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Cajasur Banco, S.A.U. maintains a firm commitment as regards the protection of personal data and the confidentiality of our customers’ information, as well as providing updated and comprehensive information of the data processing undertaken by the organisation at all times, in accordance with prevailing regulations. We therefore inform you below about how we process your personal data in Cajasur Banco, S.A.U., (hereinafter, Cajasur).
Basic Information on Data Protection |
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Controller |
Identity: Cajasur, S.A. Postal address: Avda. del Gran Capitán 11-13, 14008 (Córdoba) Email address: info@cajasur.es Data Protection Officer Contact: dpo@grupokutxabank.com |
Data categories used |
Detailed information can be found in section 3 of this Policy.
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Main purposes of processing and legitimation |
Detailed information can be found in section 4 of this Policy.
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Recipients |
Detailed information can be found in section 6 of this Policy.
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Rights |
Data subjects may submit a claim before the control authority as well exercise their rights of access, rectification, cancellation, objection, limit processing, portability of the data and not be subject to automated individual decision making, as regards their personal data, including profiling in writing by means of an email or communication addressed to the registered office of the process controller stated above. |
Origin |
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Cajasur has developed this customer personal data protection Policy, which may be accessed at any time from the “Privacy” section at www.Cajasur.es or www.Cajasur.com, and in which you may consult the full details of how we will use your personal data in the relationships we establish with you. Similarly, you may request this information on paper from any of our branch offices.
In order to manage your relationship with us, Cajasur will process your personal data for each one of the purposes we inform you of in this Policy and always in accordance with prevailing regulations, respecting your rights and with total transparency.
The main regulations regulating our processing of your data are:
Other regulatory bodies which include obligations in terms of the protection of personal data are as follows:
Controller: The controller of the personal data in your contractual and business relations with us is Cajasur, S. A., with registered office at postal address: Avda. del Gran Capitán 11- 13, 14008 (Córdoba). Email: info@cajasur.es.
Cajasur has a Data Protection Officer appointed, who will assist you to answer any questions relative to the processing of your personal data and the exercising of your rights. You may contact the Data Protection Officer to submit your suggestions, questions, misgivings or claims at this address: dpo@grupokutxabank.com
Cajasur has also entered into joint controller processing contracts with each one of the following subsidiary entities: Kutxabank Pensiones for the management and administration of Pension Plans and Voluntary Social Welfare Entities.
The mayor aspects of said agreements are as follows:
The purpose of processing the personal data of the ordinary members and beneficiaries of Kutxabank Pensiones is to formalise, manage and execute the contractual relationship of adhesion of such ordinary members and beneficiaries to the Welfare Plans. The execution of the aforementioned adhesion contract constitutes the legitimate basis for this processing.
The purpose of personal data processing by Cajasur is to guarantee its customers, a high- quality service, an increased protection of their interests and better monitoring of any incident that may arise from the contractual relationship of adhesion to any of the products. The legitimate basis of this processing constitutes the legitimate interest of providing quality assistance to the members of said Entities as well as strengthening the guarantees for the correct administration of this type of transactions.
On the grounds referred to, the operation related to the processing of personal data is performed by Cajasur, on your behalf and in its name, and in the name of each one of the joint controllers.
In any case, you may exercise your rights before Cajasur S.A.U.
Cajasur in addition, has put together a joint responsibility agreement with the Entities subscribed to the information sharing service for the prevention of fraud. Information on the Entities adhered to said file can be found at
https://www.iberpay.es/es/servicios/servicios/prevenci%C3%B3n-del-fraude/#tab-4
Processing consists of the recording and retrieval of data of suspicious or unauthorised transactions in a common repository operated by Iberpay as process controller in an effort to detect and prevent transactions suspicious of fraud, or whose fraudulent condition has been expressly acknowledged by the affected holder. The legitimate basis is constituted by legitimate interest, of the account holders likely to be affected by the fraud committed by third parties, as well as the Entity in ensuring the detection and prevention of fraud in the incoming and outgoing transactions of your account.
Cajasur will process different personal data in order to manage your requests for information or the pre-contractual or contractual relations you enter into with us.
Outlined below are the data categories we will process, with the knowledge that not all the data categories listed are used for all data processing. In the details of the processing activities that we carry out, contained in section 4, you may specifically consult each particular processing of the data categories used, therefore counting on the necessary information enabling you, if you wish, to exercise your rights recognised by the GDPR, particularly those of opposition and withdrawal of consent.
The data categories used in the different processing activities are as follows:
In cases in which the personal data are provided by persons holding parental authority or by the legal representatives of persons with disability, the latter are authorised to collect the data as well as their use and processing by Cajasur for the purposes described in this Policy.
All data collection obtained, in the event it occurs, originating from information you have provided to third parties and is handed over by said third parties to Cajasur, require consent prior to incorporating these into the Cajasur S.A.U databases. In this case, Cajasur will contact you within a month at the latest in order to provide you with the information contained in this customer personal data protection Policy.
You ensure the veracity of the personal data provided to Cajasur during the entire contractual relationship and undertake the obligation of notifying the Bank of any change thereof in accordance with this data protection policy. Cajasur may, in any case, and without prejudice to its referred communication obligation, regularly request the review and updating of the personal data the entity maintains about you; it is also legitimated to conduct the appropriate verifications, within the prevailing regulations.
Under no circumstances will we process data that may infringe upon the principles of competition or business secrets.
It is important to understand that we do not infer any data that may contain information which reveal your ethnic or racial origin, political opinions, religious or philosophical convictions, union affiliation, the processing of genetic data, data relative to health or data relative to your life or sexual orientation (“Special data categories”).
The processing we carry out responds to different legal purposes and bases.
Description of the processing
Prior to registering your data in our systems, we will inform you of this customer personal data protection policy and then request the minimum data needed to commence the pre- contractual activity or contractual relationship you request.
Cajasur will carry out the following processing, inter alia:
Purpose of the processing
The purpose of this processing is to treat your personal data in order to handle and analyse your registration as a customer, the contract request or the concluding of the contracts.
Basis of the processing
The processing will be carried out in accordance with the obligations set forth in the prevailing legislation at all times as regards the acceptance and registration process of customers and the contracting processes of each one of the products.
Data categories used
The data Cajasur will use for these purposes are:
Verification services of Iberpay account ownership
Additionally, your identification and account data will be processed in order to enable verification of the ownership of your account at the request of a third party with whom you have initiated a contractual relationship that entails direct debiting or debiting to an account.
The processing of the data in order to verify ownership of the account in which the formalisation of an immediate or future collection or payment is intended, is based on the contractual relationship maintained with the third party requesting the verification, as well as with Cajasur and seeks the proper compliance of the contract signed between the parties, in such a way that a prior check is carried out in order to prevent pecuniary losses arising from an error of the payment into the direct debit account.
Description of the processing
The processing operations to carry out are as follows:
Purpose of the processing
The purpose of the processing is to develop, control, maintain and update the contractual relationship we have formalised.
Basis of the processing
This processing is required for maintaining the contractual relationship we establish and failure to provide them would make it impossible to manage such relationship, as it is based on meeting the contractual and legal obligations of the Entity.
Data categories used
The data Cajasur will use for this purpose are:
Data disclosures
Cajasur may disclose your data to the competent authorities, control and supervisory bodies and legal, administrative or tax authorities, for the purpose of meeting the applicable regulations at all times, in particular, but not limited, to the banking or financial sector. In addition, Cajasur may disclose your data to collaborators needed in processing activities such as agents, auditors, Notaries Public and Public Registries.
Description of the processing
Including without limitation, the most relevant processing carried out with these purposes is outlined:
Purpose of the processing
The purpose of the processing is to meet accounting, legal, tax and administrative obligations.
Basis of the processing
The processing of your data is necessary for meeting the accounting, tax and legal obligations required from the Entity for its activity.
Data categories used
Data disclosures
Cajasur may disclose your data to the competent authorities, control and supervisory bodies and legal, administrative or tax authorities, for the purpose of meeting the applicable regulations at all times, in particular, but not limited, to the banking or financial sector. In addition, Cajasur may disclose your data to collaborators needed in processes such as Notaries Public and Public Registries.
Description of the processing
The processing carried out with these purposes is as follows:
Purpose of the processing
The purpose of the processing is to maintain the security of economic traffic, thereby contributing to safeguarding the general interest and make it possible to improve the risk analyses performed by the Entity in order to protect free commercial exchange under conditions of security and solvency.
Basis of the processing
This processing is carried out in order to meet the regulations on the responsible granting of loans and remaining legal measures required by applicable legislation.
Data categories used
Data disclosures
Data relative to defaults may be reported to files relative to the compliance or non- compliance of monetary obligations, Badexcug (Experian) and Asnef (Equifax) and to CIRBE in accordance with its specific regulations.
Description of the processing
The processing carried out with these purposes is as follows:
Purpose of the processing
The purpose of the processing is the prevention of criminal activities and those related to money laundering and the financing of terrorism as defined in the specific regulations.
Basis of the processing
This processing is carried out in order to comply with prevailing legislation on the prevention of money laundering and the financing of terrorism which obliges banking entities to obtain information and documentation from their customers as regards their identity and their economic activity in order to apply due diligence and knowledge of customer measures.
Data categories
Data disclosures
In force regulations require and enable Cajasur to share information with subsidiary Entities that form part of the Represented Group for the Prevention of Money Laundering and the Financing of Terrorism to this end.
Likewise, Cajasur has the obligation of declaring to the Financial Ownership File the opening or cancelling of any current accounts, savings accounts, stock accounts, deposits and of any other type of payment accounts, as well as safety deposit box lease agreements and lease terms regardless of its trade name, consequently your identification data will form part of this file created for the purpose of preventing and deterring money laundering and the financing of terrorism. The controller of this file is the Secretary of State for the Economy and Business Affairs.
Description of the processing
The processing carried out for this purpose is:
Purpose of the processing
The purpose of this processing is the prevention, detection and/or pursuit of fraud.
Data categories used
The data categories used for this purpose are:
Basis of the processing
The processing is based on the legitimate interest of the account holders who may be affected by fraud committed by third parties, as well as Cajasur’s of ensuring the detection and prevention of fraud in the banking transactions to and from your account.
Data disclosures
With the exclusive goal of preventing criminal situations, and provided it has sufficient evidence for determining the existence of a possible fraud, Cajasur will be legitimised, in order to prevent thereof, to disclose the data of its customers to Cajasur, or to outside companies affected by such situation.
Processing referring to the Information Sharing Service for the prevention of fraud.
Joint controllers for the processing
The joint controllers of the file are all the financial institutions adhered to said common file as joint controllers of the processing. The Entity has the essential aspects of such joint controller agreement at your disposal and you may request it via the email address of our Data Protection Officer dpo@grupokutxabank.com. In addition, you may consult the updated list of entities adhered to the common list at https://www.iberpay.es/es/servicios/servicios/prevenci%C3%B3n-del-fraude/#tab-4.
Description of the processing
Registering and consulting the data of suspicious or unauthorised transactions in a common repository operated by Iberpay as controller of the processing.
Basis of the processing
The processing is based on the legitimate interest of the account holders who may be affected by fraud committed by third parties, as well as Cajasur’s of ensuring the detection and prevention of fraud in the banking transactions to and from your account.
Data categories used
Conservation period
Functionality for preventing fraud in cross-border payments in the EU
On the occasion of issuing a cross-border transfer between EU-based financial institutions, we inform you that the personal data related to your target account number and your name as beneficiary holder thereof, may also be processed to detect anomalies and fraud patterns through the European payment systems.
The object of this processing is the identification of anomalous or irregular transactions and the detection of risk behaviours and patterns that enable them to be identified.
The legitimate basis for processing the mentioned data for such purpose is the legitimate interest of Cajasur in detecting and preventing fraud in the banking transactions into or out of your account. Additionally, the processing described is conducted in the interest of the holders of the accounts which might be affected by fraud committed by third parties.
The processing to be conducted on occasion of the detection of anomalies and fraud patterns will be as follows:
Cajasur will not disclose the data collected as regards this processing to any third party other than your counterpart in the transfers and will proceed to delete them when they cease to be necessary for the purpose for which they were collected and, in any case, within a period of 14 months since these have been collected.
Description of the processing
The processing carried out with this purpose is the sending of commercial, generic or personalised communications for promoting products and services commercialised by Cajasur, as well as the remittance of communications relative to personal events, such as birthdays or anniversaries, and public events, such as Christmas and other socially accepted or recognised festivities, sports, social and/or cultural events, through postal mail, fax, SMS, email or by any other medium.
Purpose of the processing
The purpose of this processing is to offer you products and services commercialised by the Bank, and third-party collaborators dedicated to the banking and financial, insurance, real estate and services sectors, which are of interest. In addition, if we have your consent, we will send you communications related to personal events, such as birthdays or anniversaries, and public events, such as Christmas and other socially accepted or recognised festivities, sports, social and/or cultural events, which we believe may be of interest to you.
Data categories used
Basis of the processing
This processing is carried out from your explicit consent granted beforehand for remitting commercial communications. Said consent may be withdrawn at any time, through any of the channels available for exercising your rights and outlined in this Policy.
For promoting other types of products from other subsidiary companies, or third-party collaborators, and particularly in the insurance sector, we will also require your express prior consent. In any case, the mentioned consent is revocable, the customer may also oppose such processing at any time.
In this regard, we would like to inform you that Cajasur has insurance bank agent status exclusive to Kutxabank Vida y Pensiones and Kutxabank Aseguradora, which means that all the insurances commercialised by the bank go through said insurance company.
As an exception, Cajasur considers that in relation to the data subjects who were customers of the Entity prior to the entry into force of the GDPR, it has the legitimate interest of promoting its business activity making offers of credit or savings products and services as well as insurance products which are related to the credit financial products or services it maintains contracted. In order to do this, Cajasur has carried out the corresponding weighting analysis of its interests and the rights and freedoms of the data subjects.
Description of the processing
The processing carried out with this purpose is commercial profiling in order to identify the customer segment and to adapt the offer of products and services.
The profiling done with your personal data is as follows:
With all this, we will be able to identify products and services we believe may be of interest to you according to the data available, not using for these cases any data obtained from external sources, including asset solvency files.
Purpose of the processing
The purpose of the processing is to apply statistical and customer segmentation techniques on your data in order to provide you with commercial offers suited to your needs and preferences as well as monitoring the services contracted.
Data categories
The data categories processed for this purpose are:
Cajasur would like to expressly inform you that no data that you have not provided us with directly, obtained from the information contained in the asset solvency files or other external sources reported in section 3 of this Policy will be used for this profiling. Cajasur will only incorporate the information contained in such files when you request a loan or credit transaction or if we have your express consent. The information incorporated in the rest of the external sources such as the aggregation service, will only be used for profiling if we have your express consent.
Basis of the processing
The processing is carried out on the basis of the Entity’s legitimate interest, consisting of undertaking its duties with the maximum efficiency and quality intrinsic to the Entity as well as perceived by you as a customer. In order to do this, Cajasur has carried out the corresponding weighting analysis of its interests and the rights and freedoms of the data subjects. You may oppose the carrying out of this type of processing at any time by any of the means mentioned in point 8 of this Policy.
By contrast, if external databases are used for producing this information, particularly the information contained in the assets solvency files, the processing will only be carried out if you have requested a loan or credit transaction or we have your express consent. Similarly, in the case of producing this information, information included in the aggregation service is used, the processing will only be carried out if we have your express consent. You have the right to withdraw the provision of such consent at any time.
Description of the processing
The processing carried out with this purpose is relative to the processing of your access requests for promotions or draws organised by Cajasur, which we understand to be in your interest, without the need for you to expressly register therein.
Purpose of the processing
The purpose of the processing is for presenting you promotions offered by the Entity to its customers without the need for you to expressly register therein.
Data categories
The data categories we will process for this purpose are:
• Data you have provided us with when entering into contracts or during your relationship with us.
• Data relative to the maintaining of your products and services.
Basis of the processing
This processing is based on the legitimate interest for managing your contracts, but will require your consent prior to accepting a prize and therefore no processing will be carried out in the event you have previously declared your opposition to be the subject of advertising campaigns.
Description of the processing
The processing carried out for this purpose is to capture and record images through the equipment installed in Cajasur’s offices, branch offices, buildings and corporate centres.
Purpose of the processing
The purpose of the processing is to implement the necessary security measures to protect our customers and the Entity’s assets and to prevent economic and reputational damage. The surveillance camera systems are installed for Cajasur security purposes. Cajasur will not be able to use surveillance cameras in a way incompatible with the purpose expressly described and agrees to save the images recorded in good faith and in accordance with such purpose.
Data categories
The data categories we will process for this purpose will be the images captured by the video surveillance cameras.
Basis of the processing
The basis of the processing is the legal obligation of Cajasur to protect its facilities, staff and customers in accordance with Private Security Regulations.
Data disclosures
Data may be disclosed at the request of judicial authorities or State law enforcement bodies or forces when this is required in the fulfilment of their obligations.
Description of the processing
The processing carried out for the monitoring and constructing statistics of the activity in the Entity, are:
• Pooling customer data for performing statistics.
• Organising the data for drafting reports and statistical models.
In the case of providing data to third parties for statistical purposes, the Entity undertakes to apply the pertinent anonymisation techniques or provide information on an aggregate basis, such that said information bears no relation to an identified or identifiable natural person.
Purpose of the processing
The purpose of the processing is to draft statistical reports and mathematical models for managing and monitoring the Entity’s activity.
Data categories
The data categories we will process for this purpose are:
• Data you have provided us with when entering into contracts or during your relationship with us by means of interviews or forms.
• Data relative to maintaining products and services.
• Data inferred or deduced by Cajasur from the analysis and processing of the remaining data categories.
Basis of the processing
The basis of the processing is Cajasur’s legitimate interest of developing its business activity.
Description of the processing
The processing carried out with this purpose is:
Purpose of the processing
The purpose of the processing is the handling of complaints, as well as preventing, detecting, managing and resolving criminal, illegal conduct and/or contrary to the Entity’s internal regulations.
Data categories
The data categories we will process for this purpose will be:
Basis of the processing:
This processing is carried out under the principle of legitimate interest as well as in compliance of a legal obligation.
Description of the processing
The processing carried out for this purpose is communicating identification, contact and profiling data to other companies so they may remit commercial communications, including by electronic means, of the products and services commercialized by them.
Purpose of the processing
If we have your consent, we will disclose the data to collaborating and/or investee companies, in order for them to make commercial offers of the products and services they commercialize.
Data categories
If you do not grant us consent for this processing, we will not disclose your data. If you do consent, the data we will communicate to other companies will vary depending on whether you have refused, or not, to commercial profiling to adapt the offer of products and services:
Basis of the processing:
This processing is carried out from your prior explicit consent for communicating data to other companies. This consent may be withdrawn at any time through any of the channels enabled for exercising rights and set forth in this Policy.
Data disclosures
The companies to which we may disclose your data provided we have your express consent can be viewed in detail on the following link: https://portal.kutxabank.es/cs/Satellite/kb/es/sociedades-del-grupo-kutxabank/documento.
Cajasur will keep your data during the term of the contractual relationship or as long as is necessary for the particular purpose of each processing.
The processing of data based on consent will be in force until you expressly withdraw it or the contractual relations or business you have established with us have come to an end.
Upon the withdrawal of consent or the end of contractual or business relations, we will proceed to implement technical and organisational measures to ensure your data are only used in accordance with in force legal obligations.
The Entity will proceed with the destruction of your data within the deadlines set forth by the in-force legislation and which regulates Cajasur’s activity, taking into account the statutes of limitations of administrative or judicial actions.
The personal data provided in the phase leading to the formalisation of the business relationship or the contracting of a product or service, will be kept by Cajasur for a maximum of six months, unless a longer period is determined in the request. Nevertheless, if you wish, you have the right to request the effective removal of your data in a shorter period.
As regards the video surveillance recordings, the regulations relative to Private Security applicable to Cajasur establishes a maximum data retention period of fifteen days from the date of recording, unless the competent judicial authorities or the Law Enforcement Bodies and Forces provide otherwise.
Personal data relating to communications and investigations on regulatory breaches and the fight against corruption will only be kept for as long as necessary, and in no case may this exceed ten years. If an investigation is not commenced within three months from the submission of the communication, the communication system will be abolished, unless it is in order to keep evidence of system operations and anonymously if they are not forwarded communications.
Cajasur will not disclose any of your data, unless such disclosure is carried out based either on your consent, or on a legal or contractual obligation with you, such as those listed below:
As a general rule, Cajasur does not send data transfers to other companies located or whose servers are located outside the European Economic Area. However, in those exceptional circumstances in which such international transfers do occur, Cajasur will adopt the necessary measures for these to be sent to a country or organisation that has provided the appropriate guarantees, or failing this, these can be based on legitimate principles established by regulations.
You may exercise your rights of access, rectification, opposition, cancellation, limitation, portability of your personal data, of withdrawing your consent and not be subject to automated decision-making, in accordance with the law. You may request to exercise these rights through any of the following channels, submitting your request, accompanied, if necessary, by a copy of your identification document:
In addition, if you have any claim derived from the processing of your data, you may address it to the Spanish Data Protection Agency (www.aepd.es).
Rights | Considerations and service channels |
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Last update 07/18/2024