards, passports or other form of identification documents including proof of address such as a utility bill or bank statement.
Contact Data includes billing address, delivery address, home address, work address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of any transactions you enter into using products and services you have purchased from us.
Investment Data includes information about your investment objectives, investment experience and prior investments.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location data, browser plug-in types and versions, operating system and platform, and other technology or information stored on the devices you allow us access to when you visit the Site or use the Services, such as friends lists or other digital content.
Profile Data includes your username and password, requests by you for products or services, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our Site, App, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
As explained above under Identity Data, we will also collect a visual image of your face which we will use, in conjunction with our sub-contractors, to check your identity for onboarding purposes. This data falls within the scope of special categories of data (see Special Categories of Data below). When we ask to collect a visual image of your face you will be asked for your specific consent. You can refuse to provide this but it means that we will be unable to register you and provide you with the Services.
In addition, the law also treats certain other categories of personal information as special. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data, as well as details of criminal records. We will not collect or use these types of data (known as Special Categories of Data) without your consent unless the law allows us to. If we do, it will only be when it is necessary:
for reasons of substantial public interest (for example to use criminal records to help prevent, detect, and prosecute unlawful acts and fraudulent behaviour); or
to establish, exercise or defend legal claims.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
If you refuse to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you refuse to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms, providing a visual image of yourself via the Service, by email or otherwise. This includes personal data you provide when you:
apply for our products or services;
create an account;
subscribe to our service or publications;
make use of any of our Services;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with us via our Site or App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We will also collect Transaction Data and Investment Data. We may also receive Technical Data about you if you visit other websites employing our cookies. Please refer to our main website, where you can access the Cookie Consent banner for more details.
Third parties or publicly available sources. We also obtain information about you from third parties (such as employers, credit reference agencies and fraud prevention agencies) who may check your personal data against any information listed on other databases.
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
For the provision of the Services.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Please refer to the GLOSSARY, LAWFUL BASIS sections to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer