CaixaBank and the CaixaBank Group companies that we indicate below are joint data controllers to carry out the following commercial activities: (i (i) customisation of product offer according to analysis of your data; (ii) notification of the commercial offer of products and services through channels; and (iii) transferring data to other companies:
- CaixaBank, S.A.
- CaixaBank Payments & Consumer, E.F.C., E.P., S.A.U.
- Nuevo Micro Bank, S.A.U.
- Wivai Select Place, S.A.U,
- ImaginersGen, S.A.
- VidaCaixa, S.A.U. de Seguros y Reaseguros
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 of which are as follows:
(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 for this processing is your consent, as laid out in Article 6.1.a) of the General Data Protection Regulation (GDPR).
We may have requested this consent through different channels; for example, during your (in-person or virtual) customer registration interview, through your adviser, through our digital channels or mobile applications, or at any CaixaBank Group company that is a joint data controller of the specific processing operation.
If, for any reason, we have never asked you for your consent, this processing will not apply to you.
You can view the consent you have given or denied, and change your decision at any time and for free at our branches, the CaixaBank website (www.caixabank.es) and each of the companies jointly responsible for the specific processing, or through your online account or the CaixaBank mobile apps.
The types of data processing for commercial purposes based on your consent are listed below from (A) to (C). For each item, we will indicate: a description of the purpose (Purpose), the details of the processed data (Processed data), if applicable, information on the use of profiles (Use of profiles) and other relevant processing information (Other relevant information).
A. Customisation of product offer according to analysis of your data
Purpose: If we have your consent, we will use the data indicated below to create a commercial profile for you, which will allow us to define your preferences or needs and offer you, through your adviser (in-person or virtual), products and services marketed by companies acting as joint data controllers that we believe may interest you according to those preferences and needs.
By processing your data, we can make customised offers that may be of more interest to you than generic offers.
Data processed: We will not process data that contains information that reveals your ethnicity or race, your political opinions, religious or philosophical convictions, union membership, the processing of genetic data, biometric data intended to uniquely identify you, health data or data relating to your sex life or orientation.
The data we will process for this purpose are:
- Identifying and contact details: full name, sex, telephone and email contact information, address of residence, nationality and date of birth, language choice, identification document.
- Details of your professional or work activity and socio-economic information: details related to your job, income or remuneration, household, level of education, assets, tax and fiscal data.
- Contract details: contracted or requested products and services (own or third-party), account holder status, authorised or representative of the product and service contracted, categorisation according to regulations regarding securities markets and financial instruments (MiFID category), information on investments made and their evolution and information and transactions related to your financing operations.
- Basic financial data: current and historical balances of products and services and payment history of contracted products and services (own or third party).
- Third-party data from statements and receipts of instant accounts and payment accounts: information on entries and transactions that third-party issuers make to your accounts, including transaction type, issuer, amount, and the concept as it appears on receipts and statements for debit, credit and prepaid card transactions.
- Details of whether or not you are a CaixaBank shareholder: if you have CaixaBank shares or not.
- Data on communications maintained with you: data obtained in chats, walls, video conferences, telephone calls or any other equivalent means of communication.
- Own browsing data: if you have accepted the use of cookies and similar technologies on your browsing devices, the data obtained from your browsing on our websites or mobile applications and the browsing you perform on them: browsing history (pages visited and clicks on content), device ID, advertising ID and IP address.
- Geographical details: details of the location of the businesses where you make card transactions and the geolocation data of your mobile device provided by the installation and/or use of our mobile applications, when authorised by you in the settings for the apps.
- Data obtained from the execution of statistical models: we use the results of applying mathematical modelling to client data, which helps us combat fraud, detect your consumer habits, preferences or product tendencies for regulatory compliance, and manage your products and services.
- Risk assessment data or scoring: in financing or payment for instalments, we will forecast your capacity to pay or not pay or the risk limits, applying statistical and mathematical models using your data.
- Demographic and socio-economic data: statistical data not related to specific people but geographical areas, age sectors or professional activity sectors, which we will use to put into context with customer information.
- Details of properties and vehicles associated with you: these are data obtained from the land registry and basic data on vehicles obtained from the Spanish Traffic Directorate, which we will use to add to the information on your properties and vehicle.
- Details of directors, functional officers and corporate relationships: these are data taken from the INFORMA databases that we will use to add to the information on your activities.
- Details of agricultural subsidies and insurance: these are data published by the Spanish Agricultural Guarantee Fund (FEGA) and the State Agricultural Insurance Institution (ENESA).
- Data from third-party companies where you have given your consent to share them with us: your data processed by other companies with which we have agreements, and which you have authorised to share your information with us.
- Browsing details: if you have accepted the use of cookies and similar technologies on your browsing devices, the data obtained from your browsing on third-party websites or mobile applications and the browsing you perform on them: browsing history (pages visited and clicks on content), device ID, advertising ID, IP address, whether you have accepted the use of cookies and similar technologies on your browsing devices.
- Data from social media or the internet: social media or internet data that you authorise us to view.
Use of profiling: For this processing, we will create a business profile that we will use exclusively to customise the products and services we offer you:
- Purpose of the profile: The purpose of the profile is to identify the products and services we think may interest you, based on the information we have about you, to offer your specific rather than generic commercial offers.
- Consequences: If you authorise the processing, we will use commercial profiles to decide which products or services to offer you. If you do not give your authorisation, we will not use your information to customise our commercial offer.
We do not use this profiling, under any circumstances, to refuse any product or service, or to set credit limits. Refusal to accept this processing will not prevent, limit or condition your access to our full catalogue of products and services, which is always available to you.
If you apply for any product or service, your application will be assessed in accordance with our regular procedures. The acceptance or non-acceptance of the analysis of your data for the purpose of customising the product offering will not affect this assessment. - Logic: The profile of a customer is calculated based on the data indicated in the "processed data" section.
These data are applied to mathematical formulas obtained from past behaviours observed in clients of similar characteristics to infer the customer's future behaviour. These mathematical formulae allow us to determine the importance of all the data processed in the final result of the applicant's profile.
This final result is the probability that the customer will be interested in a product or service.
Other relevant information: The following section includes other relevant data processing information:
- Preliminary check of your payment capacity: When the offers we wish to propose to you consist of products or services that involve payment in instalments or financing, we will first check your payment capacity.
We will carry out this check by means of the processing outlined in section 6.2.C of our Privacy Policy, with the aim of offering you a credit limit and repayment term suited to our knowledge of your financial situation, in accordance with the principle of responsibility regarding the offer of financing products required by the Bank of Spain, under regulations on the oversight and solvency of credit institutions and responsible lending.
Not accepting this processing does not prevent, limit or condition your access to our catalogue of financing products and services. If you request them, we will evaluate them with you in accordance with our standard procedures. - Duration of data processing: We will only process your data if you have given us your consent, which will remain in force until you withdraw it. If you cancel all your products or services but forget to revoke your consent, we will do so automatically.
- Offer of products and services from companies acting as joint data controllers: If you consent to this processing, we will offer you products and services marketed by the companies acting as joint data controllers detailed in the following section.
These companies engage in activities related to finance, banking and payment methods, including the offering of property assets derived from these activities; to the insurance business; to general e-commerce; to leisure; and to the promotion of corporate and sustainability actions.
B. Notification of the commercial offer of products and services through channels
Purpose: If we have your consent, we will make our commercial offer available to you through the following channels: mobile applications, digital environments and electronic channels, letter or telephone.
Data processed: The data we will process for this purpose are:
- Identifying and contact details: full name, sex, telephone and email contact information, address of residence, language choice.
Other relevant information: The following section includes other relevant data processing information:
- Duration of data processing: We will only process your data if you have given us your consent, which will remain in force until you withdraw it. If you cancel all your products or services but forget to revoke your consent, we will do so automatically.
C. Transfer of data to other companies
Purpose: If we have your consent, we will transfer the data indicated below to companies with which we have agreements so they can offer you their products and services.
If you do not consent to this data processing, we will not disclose your data. However, if you do give your consent, the data transferred to other companies will vary depending on whether you have authorised us to customise our product offerings by analysing your data:
- If we do not have your consent to customise our commercial offer (Processing A), we will only provide these companies with your identifying and contact details.
- If you have given us your consent to personalise our commercial offer (Processing A), we will also inform these companies of your commercial profile, including information on your preferences and needs, as well as inferred information about your probability of payment or non-payment, or risk limits.
These third-party companies to which we may transfer your data undertake the following activities:
- banking
- investment services
- insurance and reinsurance
- venture capital
- property
- highways
- sale and distribution of goods and services,
- consultancy services
- leisure and
- charity-social action
Data processed: We will not process data that contains information that reveals your ethnicity or race, your political opinions, religious or philosophical convictions, union membership, the processing of genetic data, biometric data intended to uniquely identify you, health data or data relating to your sex life or orientation.
This is the data we will use if you consent to us disclosing your data to third parties, but we do not have your consent to personalise our commercial offer of products and services to you (Processing A):
- Identifying and contact details: full name, sex, telephone and email contact information, address of residence, nationality and date of birth, language choice, identification document.
We will also use the following data if you have given us your consent to personalise our commercial offer of products and services (Processing A): - Data obtained from the execution of statistical models: we use the results of applying mathematical modelling to client data, which helps us combat fraud, detect your consumer habits, preferences or product tendencies for regulatory compliance, and manage your products and services.
- Risk assessment data or scoring: in financing or payment for instalments, we will forecast your capacity to pay or not pay or the risk limits, applying statistical and mathematical models using your data.
Other relevant information: The following section includes other relevant data processing information:
- Data transfer information: If we reach an agreement with a third company to transfer your data, the recipient company will inform you of this situation and the details of the processing they intend to carry out.
- Duration of data processing: We will only process your data if you have given us your consent, which will remain in force until you withdraw it. If you cancel all your products or services but forget to revoke your consent, we will do so automatically.