As a bank, we make use of profiling. Below we explain why we do this, and when.
How do we make use of profiling when you want to purchase a product? The following example explains how we do this. Imagine that you apply online for a loan from us.
We also use profiling to send you offers that are appropriate for you. For example, if you have a mortgage you will not receive any offers for mortgages from us. We attempt to identify your areas of interest, based on a number of characteristics. We then look at specific aspects, such as your age category and whether you already have any other products from us. You will only be selected for a relevant marketing campaign if you meet a specific profile. Obviously, we check the data protection rules to determine whether personal data may be used for that purpose. You may object to the creation of a personal client profile for direct marketing purposes at any time. If you do not have a contract with us, we determine whether direct marketing is permitted in specific situations.
We may use automated decision-making if we enter into a contract with you, for instance for an online loan.
If we make a decision that has legal consequences for you or affects you to a significant degree, this will be done with the intervention of one or more competent bank employees. This also applies if the process that led to the decision is automated or if profiling was used. Examples include client acceptance or the reporting of unusual transactions to the authorities.
There are situations in which we use automated decision-making without any human intervention. This is permitted by law. These situations may, among other things, concern decisions not to execute transactions, such as iDEAL transactions, because they might be fraudulent. These decisions may be taken on the basis of a fully automated process without any human intervention.
If, at any time in the future, we want to use automated decision-making that has legal consequences for you or affects you to a significant degree, we will make this clear to you beforehand. We will inform you of your rights, such as your right to obtain an explanation of the decision reached by automated means, your right to express your point of view, your right to challenge the decision and your right to obtain human intervention.