Privacy Regulations
Through these Privacy Regulations, SNS Property Finance aims to provide clarity on how it uses your personal data. SNS Property Finance is part of SNS REAAL. SNS Property Finance assigned SNS REAAL as the party responsible for the processing of its clients’ personal data.

Our privacy policy
We respect the privacy of the visitors to our website. Personal data are processed in accordance with the Dutch Personal Data Protection Act (‘WBP’) and the Code of Conduct for the Processing of Personal Data by Financial Institutions (‘Code of Conduct’). The Code of Conduct fleshes out the WBP specifically for banks and insurers. The Code of Conduct can be downloaded at the website of the Netherlands Bankers’ Association (www.nvb.nl, under ‘Infobalie/regelingen’).

SNS REAAL has reported its processing of personal data to the Dutch Data Protection Authority (‘CBP’). These reports are included in the public register of the CBP; see www.cbpweb.nl.

What are the reasons for processing these data?
Upon the request (whether or not through a consultant) for a financial product and/or financial service, you are asked to state your personal data and any other data. SNS Property Finance, or any legal entities that are part of SNS REAAL*, uses these data to process your request, conclude and perform agreements with regard to financial products and/or financial services, and statutory regulations. Your data may also be used for other activities that support business operations to prevent fraud, perform statistical analyses and inform you about other products and services. You, as a client of SNS Property Finance, are therefore also considered a client of the other SNS REAAL business units listed below.

* The following business units are currently part of SNS REAAL: SNS Bank N.V. (also operating under the name of SNS Fundcoach), SNS Regio Bank N.V., ASN Bank N.V., BLG Hypotheekbank N.V., SNS Property Finance B.V., SNS Asset Management N.V., SNS Securities N.V., REAAL Verzekeringen N.V., REAAL Levensverzekeringen N.V., REAAL Schadeverzekeringen N.V.,  Proteq Levensverzekeringen N.V., Proteq Schadeverzekeringen N.V., Route Mobiel B.V., SNS Assuradeuren B.V., SNS Assurantiën B.V., SNS Verzekeringen N.V., Zwitserleven N.V.

Your data will not be sold or rented or otherwise provided to third parties, unless:
1. these third parties are engaged for the processing of your request and/or the conclusion and performance of agreements;
2. this is necessary to protect your and/or our rights;
3. we are required to do so by law; and
4. you have given permission for your personal data to be sold, rented or otherwise provided to third parties.
Please note that your data can be collected by the US authorities within the context of the prevention of terrorism if you make international payments using the SWIFT banking network.

Processing specific data
We sometimes require specific data from you due to the nature of our services. This may include data regarding your health upon your request for certain financial products and/or financial services. If we also need information from a GP, we will always first ask your permission. We are then required to inform you why we need this information and which specific data it is we need.

Another example concerns data about criminal offences. Some agreements may require you to provide information on your criminal record, if you have any. In that event, we will only ask for information on your criminal record relating to the past eight years prior to your request for a financial product and/or financial service.

Recording communications
We record certain communication to verify and inquire into instructions and transactions, for example, upon the sale or purchase of securities. In addition, we record communication if this is considered necessary with a view to the prevention of fraud, or for training, coaching and/or assessing our personnel. You, as a client, are entitled to listen to or receive a transcription of the recorded conversation, if possible. The records and transcriptions are not retained longer than is strictly necessary for the above purposes.

Consulting the Stichting CIS database
In connection with a responsible acceptance policy with regard to insurance, your data may be requested from Stichting CIS in Zeist, the Netherlands. In this context, members of Stichting CIS can also exchange data in order to control risks and prevent fraud. That is why the privacy regulations of Stichting CIS (‘FISH Protocol’) are also applicable. See www.stichtingcis.nl.

Using this website
We have taken appropriate measures to secure your visit to and the use of our website and to prevent abuse. All persons who can access your data are bound by an obligation to observe confidentiality.

If you visit our website to obtain information, visitors’ data can be collected and saved in order to improve the website’s user friendliness.

Cookies and web beacons
It is also possible that small text files (‘cookies’) are sent to your computer and stored there to facilitate the communication through the electronic communication network, for example, to ensure that you only need to log on once. The cookie’s purpose in this example is to tell the server that you have returned to that web page. If you never register and do not leave any personal data on that website, the server only knows that someone with that specific cookie has returned to the website. It facilitates your use of this website and allows us to collect (anonymised) data regarding the visit to this website. We can determine which data are important to our visitors, and which ones are not. We can remove web pages you do not use and direct our attention to information you need.

In addition, we use an external advertising technology to gain insight into visitors’ behaviour on our website. The purpose of using this technology is to gain insight into the effectiveness of internet advertisements on our website and third-party websites.

To this end, we use web beacons and cookies that are supplied by a third party and placed by us on our website. In both cases, the information that is collected and tracked through this technology is not personally identifiable. The web beacons are aimed at determining from which external website you came to our website and whether this leads to a successful use of our website. Based on these data, the effectiveness of our internet advertisements on other websites can be determined. The cookies are aimed at registering certain actions and transactions by you as a visitor to our website. Based on these data, specific profiles can be assigned. If you then arrive at a website within the network of the third party referred to above, you can be shown an advertisement based on the assigned profile. In both cases, we pass on information on visitors’ website use to the servers of that third party. As stated above, this information is not personally identifiable.

You can instruct your browser to accept all cookies or to warn you when a cookie is being offered. You can then determine whether or not to accept the cookie. See below the instructions per browser:

Internet Explorer: http://support.microsoft.com/gp/cookies/nl
Firefox:  http://support.mozilla.com/nl/kb/cookies-nl#Cookieregels_instellen
Opera: http://www.opera.com/support/kb/view/350/ (Engelstalig)
Safari: http://docs.info.apple.com/article.html?path=Safari/3.0/nl/9277.html
Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=nl&answer=95647

Hyperlinks
Our website may contain hyperlinks to other websites. We do check the connection to these websites, but we cannot be held responsible for the content and privacy aspects of these websites. These Privacy Regulations do not relate to websites for which a hyperlink has been provided.

Inspecting, correcting and changing personal data
You are entitled to ask which information we are processing about you. We must then provide you with an overview of your data within four weeks. You can ask SNS Property Finance for information by contacting the Corporate Legal Department via P.O. Box 390, 3830 AK Leusden, The Netherlands. We may charge a fee for this request.

If you are of the opinion that the personal data relating to you are incorrect, incomplete or irrelevant to the purpose for which they have been collected or are otherwise in contravention of a statutory rule, you are entitled to ask us to correct, supplement, remove or secure the personal data relating to you. In that case, please contact the Corporate Legal Department via P.O. Box 390, 3830 AK Leusden, The Netherlands.

New developments
We may amend the text of these Privacy Regulations in view of new developments, for example, in the context of changing business operations. It is therefore recommended that you regularly check this text if you are visiting this website.

Questions?
If you have any questions regarding these Privacy Regulations, please contact the Corporate Legal Department via P.O. Box 390, 3830 AK Leusden, The Netherlands.