We will explain how we use any personal data we collect about you or that you provide to us.
- “Cynergy Bank Group” means Cynergy Bank Limited and its group entities;
- “Bank of Cyprus Group” means Bank of Cyprus Public Company Limited and its group entities.
The following Cynergy Bank Group companies will act as a data controller where you hold a product or service with them or contact them for information on a product or service. Please refer to your product documentation. Any references to “we, us, our” means either:
- Cynergy Bank Limited - registered in England and Wales as company number 04728421.
- Cynergy Business Finance Limited - registered in England and Wales as company number 13322121.
Please note that Cynergy Business Finance Limited is a subsidiary of Cynergy Bank Limited and your personal data may be passed to Cynergy Bank for reporting purposes.
Cynergy Business Finance Limited
Please note that if you are looking to use data extraction services, your data will be passed between Dancerace and Xero which may involve processing of your data by certain third party processors appointed by Dancerace and the transfer of your data outside the EEA. More information can be found on:
If you applied for a Coronavirus Business Interruption Loan (CBILS) or Recovery Loan Scheme (RLS) with Cynergy Bank Limited, please note the following:
Categories of Personal Data that we process
If you apply for any product with us we generally always collect:
- Your financial details e.g. salary, other income;
Your title, name, home address and address history as well as contact details such as telephone and mobile numbers and email address;
- National Insurance and Tax Identification number (TIN) used for identification purposes and for use with ISA's;
- Date of birth;
- Nationality and tax residence in order to comply with our legal and regulatory obligations;
- Other details regarding proof of residency such as utility and passport information which we retain on our file;
- Information regarding your employment status and your employers identity;
- If you are opening an online account, your IP and MAC address as relevant;
- Personal data about you which is obtained from third parties (such as credit reference agencies where you have applied for an overdraft or other credit facilities connected with your account, fraud prevention agencies and such publicly available sources such as the electoral roll and in some cases records of debt judgements and bankruptcy information - for further details see the Credit Reference Agencies section;
- Any other information you give to us or our agents.
You must show this privacy notice to the other applicant(s) and obtain confirmation from them that they know you share their information with us for the purpose described and where necessary obtain their consent for us to process their personal details.
If you are a prospective customer, or a non-customer counterparty in a transaction of a customer (e.g. account or payment authorisation (by SWIFT or not) and over-the-counter transactions) or prospective security provider (e.g. a guarantor for a credit facility) or an authorised representative/agent or beneficial owner of a legal entity or of a natural person which/who is a prospective customer, the relevant personal data which we collect may include:
Name, address, contact details (telephone, email), EU basic payment account identification, birth date, place of birth (city and country), marital status, employed/self-employed, if you hold/held a prominent public function (for PEPs), FATCA / CRS info and authentication data.
Current Account applications
When you apply for a Current Account we will require current income and expenses, employment position and history, property ownership and personal debts, number of dependent children, personal investments and investment income, other banking relationship details, tax residence and tax ID, credit reference agency data, residence or work permit in case of non-EU nationals.
For individuals who will be providing their personal guarantees, the Bank will request personal data disclosing their economic and financial background and credit reference agency data.
We understand the importance of protecting children's privacy therefore, we only collect children’s personal data if we have obtained their parents' or legal guardian's consent or unless otherwise permitted under law. We do not provide any online services to children but we may allow children, with their parents' or legal guardian's consent, to access accounts opened for their benefit on the Bank's online banking system in order to view their account balances. For the purposes of this privacy statement, "children" are individuals who are under the age of eighteen (18) years.
When you apply for a mortgage we will require current income and expenses, employment position and history, property ownership and personal debts, number of dependent children, personal investments and investment income, life insurances (life insurance companies, policy numbers, current surrender values), other banking relationship details, tax residence and tax ID, residence or work permit in case of non-EU nationals.
We carry out credit and identity checks when you apply for a product or services for you or your business. See our section on Credit Referencing Agencies for more information. However, some of our identity checks will be done by Jumio Corporation, based in California, USA so we need to share your personal data with them. Please see the section on the Transfer of your personal data to a third country or to an international organisation below. Such personal data can include:
- Date of birth
- identification image – including a ‘selfie’ image and identity photo documents such as a driving license
- Email address
- IP address
For more information on how Jumio Corporation processes your data, please visit: https://www.jumio.com/legal-information/privacy-policy/jumio-corp-privacy-policy-for-online-services/
Please also see the section below on Automated Decision Making and Profiling.
Credit Reference Agencies
We may share your personal data with Credit Reference Agencies and this may be carried out on a different basis depending on the type of product. We will inform you when a search will result in an entry on your credit file.
Data exchanged can include:
- Name, address and date of birth
- Credit application
- Details of any shared credit
- Financial situation and history
- Public information, from sources such as the electoral register and Companies House.
We'll use this data to:
- Verify your identity and your address when you apply for a product or service for you or your business
- Carry out credit checks and assess whether you or your business is able to afford to make repayments
- Make sure what you've told us is true and correct
- Help detect and prevent financial crime
- Manage accounts with us
- Trace and recover debts
- Obtain information about you such as missed payments on other accounts you hold
- Make sure that we tell you about relevant offers (where you have consented to this); and
- Ensure any offers provided to you are appropriate to your circumstances (where you have consented to this).
The Credit Reference Agencies may give this information to other organisations that want to check your credit status. You can find out more about the Credit Reference Agencies on their websites, in the Credit Reference Agency Information Notice (CRAIN) which sets out how your data will be processed by Callcredit, Equifax and Experian and their privacy notices.
Credit Reference Agency:
Privacy Notice Link:
Joint Applicants and Businesses
If you apply for a product with someone else, we will link your records with theirs including if you tell us you have a spouse, partner or civil partner – or that you are in business with other partners or directors. These links will stay on your files unless one of you asks the Credit Reference Agencies to break the link. You will normally need to give proof that you no longer have a financial link with each other.
When Credit Reference Agencies receive a search from us they will place a search footprint on your credit file that may be seen by other lenders and those that you apply with. It is important that they know your records will be linked together, and that credit searches may be made on them so you should tell them before applying.
We will go on sharing your personal data with Credit Reference Agencies for as long as you are a customer and will include details:
- of your repayments and whether you repay on time
- about your settled accounts and any debts not fully repaid on time;
- of funds going into the account and the account balance.
Fraud Prevention Agencies
We may need to confirm your identity before we provide products or services to you or your business. Once you have become a customer of ours, we will also share your personal data as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies (FPA) such as CIFAS and National Hunter to help us with this, and if false or inaccurate information is provided and fraud identified, details will be passed to Fraud Prevention Agencies to prevent money laundering.
Both we and Fraud Prevention Agencies can only use your personal data if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest'.
A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for you.
We will use the information to:
- Confirm identities
- Help prevent fraud and money-laundering
- Fulfil any contracts you or your business has with us
We or a Fraud Prevention Agency may allow law enforcement agencies to access your personal data. This is to support their duty to detect, investigate, prevent and prosecute crime.
FPAs can keep personal data for different lengths of time. It is up to six years if they find a risk of fraud or money-laundering.
The information we use:
- Date of birth
- Residential address
- History of where you have lived
- Contact details, such as email addresses and phone numbers
- Financial data
- Data relating to your or your business products or services
- Employment details
- Data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address
Why we process your personal data and on what legal basis
We are committed to protecting your privacy and handling your data in an open and transparent manner and as such we process your personal data in accordance with the Data Protection Act 2018 for one or more of the following reasons:
- For the performance of a contract
- to carry out banking transactions and offer financial services
- to be able to complete our acceptance procedure so as to enter into a contract with prospective customers
The purpose of processing personal data depends on the requirements for each product or service and the product terms and conditions provide more details of the relevant purposes.
- For compliance with a legal obligation
There are a number of laws and regulations we must comply with as well as statutory requirements, e.g. UK banking law, the Money Laundering Law, Tax laws, Law on Deposit Guarantee Protection and Resolution of Credit and Other Institutions Scheme, Payments Law and Payment Scheme Rules.
There are also various supervisory authorities whose laws and regulations we are subject to (see Who receives your personal data? below).
Such obligations and requirements impose on us necessary personal data processing activities for credit checks, identity verification, compliance with court orders, tax law or other reporting obligations and anti-money laundering controls.
- For the purposes of safeguarding legitimate interests
A legitimate interest is when we have a business or commercial reason to use your information which may be pursued by us or by a third party. But even then, it must not unfairly go against what is right and best for you. Examples of such processing activities include:
- Initiating legal claims and preparing our defence in litigation procedures
- Means and processes we undertake to provide for the Bank's IT and system security, preventing potential crime, asset security, admittance controls and anti-trespassing measures
- Setting up CCTV systems, e.g. at ATMs, for the prevention of crime or fraud
- To adhere to best practice, rules and requirements of bodies such as HMRC; the FCA; the PRA; the FOS; the Information Commissioner's Office; the FSCS
- Measures to manage business and for further developing products and services,
- Sharing your personal data to other companies in the Bank of Cyprus Group where we have a contractual requirement to do so following our separation from the Bank of Cyprus Group
- Our own and risk management
- The transfer, assignment (whether outright or as security for obligations) and/or sale to one or more persons (including the Bank of England) of and/or charge and/or encumbrance over, any or all of the Bank's benefits, rights, title or interest under any agreement between the customer and the Bank.
- You have provided your consent
Provided that you have given us your specific consent for processing (other than for the reasons set out hereinabove) then the lawfulness of such processing is based on that consent. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.
Examples of when we process data with your consent are:
- When you request us to share your data with someone else
- When you indicate you wish to receive direct marketing from us
- For some special categories of Personal data such as data regarding your health or if you have special circumstances which may require us to tailor how we communicate with you; in such circumstances we will explain to you when we ask for your consent what purpose and how we will use your data.
- Processing for a substantial public interest
We may process data for a substantial public interest under laws which apply to us where this helps us to meet our broader social obligations such as processing information about your health or if you have a special need which may require us to tailor how we communicate with you or where we need to fulfil our legal or regulatory obligations.
Recording our calls
We regularly record and monitor our telephone calls to help:
- improve customer service
- meet our legal and regulatory requirements
- answer your queries and issues
- detect and prevent fraud and/or other crimes
Social media and other public websites
You may find us on social media websites including (but not limited to) LinkedIn, Twitter and YouTube. We use these websites to provide news about us and any upcoming events. We may also appear on other public websites including (but not limited to) Trustpilot.
If you engage with us on any website, please note this will become public information, therefore, do not share your personal account information on any of the websites, including through the use of private messages as we cannot guarantee how secure they are.
Any information that you provide us with on social media web pages may be retained by the website for longer than your relationship with us.
Please note we will not put any of your personal data on social media or any other public website.
Text Message (SMS) and Push Notifications
We will send you text messages and push notifications (messages that pop up on mobile devices) and through new methods that may become available in the future. In establishing and carrying out a business relationship, we generally do not use any automated decision-making. We may process some of your data automatically, with the goal of assessing certain personal aspects (profiling), in order to enter into or perform a contract with you, in the following cases:
We will send you a text message to your mobile device allowing you to verify your identity (authentication) and access the service when you first register for online banking/mobile banking. We may send you text messages in limited circumstances for example, if we are required to do so for regulatory reasons.
There are additional services you can request to receive via text message alerts for example, daily balances, transaction alerts, mini statements. The availability of these services will depend on the type of account you have and you should refer to your product conditions for more information.
Push notifications allow us to directly send you a notification to your mobile device allowing you to verify your identity (authentication) and access the service. We may do this in the following circumstances:
- when you first register for online banking/mobile banking; and
- every time you initiate a banking process such as making a payment, or withdrawing funds.
Who receives your personal data?
In the course of the performance of our contractual, statutory, legal or regulatory obligations or if you have given your consent, your personal data may be provided to:
- various departments within the Cynergy Bank Group; and the Bank of Cyprus Group where we have a contractual requirement to do so following our separation from the Bank of Cyprus Group
- Supervisory and other regulatory and public authorities where a statutory obligation exists e.g.:
- the Financial Conduct Authority (FCA)
- the Prudential Regulation Authority (PRA)
- Bank of England
- the Financial Ombudsman Service (FOS)
- the Financial Services Compensation Scheme (FSCS)
- European Central Bank where we have a contractual requirement to do so following our separation from the Bank of Cyprus Group.
- Credit and financial institutions such as correspondent banks and the British Business Bank plc
- Share and stock investment and management companies
- Valuers and surveyors
- Non-performing loan management companies
- External legal firms
- Financial and business advisors
- Auditors and accountants
- Marketing companies (where you have provided consent) and market research companies
- Companies which help us to provide you with debit, cards such as Visa and process those payments
- Credit Reference Agencies and Fraud Prevention Agencies as explained above
- File storage companies, archiving and/or records management companies, cloud storage companies
- Companies who assist us with the effective provision of our services to you by offering technological expertise, solutions and support and facilitating payments
- Purchasing and procurement and website and advertising agencies
- Potential or actual purchasers and/or transferees and/or assignees and/or charges (including the Bank of England FLS) of any of the Bank's benefits, rights, title or interest under any agreement between the customer and the Bank, and their professional advisors, service providers, suppliers and financiers
- Debt Collection Agencies
All data processors appointed by us to process personal data on our behalf are bound by a contract imposing confidentiality and data protection obligations including compliance with the Data Protection Act 2018 or GDPR.
Transfer of your personal data to a third country or to an international organisation
Whilst we are based in the UK sometimes it's necessary to transfer information outside the UK. Data transferred within the European Economic Area (EEA) is protected by European data protection standards. Some countries outside the EEA do not have adequate protection for personal data under laws that apply. We will therefore make sure that adequate protection is in place before data is transferred in such circumstances.
Automated decision-making and Profiling
We may process some of your data automatically in limited circumstances, with the goal of assessing certain personal aspects (profiling), in order to enter into or perform a contract with you.
In the following cases, an individual review will be completed before a final decision is made:
- Data assessments (including on payment transactions) are carried out in the context of combating money laundering and fraud. An account may be detected as being used in a way that is unusual for you or your business. These measures may also serve to protect you.
- We use a detection system that computes a risk score and a decision. It may include (but not limited to) running algorithms and location (IP address), user behaviour metrics (comparing traits adopted by fraudsters or behavioural trends which do not match your usual activity), your network connection and checks against fraud & malware databases. If it is determined that there is a risk, you may be denied access to your online banking/mobile banking or asked to perform extra authentication, your account may also be frozen.
- Credit scoring is used as part of the assessment of your creditworthiness. This calculates whether you or your business will meet your payment obligations pursuant to a contract. This helps us make responsible lending decisions that are fair and informed.
Identity checks - a decision to process your application may be made without human involvement and based on technological means. This will occur where the photo on an identity document is compared with a ‘selfie’ to verify the person making the application is the owner of the identity document. See Identity Checks above for more information.
If you have provided consent and wish to withdraw it, you can do so but note that this may limit your ability to use our products and services and may result in the closure of your account(s).
Marketing activities and surveys
We may process your personal data to tell you about products, services and offers that may be of interest to you or your business but only if you have provided explicit consent to do so and only via the method(s) you have requested e.g. post, email etc.
The personal data that we process for this purpose consists of information you provide to us and data we collect and/or infer when you use our services, such as information on your transactions. We study all such information to form a view on what we think you may need or what may interest you.
You have the right to object at any time to the processing of your personal data for marketing purposes by contacting either in person or in writing or by calling 0345 850 5555 (+44 (0)20 3375 6422 from outside the UK). Calls may be recorded for monitoring and training.
Your right to object does not prohibit banks from providing information to their customers when requested or required by an industry regulator, such as under the FCA. This is true even where customers have previously ‘opted out’ of direct marketing. For example, we will make our customers sitting on lower rate products aware of higher rate products that the Bank has that may better serve their financial objectives.
If you wish to unsubscribe from receiving surveys, you can click on the corresponding link contained within the survey invite you receive, or by calling us on the above number.
How long we keep your personal data for
Prospective Customers/New Applications
When you are applying for a product or service online, you may be able to save your application so that you can return to it as and when you wish. Where this function is available, if you are the primary applicant, we will hold your data for 14 days from the start of the application. If you do not complete your application within 14 days or you cancel it before submitting, all your data will be deleted. If you are an additional/joint applicant and requested to add your information, your data will be held for 14 days from the date we send you an email requesting this. If you do not submit your information within 14 days or you cancel it before submitting, all your data will be deleted.
In all other cases
We may keep your data for up to 10 years
- after your account closes
- after your application for a product or service is refused
- after you have submitted your application but decided not to proceed.
In limited circumstances we may keep your data for a shorter period for example, if you opened an individual savings account and did not fund it.
How long we keep your data is based on a mixture of our legal and regulatory obligations and limitation periods. The reasons for keeping your data are:
- To respond to queries or complaints or regulatory requests;
- Defend or take legal action;
- To maintain records according to any rules that apply to us; and
- For research and statistical purposes to ensure we continue to make informed lending decisions and understand the performance of our savings products.
We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons.
Retention periods may be changed from time to time based on business or legal and regulatory requirements and we keep these under review annually.
Your data protection rights
With regards to your personal data, you can:
- ask to have access to it (Data Subject Access Requests) - for more information, please go on our FAQs and use the drop down for GDPR: The General Data Protection Regulation. You can also obtain the Data Subject Access Request form on our website.
- ask us to correct it (rectification) – for example if we hold incomplete or inaccurate data.
- ask us to delete it – also known as the ‘right to be forgotten'. Please note however that this right does not take precedence over our obligations as a regulated business to retain your data in certain circumstances.
- object to us processing it - if you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms. If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.
- Restrict how we use it - if:
- it is not accurate,
- it has been used unlawfully but you do not wish for us to delete it,
- it is not relevant anymore, but you want us to keep it for use in possible legal claims,
- you have already asked us to stop using your personal data but you are waiting us to confirm if we have legitimate grounds to use your data.
- ask us to provide your data (data portability) in a format that is structured and commonly used and transmit such data to other organisations. You also have the right to have your personal data transmitted directly by ourselves to other organisations you will name.
- tell us you withdraw your consent to us processing your data at any time. Note that any withdrawal of consent shall not affect the lawfulness of processing based on consent before it was withdrawn or revoked by you.
Right to lodge a complaint
If you have exercised any or all of your data protection rights and still feel that your concerns about how we use your personal data have not been adequately addressed by us, you have the right to complain by contacting us. You also have the right to complain to the Information Commissioner's Office. Find out on their website how to submit a complaint at https://ico.org.uk/.
Frequently asked questions
To help you understand the basic principles of data privacy law and address some of the common questions that arise with regard to the protection of your personal data, please refer to the Frequently Asked Questions.
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