RwS online privacy policy

Protection of personal data

Notice on the procedure for processing personal data and the rights of personal data subjects

Dear clients, counterparties, shareholders (participants) of JSC "RVS BANK" (hereinafter - the Bank), their managers, founders/participants/owners, representatives and other natural persons (including natural persons-entrepreneurs) with whom the Bank has business relations.

In accordance with Part 2 of Article 12 of the Law of Ukraine "On the Protection of Personal Data" dated June 1, 2010 No. 2297-VI, we inform you that the owner of the personal data provided by you is "RVS BANK" JOINT-STOCK COMPANY, code under EDRPOU 39849797, with location: 04071 , Ukraine, Kyiv, str. Vvedenska, building 29/58.
The Bank ensures the processing and protection of personal data in compliance with the requirements of the Constitution of Ukraine, the Law of Ukraine "On the Protection of Personal Data", other acts of Ukrainian legislation.

In the Bank's activities, personal data processing procedures are applied, which take into account the requirements of the Law of Ukraine "On the Protection of Personal Data". The right to access and process personal data is granted only to authorized employees, only after they have signed an obligation not to disclose information with limited access that was entrusted to them or that became known in connection with the performance of official duties. Authorized employees are allowed to process personal data in banking automation systems, subject to compliance with information security requirements for processing information with limited access. The Bank processes the personal data of its customers, counterparties, shareholders, employees, persons related to them, as well as other natural persons, the data of which is obtained by the Bank during the implementation of banking activities, the provision of financial services and the implementation of other activities by it in accordance with the legislation of Ukraine.

Purpose of personal data processing

The Bank processes personal data for the purpose of:

•    provision of financial services by the Bank and implementation of other activities in accordance with the Bank's charter and the legislation of Ukraine;
•   fulfillment of terms of contracts, general agreements that were/will be concluded by the Bank, implementation and protection of the rights of the parties under the concluded contracts;
•    ensuring the quality of banking services and the security of the Bank's activities,
•   compliance with the requirements of the legislation of Ukraine, internal documents of the Bank, collective agreement, decisions of state authorities and bodies supervising the activities of the Bank, court decisions, decisions of the Bank's management bodies;
•    management of personnel records;
•    establishment of business relations and contractual relations by the Bank;
•    establishment of correspondent relations by the Bank with other banks;
•    the Bank's protection of its legal rights and interests;
•    implementation of financial monitoring and fulfillment of FATCA requirements by the Bank;
•    implementation of other powers, functions and duties of the Bank that do not contradict the legislation of Ukraine.

The purpose of the Bank's processing of personal data of personal data subjects may change as a result of changes in the terms of contracts concluded with them or business relations, the content of the Bank's activities, including in connection with changes in the legislation of Ukraine.

Rights of natural persons - subjects of personal data

According to Article 8 of the Law of Ukraine "On the Protection of Personal Data", the subject of personal data has the right:

•    to know about the sources of collection, the location of your personal data, the purpose of their processing, the location or place of residence (residence) of the owner or manager of personal data or to give an appropriate mandate to obtain this information to persons authorized by him, except for cases established by law;
•    receive information about the terms of providing access to personal data, in particular information about third parties to whom personal data is transferred;
•    to access your personal data;
•    to receive no later than thirty calendar days from the date of receipt of the request, except in cases provided by law, an answer on whether his personal data is being processed, as well as to receive the content of such personal data;
•    submit a reasoned claim to the owner of personal data objecting to the processing of their personal data;
•    make a reasoned demand for the change or destruction of your personal data by any owner and administrator of personal data, if these data are processed illegally or are unreliable;
•    to protect your personal data from illegal processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision of data, as well as protection from providing information that is unreliable or dishonors the honor, dignity and business reputation of a physical person individuals;
•    file complaints about the processing of your personal data with the Commissioner or the court;
•    apply legal remedies in case of violation of the legislation on personal data protection;
•    enter reservations regarding the limitation of the right to process your personal data when giving consent;
•    withdraw consent to the processing of personal data;
•    know the mechanism of automatic processing of personal data;
•    to protect against an automated decision that has legal consequences for him.

Grounds for processing personal data

Processing of personal data is carried out by the Bank with the consent of individuals, as well as without such consent in the cases defined by Article 11 of the Law of Ukraine "On the Protection of Personal Data":

•    for the Bank to implement its functions, rights, obligations and powers defined by the legislation of Ukraine, including in accordance with the Law of Ukraine "On Banks and Banking Activities", the Law of Ukraine "On Prevention and Combating the Legalization (Laundering) of Criminal Proceeds or the Financing of Terrorism", the Law of Ukraine "On Financial Services and State Regulation of Financial Services Markets", i.e. .;
•    for the purpose of concluding and executing a transaction to which the subject of personal data is a party or which was concluded for the benefit of the subject of personal data or for the implementation of measures preceding the conclusion of the transaction at the request of the subject of personal data;
•    in order to protect the vital interests of the subject of personal data;
•    if necessary to fulfill the obligation of the owner of personal data, which is provided by law;
•    if it is necessary to protect the legitimate interests of the owners of personal data or a third party to whom personal data is transferred, except in cases where the needs to protect the fundamental rights and freedoms of the subject of personal data in connection with the processing of his data prevail over such interests.

For the purpose of monitoring fraudulent / risky banking operations and / or taking measures to repay the client's debt, the Bank has the right during the term of the Agreement to establish the geolocation of the phone of the client / authorized person of the client, the number of which is specified in the Agreement, as well as to use information about the location of the client / authorized person of the client , received by the Bank based on the geolocation of the phone.

The Client grants the Bank permission to display the availability status and type (class) of the Client's card in the mobile application of other Bank clients that have the Client's phone number among the smartphone metadata. Also, the Client gives the Bank permission to use the phone numbers and names of contacts and their images contained in the metadata of the Client's smartphone, in order to quickly transfer funds using the Mobile application. The Bank does not use or store any other data contained in the metadata of the Customer's smartphone.

The Bank processes personal data obtained from publicly available sources without the consent of the subject of personal data. An individual's application to the Bank or use of the Bank's services indicates the consent of such a person to the processing of his personal data by the Bank in connection with such an application or use of the Bank's services. A person's objection to the processing of personal data necessary for the Bank to fulfill its obligations, including withdrawal of consent to data processing by a person may become grounds for the Bank to terminate the performance of the terms of the concluded contracts. In the event that a natural person withdraws consent to the processing of personal data without completing the procedures necessary to terminate contractual or other relations with the Bank, the Bank will continue processing personal data within the limits and volumes determined by the implementation of existing legal relations and the legislation of Ukraine, including for the Bank to protect its rights and legitimate interests under contracts.

Composition and content of processed personal data

The RwS online application collects and stores:

• information about the location of the device - for finding branches, ATMs or terminals of the Bank.
• access to the camera and the media library of the mobile device - to create photo documents, to create or save an image or photo.
• read-only access to mobile device status, including phone number, current network information, status of all current calls, and a list of all accounts registered on the mobile device - to increase the security level of using the RwS online application.
• phone book of a mobile device – for using the client's contact book when connecting to the money transfer service by phone number.
• e-mail address – to display the client's e-mail in the RwS online mobile application, for communication with the client.
• SMS-message – for auto-completion of the one-time password (OTP) in the RwS online application.
• photo of the Client - to display the photo in the user's profile in the RwS online application and for initial registration in accordance with the requirements of current legislation.

Basis for processing: Conclusion and execution of the transaction, Consent of the person (in some cases).

Collection of personal data

Collection and processing of personal data specified by the Bank is carried out based on the written consent of the subject of personal data.

During the relationship between the subject of personal data and the Bank, personal data is entered into the Bank's banking automation systems. Subjects of personal data shall notify the Bank of a change in their personal data subject to processing within ten days and provide the relevant documents.

In the case of detection of the fact of entering information into personal data that does not correspond to reality, such information must be immediately corrected or destroyed.
Consent to the processing of personal data of clients, counterparties, etc. is defined in the contract on banking services between the Bank and the client, which is signed by the client himself, or in other documents. The subject of personal data is informed about the owner of personal data, the composition and content of collected personal data, the rights defined by the Law of Ukraine "On the Protection of Personal Data", the purpose of collecting personal data and the persons to whom his personal data is transferred:

•    at the time of collection of personal data, if personal data is collected from the subject of personal data;
•    in other cases, within thirty working days from the date of collection of personal data.

Storage and destruction of personal data

Personal data are stored for a period no longer than is necessary in accordance with the purpose of their processing, unless otherwise provided by legislation in the field of archival and record keeping.

Personal data shall be deleted or destroyed in case of:

• expiration of the data storage period determined by the consent of the subject of personal data to the processing of this data or by law;
• termination of the legal relationship between the subject of personal data and the owner or administrator of the database, unless otherwise provided by law;
• Issuance of the relevant order of the Commissioner or officials of the Secretariat of the Commissioner designated by him;
• entry into legal force of a court decision on the removal or destruction of personal data;
• at the reasoned request of the subject of personal data, if it does not contradict the requirements of the legislation of Ukraine.

The Bank processes personal data as necessary, during the entire duration of all business relations with the relevant subjects of personal data (starting with the conclusion of a contract/service order, their execution and ending with the termination of the relevant contract, completion of customer service of the Bank), as well as until the expiration of the information (documents with such information) storage periods determined by the terms of concluded contracts or the legislation of Ukraine, including the Law of Ukraine "On Prevention and Counteraction of Legalization (Laundering) of Proceeds Obtained by Crime, Financing of Terrorism and Financing of the Proliferation of Weapons of Mass Destruction ", by the Rules of application of the list of documents generated in the activities of the National Bank of Ukraine and banks of Ukraine, approved by the Resolution of the Board of the National Bank of Ukraine No. 130 of November 27, 2018, internal documents of the Bank.

For «RwS online» users:

The account is closed remotely if a completed application is submitted with a qualified digital signature of the client to the address office@rwsbank.com.ua.
In other cases, this application should be filled out at a bank branch.

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