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SpareBank 1 also has a cooperation agreement with LOfavør AS that allows us to offer certain benefits to members of unions affiliated to the Norwegian Federation of Trade Unions, which is also a customer of SpareBank 1.
In some circumstances, certain companies within the SpareBank 1 alliance will cooperate in deciding how your personal data will be processed. In these circumstances there will be a so-called joint controllership between these parties. Joint controllership means that the companies decide together which of your information is to be collected and how your personal data will be processed.
Regardless of the joint controllership, you will be able to enforce your privacy rights by contacting the bank or the company you are affiliated with.
Below you will find information on your rights when we process personal data about you.
Information about your products, agreements, contact information and transaction history are available in your online bank. If you cannot find the information you are looking for, please send us a request for access. We may ask you to clarify to what information or processing activities you want to access. If you do not have an online bank or cannot read digital documents for some other reason, we can send you the information on paper.
There are exceptions to the right of access in certain circumstances. This typically applies when we are legally bound to secrecy or when we have to keep the information confidential for the prevention, investigation, detection and prosecution of criminal acts. Another exception is when the information is contained only in documents prepared for internal case processing and exemption from access is necessary to ensure proper processing.
It is important that the information we have about you is correct. SpareBank 1 checks its data against the Norwegian Population Register and other sources. In addition, we ask you at regular intervals in online banking and mobile banking to confirm that the information we have registered about you is correct. If you believe that the information we hold about you is incorrect or incomplete, you have the right to request that the information be corrected or updated.
You may demand that SpareBank 1 restrict the processing of your personal data in certain situations, for example, if
you believe that the personal data is incorrect or that the processing is not lawful
SpareBank 1 wants to delete data, but you need the information because of a legal requirement
you have lodged an objection to the processing and it is based on a balance of interests
We will still store the relevant information, but all other processing of the personal data will be temporarily suspended. SpareBank 1 may begin processing your personal data again in connection with legal requirements or to protect another person’s rights.
You have the right to recieve a copy of the personal data that you have given us in a machine-readable format. Unlike to the right of access, this right applies only to personal data that you have personally provided to us and that is processed based on your consent or agreement.
You have the right to demand that SpareBank 1 stop processing personal data about you based on its legitimate interests, unless there are compelling legitimate grounds that override your interests, or the processing is for the establishment, exercise or defence of legal claims. You may also demand that SpareBank 1 stop processing your personal data for direct marketing purposes, including profiling related to such purposes.
Email is not considered as a secure channel, so please do not send us confidential information via email. We will answer you as quickly as possible and no later than within 30 days. If we see that the processing time will be longer than 30 days, we will let you know.
You can also contact us to withdraw or modify your consent.
The personal data we collect
Personal data includes information and assessments that can be linked directly or indirectly to you as an individual. The various banks and companies in SpareBank 1 process different types of personal data about you depending on your relationship with them and the products and services you have purchased.
Identification and personal information such as name, national identity number, nationality, other identification numbers issued by the government and copies of identification documents.
Contact details such as phone number, address and email address.
Financial information such as customer and product agreements, credit history, revenue information, payment card number and transaction data.
Information required to fulfil regulatory obligations such as tax country, foreign tax registration number, information in connection with financial advice, information related to anti-money laundering work and reporting to public authorities.
Specific categories of personal data such as health information and trade-union membership when you buy insurance cover or enter into an agreement with LOfavør AS.
Information on income, debt, place of work and employment, education, marital status, family relations and dependent responsibilities.
Photos and video recordings taken in connection with our customer and sponsorship events.
As a general rule, the personal data and information we register about you will be obtained directly from you as a customer, for example when you create an account, apply for a loan or when we talk to you via digital channels and chat services. If a guardian has been appointed for you, we will also collect information about your guardian.
From third parties
We collect information about you from others in order to provide services to you, to comply with legal requirements and to quality assure information you have provided to us. Examples of information collected from third parties such as publicly available sources/registers or private business sources may include:
Identity information, family relations, demographic information and mortgage data from the National Population Register, Property Register or the Register of Motor Vehicles. When you apply for a loan as a customer, we collect credit and debt information about you from the debt registers and the credit reference agency Dun & Bradstreet.
When executing payment transactions, we collect information from senders (payers or recipients), shops, banks, payment service providers (such as Vipps and PayPal), invoice issuers (such as TietoEvry and Nets) and others.
In order to carry out customer checks pursuant to the money laundering and financial contract regulations, we collect information from other public authorities such as the tax authorities, Brønnøysund Register Centre and police. We also collect information from sanction lists published by the Norwegian authorities and international organisations such as the EU, the UN and the Office of Foreign Assets Control (OFAC).
In connection with the registration of customer relationships for self-employed individuals, banks are required by law to collect information about the key people and beneficial owners of a company. The information is collected from the Brønnøysund Register Centre and commercial information services that provide information about, for example, beneficial owners and politically exposed persons.
With your consent, your bank can, in line with the Payment Services Directive, share account and transaction information with other banks or financial institutions. This means, for example, that you can view your accounts with other banks in our mobile bank and vice versa, and that you make payments from these.
Mobile applications and access rights
Our mobile apps sometimes need access to functions and information on your phone. The apps only ask for the access required to enable them to work. We cannot view the data on your phone. You can read more about the access rights the apps request in the various apps.
Your personal data is mainly processed for the purposes of customer management, financial advice, billing and the performance of banking, insurance and financial services in line with the agreements we have entered into with you. When new agreements are entered into with you, you will always be made aware of the terms and conditions that apply in relation to the agreement.
We may use your personal data if this is necessary to address a legitimate interest that overrides your right to privacy. The legitimate interest must be legal, pre-defined, genuine and objectively justified in relation to our business activities.
Examples of procession based on legitimate interest:
Marketing, product and customer analytics. The analyses provide the basis for marketing, process, business and systems development. The purpose is both to improve our solutions and to provide the best possible offers, products and services to our customers.
Profiling, for example, when we conduct customer analyses for marketing purposes or monitor transactions to detect fraud and other criminal acts.
Transaction classification of your expenses and earnings into categories to provide you with a better overview and understanding of your personal finances.
Automatic transfer to your SpareBank 1 bank when you log into your mobile bank, so you do not have to specify your bank affiliation every time you log in.
The development of machine learning models in order to better identify suspicious transactions in connection with banks’ statutory anti-money laundering work.
Identifying your subscriptions or other recurring expenses that we can help you cancel.
When we process personal data about you on the basis of our legitimate interests, you can object to the processing. Read more about the right to object under Your rights.
In some circumstances, we will ask for your consent to process personal data. Any consent given by you as a customer must be voluntary, explicit and informed. Consent provides one of the bases for processing if we need to process special categories of personal data (e.g. health information and trade union information).
If you have provided consents to SpareBank 1, you can withdraw them at any time. If you withdraw your consent, the processing will stop, and the personal data related to the consent will be deleted.
Your information is primarily processed for customer management purposes and to fulfil our obligations to you. We also process your personal data to provide you with information and offers, as well as to fulfil our legal obligations.
We will process your personal data to fulfil the obligations we have assumed in relation to the performance of assignments and service agreements entered into with you. In order to, for example, send you invoices, execute payment transactions on your accounts and respond to inquiries from you, we need to process your personal data.
We want to be available to our customers both digitally and in person. Therefore, you can contact us via chat, email, letter, phone and other channels. We can also conduct digital meetings with you when you have agreed this with one of our customer advisers.
If you start a chat from the bank’s website without being logged in to online banking, the call is anonymous. The chat is archived for the purposes of statistics and evaluating customer service, but it cannot be linked to you as a customer. Chats are retained for a period of one year.
If during a chat you choose to talk to an adviser, the chat conversation will be made available to that adviser. The purpose is to enable them to familiarise themselves with your enquiry before the chat continues.
If you start a chat when you are logged in to your online bank, it will be saved and linked to you as a customer. We do this in order to provide you with the best possible customer service when you are in subsequent contact with the bank, and as documentation in the event a dispute should arise.
If you contact us via social media (e.g. Facebook), one of our customer advisers will be able to contact you. However, if you need to share personal information, please still use one of the secure channels on our website.
When we provide investment services, we are required by law to make audio recordings and retain calls, meetings and other customer communications. In the case of in-person advice meetings, we must keep minutes of the meetings. Such documentation is retained for at least five years to document the investment services we provide.
Audio recordings of phone calls
We may occasionally record phone calls made to and from our call centre. You will be informed about this before the call starts, so that you can opt out of being recorded. The recording will be used only if you or we need to document the content of the conversation. To document notification of lost cards, we make audio recordings when the loss is reported over the phone. The audio recording is retained for 18 months.
In some cases, we want to record phone calls for training purposes. Before the call starts, you will be notified of this and be given the option of opting out of being recorded. You can request access to audio recordings by contacting the bank. You must specify at what time the call took place and from what phone number when you request access.
SpareBank 1 wants to provide our customers with information about products within the product categories for which there is already a contractual relationship with the bank and/or the individual company. In these circumstances, the bank/company will use neutral personal data such as your name, contact details, date of birth and the services or products for which the customer has already entered into an agreement.
Our products are divided into the following categories:
Savings and deposit products
Loans and other credits
With the aid of personal data and interest and user group profiles, we personalise communication, advice and offers so that they are relevant and useful. The information about you may also be used in analyses and customer surveys to develop and improve products and services and enhance customer service. Analyses for marketing purposes that include transaction data will only be performed if you have explicitly consented to this in your mobile bank or online bank.
You may also see ads from us on social media and other web pages when we buy ad space through various media.
Other channels: Newsletters, email and customer surveys
If you have opted out of marketing in the Reservation Register in Brønnøysund, we will of course respect this decision.
By using Facebook image pixel on SpareBank 1’s website, we can deliver personalised content from SpareBank 1 in Facebook’s channels. This content will be more targeted and relevant to the user. Facebook Pixel collects information about your activity.
We use Adform to keep track of the ads that should be displayed, to count the number of views, clicks etc. This is done on an anonymous basis and cannot be traced back to individuals. This is the system in which our marketing materials are located, and the information we collect is used to deliver personalised content and provide relevant ads on external websites, such as online newspapers.
Google Ads and Adobe Advertising Cloud Search
In Google Ads and through Adobe Advertising Cloud Search, we keep track of the ads that are to be displayed, count the number of displays and clicks, and see if any action is taken based on your ads. The information we collect is used to deliver personalised content and to provide relevant ads. We cannot link customer data to the ad placement.
Appnexus script, programmatic buying
Programmatic media advertising is automated buying and selling of online ads through an ad exchange. The online newspapers put ad slots (displays) up for sale on the ad exchange, and as an advertiser, we place bids for what we want to pay. Using the script, we can set criteria to be used in the bidding and optimise the advertisements.
SpareBank 1 uses various social media sites such as Facebook, Instagram, YouTube, Twitter, LinkedIn and Snapchat in order to be available to our customers. In these channels, we share useful information and relevant stories and updates about SpareBank 1 in local communities.
None of the information you provide to us via social media, such as reactions and comments on our posts, is stored by us. It is stored by the social media site of which our page is a part. You can delete information you have provided at any time, for example if you delete comments you have posted. Please note that the information will not be deleted if you simply stop following our page.
We process personal data in connection with market and customer satisfaction surveys. For example, after you have been in touch with us, we ask you to tell us how you experienced the contact. Your feedback helps us to provide you with even better products and services. We can also measure the effectiveness of improvement measures and look at the link between customer satisfaction and customer behaviour over time.
If you do not want to share this type of information with us, you can decide not to respond to the survey we sent you.
We use certain personal data to assess risk in the connection with the sale of products and services. This provides you, the customer, with the confidence that your assets will be well taken care of.
In accordance with the provisions of the Financial Institutions Act, the Securities Trading Act and the CRR/CRD IV Regulations, we will process credit information, application information and other information about you in order to calculate our capital requirements for credit risk. Such processing is also carried out in connection with the establishment of your customer relationship and when ascertaining which services and products are suitable for you.
Calculations are made using our own models, procedures and decision-making processes for lending, credit management and control mechanisms, IT systems, and internal policies related to classifying and quantifying the institution’s credit risk and other relevant risks. In connection with this, personal data may be collected from credit reference agencies. Information can also be retrieved from Norwegian debt registers for the purpose of developing models for risk assessments and formulating individual credit policy rules.
Rules pursuant to the Financial Institutions Act, the Securities Trading Act and the CRR/CRD IV Regulations mean that institutions must share customer information in order to fulfil the institution’s governance, control and reporting requirements. This particularly applies in the case of information related exposures in default.
We process personal data to prevent, detect, clear up and deal with fraud and other criminal acts against you, other customers or us.
We will also process personal data to prevent and detect transactions related to proceeds from criminal acts or in conjunction with terrorist financing. We do this because we are required to investigate and report suspicious transactions under the Anti-Money Laundering Act, as well as to carry out identification checks on all our customers.
Under the Anti-Money Laundering Act, we are also required to report suspicious information and transactions to the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime (Økokrim) and the Financial Intelligence Unit Norway (EFE). The information will be retrieved from, and may be disclosed to, other banks and financial institutions, the police and other public authorities.
SpareBank 1 implements technical and organisational security measures to protect your personal data. SpareBank 1 constantly works to ensure that your personal data is protected from loss, misuse, inadvertent access, disclosure, alteration or destruction. This is done through access management, logging, encryption, firewalls, access control and CCTV monitoring, as well as other measures that support your security and security at SpareBank 1. We have a dedicated management system for information security, access control, nonconformance management and training.
SpareBank 1 has CCTV surveillance and in our premises and for our ATMs. Recordings are deleted after 90 days unless they are turned over to the police or the bank has the right to use the recordings for other purposes.
Your activity in your online bank and mobile bank is logged in order to track what changes have been made and by whom, for example, if there is a systems error or a breach of security occurs. Similar logging takes place in our internal systems where we process your personal data. SpareBank 1 has a legitimate interest in logging this traffic in order to identify or prevent potential unwanted activity in or against the bank. The scope of such logging is limited to the minimum amount strictly necessary and proportionate to ensure online and information security.
It is your responsibility as a customer to choose the log in solution (PIN code or biometrics) that you want to use.
SpareBank 1 is constantly working to improve its systems, services and products. To address personal data security and ensure that our solutions are working properly, we need to be able to use data for testing and development purposes. The general rule is that only fictitious or anonymised data should be used, although sometimes we need to use real customer data to ensure functionality and security.
Basis for processing: To offer our customers good solutions, we need to be able to develop and test new solutions before they are put into production. We consider this processing to be very closely related to our original purpose of delivering products and service to our customers. We have documented this via a so-called compatibility assessment.
SpareBank 1 process personal data to provide statistics for public enterprises and private companies. The statistics we share with these enterprises and companies will be aggregated data that cannot be linked to you as an individual person (anonymised). For example, the statistics will be based on demographic information, product information and transaction information. The enterprises and companies can only use the statistics to improve goods, services, communication and offers to consumers.
Examples of statistics can include what times most people visit supermarkets, how many customers live in a detached house or what average citizens in a municipality spend on electricity, phone subscriptions or food.
In some cases, we use automated decisions to assess whether we should enter into or perform an agreement with you, such as when you buy loan products or receive advice via the bank's website.
Automated decisions are decisions made exclusively by computer programmes without human intervention or influence. If automated decisions will have legal implications for you or otherwise significantly affect you, we may use them only if
it is necessary to enter into or perform an agreement with you
you have consented to it
We will tell you if an automated decision has been made. You can also ask to have an automated decision reviewed by an account officer, ask for a decision to be explained or contest a decision.
Profiling is a form of automated processing of your personal data. We use profiling and data modelling to, for example, provide you with specific services and products that match your preferences, to prevent money laundering, to set prices for certain services and products, to uncover fraud and risk of fraud, to assess the likelihood of default, to estimate the value of assets, and to serve marketing purposes. You have the right to object to such profiling.
Sometimes we share information about you with others who have the right to use it, such as government agencies, payment service providers, or companies in the SpareBank 1 Alliance. This may be done to fulfil our agreement with you, to meet legal obligations or to protect our legitimate interests. Before sharing personal data, we always ensure that we comply with the relevant confidentiality provisions applicable in SpareBank 1 as a financial institution.
The banks and companies in SpareBank 1 have a duty of confidentiality regarding customer information. As a general rule, this duty of confidentiality also applies between the companies within SpareBank 1. Nevertheless, companies in SpareBank 1 may disclose certain personal data to each other where permitted by law. This could be
your contact details
your date of birth
information about the SpareBank 1 company in which you are a customer and the services and products you have entered into an agreement to receive
If you would like more relevant advice and offers from us, you can give your consent that the enterprises in SpareBank 1 may share more information about you.
In many instances, SpareBank 1 has a statutory duty to disclose personal data to public authorities. Examples of this may include disclosures to tax authorities, the Norwegian Labour and Welfare Administration (NAV), the courts, the police, supervisory authorities, the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime (Økokrim) and public tribunals. Registered personal data will only be disclosed to public authorities and other third parties when this is required by a statutory duty of disclosure or right to disclose.
Pursuant to the law, personal data may be disclosed to other banks, insurance companies, financial institutions and partners. Examples of this might be if you want to view account information in one bank via a different bank or if you want to view your insurance cover from Fremtind in your mobile bank.
In the event of payments to or from abroad, we will provide pertinent personal data to the foreign bank. The laws of the recipient country determine the extent to which the information is disclosed to government agencies or regulatory bodies. This might be done to comply with the recipient country’s tax laws, measures against money laundering or terrorist financing.
If you default on your credit agreements, the information may be disclosed to a debt collection company for the purpose of collecting the defaulted claim on behalf of the creditor. The claim may also be sold to a debt collection company which then takes over as creditor for the claim.
Norway has entered into agreements with several countries on mutual tax reporting to combat tax evasion and international tax crime. The agreements are often referred to as the Common Reporting Standard (CRS) and The Foreign Account Tax Compliance Act (FACTA). Under the agreement, Norwegian financial institutions are required to identify and report persons, companies and other entities that reside or are domiciled abroad to the Norwegian tax authorities. For more information about CRS and FATCA, consult the Norwegian Tax Administration.
SpareBank 1 uses third parties to deliver services to you as a customer. If these third parties process your personal data, they are acting as our processors. For example, SpareBank 1 uses a number of cloud services to deliver well-functioning services to you as a customer.
SpareBank 1 enters into data processing agreements with all of the companies that process personal data on our behalf. These agreements govern how a data processor can use the personal data to which they gain access. SpareBank 1 will only use processors that guarantee they will comply with the Personal Data Act and GDPR.
SpareBank 1 currently uses different types of processors, such as:
SpareBank 1 Utvikling – our own IT and development company, which provides services to the entire SpareBank 1 Alliance.
Amazon (AWS) – a platform we use to build the digital bank, the financial platform, etc.
TietoEvry – one of SpareBank 1’s largest third-party providers of core banking and other payment systems.
Microsoft—for example, for Teams meetings with you or general email correspondence.
SpareBank 1 primarily wants to use processors based in the EU/EEA. If SpareBank 1 uses providers outside the EU/EEA, we will ensure that the following conditions are met to ensure that the privacy and rights of our customers are properly protected:
There is an approved transfer basis for the delivery of personal data to a third country, such as the use of standard contracts (EU standard clauses) approved by the European Commission, the data processor has valid, binding corporate rules (BCR) or the European Commission has decided that there is an adequate level of protection in the relevant country.
The level of protection for the processing of personal data in a third country has been assessed as equivalent to the level of protection in the EU/EEA, as a result of specified technical and/or organisational measures.
How long do we retain your personal data?
We retain your personal data for as long as it is necessary for the purposes for which it was collected and processed, unless statutes or regulations require us to retain it for longer.
For as long as it is necessary
This means that, as a general rule, we retain your personal data for as long as it is necessary to fulfil an agreement you have entered into with us, or in compliance with the requirements for retention time in laws and regulations. After that, it is deleted or anonymised.
In cases where the retention of your personal data is based solely on your consent, and you withdraw your consent, we will delete the data as soon as possible.
Offer: up to six months after the customer has received the offer.
Documentation collected and prepared to prevent and detect money laundering and terrorist financing: 10 years after transaction has been completed or the customer relationship terminated.
Information we are required to keep under the Bookkeeping Act and Bookkeeping Regulation: up to 10 years.
Audio recordings of investment services: at least five years, and, if deemed necessary, up to 13 years.
Information collected for calculating regulatory capital requirements for credit risk (so-called internal rating-based approach): Up to 50 years (the information is stored separately with strict access controls).
Documentation and history related to the execution of an agreement: up to 13 years after the end of customer relationship (this corresponds to the period during which you may, on specific terms, make claims against us under your agreement, the so-called ‘period of limitation’).
Information collected from you in connection with a conversation about cancelling cards or your need for emergency funds if, for example, your wallet has been stolen: three years.
Backups of logs: Retained for as long as it is appropriate for the individual service (backup logs are stored separately with strict access controls).
Your data/information: Is available to customer advisers for two years after your customer relationship has ended. You have the right to object to this.
It is important to us that you feel safe when you visit our website, and at the same time confident that we are doing our best to provide you with what you need.
Cookies are small data files that are stored on your computer or your mobile phone by the browser or app you are using. A cookie belongs to a particular website and therefore cannot be read by other websites.
If you use our website without identifying yourself, the cookie consent will only apply to the device (e.g. mobile or PC) you are using at the time. When you log in to your online bank or mobile bank, you can choose to allow whether the response for the device should also apply to your entire customer relationship.
You can choose which categories of cookies we can use.
SpareBank 1 may collect information about you that is used to analyse how you as a customer use SpareBank 1’s services via digital channels and other communication channels. This information is also used to identify potential demand for new products and services, and to improve the functionality of existing products and services.
The following are examples of how we apply analysis:
To determine price levels.
To assess and monitor credit risk.
To personally adapt our web pages.
To prevent and detect fraud.
To analyse website traffic and use of email and text messaging.
We need to use technical cookies to make the websites work. Therefore, these cannot be turned off.
We use functional cookies so you do not have to make the same choices every time you are on our websites. These store information about your use of the websites and the settings you have selected in order to personalise the functionality for you.
Cookies that archive statistics
Cookies for targeted marketing
In addition to cookies, we use pixels and scripts from third parties. These are snippets of code that allow us to analyse your usage across social media and our channels, and we use this to provide you with more relevant marketing.
You can choose which categories of cookies we can use.
Necessary adjustments and clarifications in line with the development of our services, products and websites, as well as judicial changes in privacy.
29 August 2023
Necessary adjustments and clarifications in line with the development of our services, products and websites.
28 March 2023
Necessary adjustments and clarifications in the section regarding cookies.
17th June 2022
Necessary adjustments and clarifications in line with the development of our services, products and websites.
8th March 2021
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