CaixaBank and the companies that we indicate below (within each of the processing operations) are joint controllers of your data in compliance with regulations applicable to CaixaBank Group companies: (i) anti-money laundering and terrorist financing regulations; (ii) tax regulations; (iii) obligations arising from sanctions policies and international financial countermeasures.
In accordance with the provisions of the applicable regulations, the Joint Controllers have signed a joint controller agreement for certain processing activities, the essential elements on the following principles:
(i) For certain processing activities identified in the Privacy Policy, the Joint Controllers will act in a coordinated or joint manner.
(ii) All suitable technical and organisational measures have been determined to ensure a level of security that corresponds with the risk inherent to processing the personal data subject to joint processing.
(iii) There is a single point of contact for data subjects to exercise their rights, assuming the duty of cooperation and assistance where appropriate.
(iv) They comply with the duty of secrecy and the requirement to keep confidential personal data which is processed through informed data processing activities.
(v) Regardless of the terms of the joint controller agreement, the data subjects can exercise their data protection rights by contacting any of the joint controllers.
The legal basis of this processing is the requirement to comply with a legal obligation that is required of us, as laid out in Article 6.1.c) of the General Data Protection Regulation (GDPR).
Therefore, it is necessary for you to establish and maintain Contractual Relations with us. If you object to it, we will need to end these relations, or we cannot establish them if they have not yet started.
The types of processing required to satisfy the regulatory requirements are listed below, arranged from (A) to (C). For each item, we will indicate: a description of the purpose (Purpose), the type of processed data (Type of processed data), if applicable, information on the use of profiles (Use of profiles), other relevant processing information (Other relevant information) and the joint controllers (Joint Data Controllers/Data Controllers).
Processing to comply with anti-money laundering and terrorist financing regulations
Purpose: The purpose of this processing is to adopt the measures imposed on our activity by Law 10/2010, on the Prevention of Money Laundering and Terrorist Financing.
The processing operations that are carried out to comply with anti-money laundering and terrorist financing regulations are:
- Collecting information and documentation that allows customers to comply with due diligence and knowledge measures;
- Checking the information that you provide us;
- Checking if you hold or have held a position of public trust;
- Categorising your risk level, based on which the various due diligence measures will be applied in accordance with Prevention of Money Laundering and Financing of Terrorism regulations;
- Analysing the transactions executed through CaixaBank, in accordance with legal obligations;
- Checking your relationship with companies and, if necessary, your controlling position within their ownership structure, and;
- Reporting and updating your information monthly in the Financial Ownership File, managed by the Executive Service of the Commission to Prevent Money Laundering and Financial Crimes (SEPBLAC).
Types of data processed: The types of data we will process for this purpose (the content of which is detailed in heading 5) are:
- Identification and contact details
- Details of your professional or work activity and socio-economic information
- Contract details
- Basic financial data
- Third-party data from statements and receipts of instant accounts and payment accounts
- Data on communications maintained with you
- Data obtained from the execution of statistical models
- Details of directors, functional officers and corporate relationships
- Data from the General Treasury of the National Social Security Institute
- Information obtained from public access sources and public records
Use of profiling: This processing involves creating a profile that we use exclusively for adopting the necessary measures in accordance with the provisions of Law 10/2010 on the Prevention of Money Laundering and the Financing of Terrorism.
- Purpose: The purpose of the profile is to prevent the contracting of operations susceptible to money laundering or the financing of terrorism.
- Consequences: Profiles are tools that help money laundering and terrorist financing prevention units determine whether operations are likely to be subject to money laundering or terrorist financing and, therefore, whether to accept or decline them.
Data controllers: The following CaixaBank Group companies will process your data jointly.
- CaixaBank, S.A.
- CaixaBank Payments & Consumer, E.F.C., E.P., S.A.U.
- VidaCaixa SA de Seguros y Reaseguros
- BPI Vida e Pensões – Companhia de Seguros, S.A.
- Nuevo Micro Bank, S.A.U.
- CaixaBank Asset Management SGIIC, S.A.U
- Telefónica Consumer Finance, E.F.C., S.A.
- Buildingcenter, S.A.U.
- Livingcenter Activos Inmobiliarios, S.A.U.
- Unión de Crédito para la Financiación Mobiliaria e Inmobiliaria, CREDIFIMO, E.F.C., S.A.U.
- Corporación Hipotecaria Mutual, S.A.U., Establecimiento Financiero de Crédito
- CaixaBank Wealth Management Luxembourg, S.A.
- CaixaBank Asset Management Luxembourg, S.A.
- BPI Gestão de Ativos, SGOIC, S.A.
- Banco BPI, S.A.
- Bankia Habitat, S.L.U.
- Puerto Triana, S.A.U.
B. Processing to comply with tax regulations
Purpose: The purpose of this processing is to adopt the measures imposed on our activity by Law 58/2003, of 17 December, the General Tax Law, Royal Decree 1021/2015, of 13 November, establishing the obligation to identify the tax residence of persons who own or control certain financial accounts and to report on them in the field of mutual assistance, and other current tax regulations.
The processing operations carried out to comply with tax regulations are:
- Collection of information and documentation regarding your tax situation as required by tax laws, and;
- Reporting to government agencies details relating to your tax situation when required by law or by the authority.
Types of data processed: The types of data we will process for this purpose (the content of which is detailed in heading 5) are:
- Identification and contact details
- Details of your professional or work activity and socio-economic information
- Contract details
- Basic financial data
Data controllers: The following CaixaBank Group companies will process your data jointly:
- CaixaBank, S.A.
- VidaCaixa SA de Seguros y Reaseguros
- Nuevo Micro Bank, S.A.U.
- CaixaBank Asset Management SGIIC, S.A.U
- Bankia Mediación, OBSV
C. Processing to comply with obligations arising from sanctions policies and international financial countermeasures
Purpose: The purpose of this processing is to adopt the measures imposed on our activity by the international financial sanctions and countermeasures programmes adopted by the European Union and the Kingdom of Spain.
In accordance with international financial sanctions and countermeasures, we will check if you appear in lists of data on people or entities included in laws, regulations, guidelines, resolutions, programmes or restrictive measures regarding international economic and financial sanctions imposed by the United Nations, European Union, Spain, the Office of Financial Sanctions Implementation (OFSI) of Her Majesty's Treasury (HTM) of the United Kingdom and/or the US Department of the Treasury's Office of Foreign Assets Control (OFAC).
Types of data processed: The types of data we will process for this purpose (the content of which is detailed in heading 5) are:
- Identification and contact details
- Data relating to international sanctions
Data controllers: The following CaixaBank Group companies will process your data jointly:
- CaixaBank, S.A.
- CaixaBank Payments & Consumer, E.F.C., E.P., S.A.U.
- VidaCaixa SA de Seguros y Reaseguros
- Nuevo Micro Bank, S.A.U.
- CaixaBank Asset Management SGIIC, S.A.U
- Telefónica Consumer Finance, E.F.C., S.A.
- Buildingcenter, S.A.U.
- Livingcenter Activos Inmobiliarios, S.A.U.
- Unión de Crédito para la Financiación Mobiliaria e Inmobiliaria, CREDIFIMO, E.F.C., S.A.U.
- Corporación Hipotecaria Mutual, S.A.U., Establecimiento Financiero de Crédito
- Banco BPI, S.A.
- CaixaBank Wealth Management Luxembourg, S.A.
- Bankia Habitat, S.L.U.
- Caixabank Equipment Finance, S.A.
- Puerto Triana, S.A.U.