Your personal data are under the responsibility of FNBC INVEST LDA (hereinafter Seven Bank), headquartered at Rua do Arranjinho, nº 321 – 4750-803, Barcelos, with share capital of €20,000,000.00 and registered at the Lisbon Commercial Registry under the unique number of registration number and legal person 516 034 871 (“FNBC Invest LDA”).

By visiting FNBC INVEST’s (hereinafter Seven Bank) Website, registering as a user or using our services, or otherwise interacting with us, you acknowledge that this Privacy Policy will be applicable to processing of your data. Please read this Privacy Policy carefully. In certain cases, processing of your personal data will only be performed if you give your consent.

We want to inform you that Seven Bank will use and obtain IP addresses and further identifiers provided by your mobile device when you use the App correctly. Similarly, the personal data provided through Seven Bank’s Website or through the App are, unless otherwise specified, necessary for the purposes established. Seven Bank will not be able to offer its full services if that data is not provided.

Seven Bank only collects and processes the personal data necessary for the provision of associated services. Seven Bank does not process personal data that is not necessary for its legitimate purposes.

In providing services and offering products, Seven Bank processes or may process various categories of personal data, including:
• Demographic data (e.g., name, gender, place of birth, date of birth, nationality);
• Contractual data (e.g., account number, IBAN, contract reference and other information on contracted products/services);
• Contact details (e.g., address, telephone, mobile phone, email address);
• Government data (e.g., citizen card number or identity card, tax identification number, passport number);
• Digital identification data (e.g., IP address, digital signature, cookies);
• Personal activity data (e.g., academic qualifications, data from social networks or the internet that the holder has made public or authorized Seven Bank to consult);
• Professional activity data (e.g., profession, remuneration, employer, previously held positions);
• Data relating to assets, positions and financial movements (eg, assets and their value, other income earned, liabilities in the financial sector, propensity to purchase financial products);
• Family data (e.g., marital status, number of children, household information);
• Voice recording data (e.g., call recordings – video and/or audio);
• Image registration data (e.g., video recordings (videoconferences, video calls), photography, images collected through video surveillance cameras);
• Biometric data (e.g. data used from technical tools that rely on biometrics to verify the identity and signature in the relationships that Customers maintain with Seven Bank (e.g. facial pattern, voice biometrics, fingerprint).

Seven Bank also processes personal data created from the analysis of your use of our products and services, your transactions and preferences, such as your customer profile.

Seven Bank will process the data you provide as follows:

• Register you as a user of the App and fulfill the terms of your account. Please note that Seven Bank will need to exchange your data with third-party partners in order to offer you our services. We receive information from users that have registered in the App as well as from those who consult our services through the Seven Bank website, even if they have not created an account. We base this processing on necessity to perform contracts concluded with you or in order to take steps (Article 6(1)(b) of the General Data Protection regulation (‘GDPR’).
• Manage payments and execute your payment orders through the App and manage the correct functioning of the App. We base this processing on necessity to perform contracts concluded with you (Article 6(1)(b) of the GDPR).
• Assess the risk of new payment transactions in Seven Bank. For this, we rely on our legitimate interest to control risk and manage our commercial exposure (Article 6(1)(f) of the GDPR).
• Prevent, investigate and/or discover fraud. We process data for this purpose to ensure compliance with our legal obligations (Article 6(1)(c) of the GDPR) and for our legitimate interest to protect ourselves, our users, or any third parties (Article 6(1)(f) of the GDPR).
• Send you, by any means, including electronic means, commercial communications in relation to products and services offered by Seven Bank. These communications will be adapted to your use of the App or Website. Seven Bank will process this data based on the relationship it has with the user, understanding that those communications will always be related to Seven Bank’s products and services. We will send you our commercial communications based on our legitimate interest to promote our business (Article 6(1)(f) of the GDPR). In some cases, where we cannot rely on our legitimate interest, we will send you or communications on the basis of your consent (Article 6(1)(a) of the GDPR). We may also create a commercial profile of the user to offer tailored commercial actions, unless you do not want us to, or you oppose or withdraw your consent.
• Manage the commercial relationship with you, answer any questions, problems or incidents you may have when you contact us through the App. Legal basis for processing is our need to fulfil or facilitate fulfilment of our contractual obligations to you (Article 6(1)(b) of the GDPR).
• Carry out the necessary requirements to manage candidate selection processes. We do this to fulfil our legitimate interests to manage our human resources and employment procedures (Article 6(1)(f) of the GDPR).
• Create anonymous statistical reports regarding the activity of users within the App. This is for our legitimate interest to manage our statistical data and improve our services (Article 6(1)(f) of the GDPR).

Seven Bank processes the following data:

• Identification data: name, last name, official identification document, phone number, email, address, personal picture, social media handle (when contacting us through those means).
• Security PIN
• Personal data and personal characteristics included in official identification document: place of birth, place of residence, date of birth, sex, nationality, and any other relevant information printed on your identity document.
• Financial data: details of your bank account, IBAN code, details of your debit and credit card, relevant expiry dates and CVV.
• Contacts of the user: phone numbers of the contact list of the user.
• Location information: we obtain information on your IP address when you use the App. We use technology to determine your location such as a GPS system or your IP address. You can always choose to share your location, but it is not required nor is it necessary for most of the services offered by Seven Bank. If you decide not to share it, we will not be able to offer you the services that require your location.

Personal data will be kept until you request its deletion, or, where personal data is processed on the basis of your consent, until you withdraw your consent. In absence of these actions, we store your data for the duration of our relationship with you and 6 years after the fiscal year in which our relationship ends in order to help comply with any legal investigations or requests from competent authorities.

Seven Bank processes or may process your personal data in the following situations:
• For the performance of a contract between you and Seven Bank, or for carrying out pre-contractual measures;
• To comply with legal obligations to which Seven Bank is subject;
• When you have given your prior consent;
• For the legitimate interests of Seven Bank;

Seven Bank may disclose your data to:

Public Administrations, Tax Authorities and Courts and other state institutions in order to comply with a legal obligation.
Similarly, Seven Bank works with some third-party partners, data processors, that could have access to your data and process that data on behalf of Seven Bank. This is needed to provide you with Seven Bank services.
Specifically, some of these partners are in the following industries: payment processors, NFC readers, legal counsels, software developers, physical security companies, mailing providers etc.

Some of these data processors such as Google Cloud Services, Mixpanel, and Twilio are outside the European Economic Space. However, all of them are listed in the EU_US Privacy Shield (www.privacyshield.gov/list) and guarantee the adequate protection of the rights of residents in the EU.

In order for Seven Bank to be able to fulfill all its duties and provide you with the best products and service, we may have to communicate your personal data to other entities. Seven Bank will only communicate your personal data to the following categories of recipients:
• Other entities belonging to the Seven Bank Group, FNBC Invest LDA;
• Service providers to Seven Bank (e.g., IT services, telecommunications services, credit management and recovery services, filing services, payment services, credit intermediation services);
• Organizations inside and outside the European Union (e.g., other financial institutions for, for example, the execution of transfer/payment operations or regulatory authorities not based in the European Union, securities fund management companies, real estate fund management companies);
• Supervisory entities and other public/official entities (e.g., Tax Authorities, the Bank of Portugal, the European Central Bank, the Securities Market Commission, Judicial or Administrative Courts)

The conservation of your personal data, by Seven Bank, is carried out for the purposes indicated above during the period of time necessary or mandatory for the fulfillment of these purposes, applying criteria for retention of information appropriate to each treatment and in line with contractual obligations, applicable laws and regulations, or to defend the legitimate interests of Seven Bank or third parties.

With regard to the processing of your personal data, you have the following rights:
• Right of access;
• Right of rectification;
• Right to erasure;
• Right to limitation of treatment;
• Right to portability;
• Right of opposition;
• Right not to be subject to exclusively automated individual decisions;
• Right to withdraw your consent;
• Right to file complaints with the supervisory authority

You can exercise your rights through the following channels:

In person: you can exercise your rights by going to the Seven Bank headquarters at Rua do Arranjinho, nº 321 Zona Industrial – V.F.S Martinho 4750-803, Barcelos;
E-mail: you can exercise your rights by e-mail to support@sevenbank.pt;
Digital Channels: you can exercise your rights through access to Seven Bank Online, at www.sevenbank.pt or through access to the Mobile App.
Letter: you can exercise your rights by means of a letter, addressed to Seven Bank for the attention of the management and sent to the address mentioned above.

Our website and our App can have links to other Websites, Apps or to third-party provided services. The data collected by third-parties, including the geographical location or contact data, will follow their respective privacy policies. For this purpose, we recommend you review their privacy policies to be informed about the security measures they take to protect your data.

Seven Bank will process your personal data in a strictly confidential way, respecting the privacy, secrecy and security of your information, in accordance with applicable regulation. In order to achieve this Seven Bank will implement the legal, technical and organizational measures required to avoid the alteration, loss, unauthorized access or processing of your data, given the state of technology, the nature of the data processed and the risks to which it is exposed. Sadly, there are no perfect security measures, and security breaches can still happen. Should this be the case, we will take urgent measures to minimize any potential damage to you or others.

Seven Bank recommends that minors do not send personal data without parental consent. Seven Bank does not take responsibility over personal data that could have been provided to us by minors younger than 14 years of age without parental consent.

Beta testing its when our mobile apps or our websites are under testing from our clients and users.
We decide that all our testing should be done with our clients so we can receive as much feedback as possible when delivering some new application or some new feature.
If any application or website its under testing and you don’t want to be part of our tests please don’t open any account. If you already have an account consider sening an email to: suporte@sevenbank.pt and make a formal account close request.

To open an account in Seven Bank, you’ll need to deposit 500€.

This money will be available in your Seven Bank account to be used as you like.

This deposit will only be needed after your account passes our review. The details on how you should proceed with the deposit will be sent to your email after the review has been completed.

We will use the data provided to us to inform you about promotions, offers, events or any other relevant information that could be of your interest. Every time we send out any of these communications, they will be directed to those users who have not specified their preference to be exempted from them.

If you do not wish to continue receiving commercial or promotional information, you can request it by email at support@sevenbank.pt

Seven Bank reserves the right to modify this Privacy policy and to adapt it to future regulatory or technological changes.

We will inform you about those changes by publishing them on the Seven Bank website, or in the App or via email within a reasonable time prior to the date on which they come into force. In special cases where urgency is required, we may modify the Privacy Policy without informing you prior to their implementation.

If you continue accessing the App or using Seven Bank’s services after the changes are made, you accept that you will be bound by the new Privacy Policy.