SR Dresdner Bank - International Private Bank of Samoa

Overview

SR Dresdner Bank ("SRDB", "we", "us" or "our") respects the privacy and confidentiality of the personal information entrusted to us.

As an international private bank, we are required to collect, use and, in certain circumstances, disclose personal information in order to provide banking, investment and trading services, administer client relationships, comply with applicable legal and regulatory requirements, and operate our business effectively.

This Privacy Policy explains how we collect, use, share and safeguard personal information relating to our clients, prospective clients and other persons who interact with us.

We may update this Privacy Policy from time to time to reflect changes in our business, operational practices or applicable legal and regulatory requirements. The most recent version will be made available on our website.

Collection and Use of Personal Information

We collect personal information when you establish or seek to establish a relationship with SRDB, use our banking or investment services, conduct transactions, communicate with us, or otherwise interact with the Bank.

Depending on the nature of your relationship with us and the products or services you use, the information we collect may include:

identification information, including your name, date of birth, nationality and identification documents;
residential, mailing and contact information;
employment, occupation and business information;
tax residency and tax identification information;
information relating to your financial circumstances, source of wealth and source of funds;
information regarding beneficial ownership, authorised representatives and related parties;
information contained in account applications, declarations and other documentation provided to us;
information regarding your accounts, balances and transactions;
information relating to banking, investment and trading activities undertaken through SRDB;
information received from our affiliates, service providers, professional advisers, financial institutions or other third parties where permitted by law; and
information collected as part of our customer due diligence, anti-money laundering, sanctions screening and regulatory compliance procedures.

We may use this information to:

open, maintain and administer your accounts;
process deposits, transfers, payments, investment transactions and other instructions;
provide banking, investment, custody, execution and trading services;
verify your identity and conduct customer due diligence;
assess and manage financial, credit, operational and compliance risks;
prevent and detect fraud, money laundering, terrorist financing and other unlawful activities;
comply with legal, regulatory, tax and reporting obligations;
maintain and improve our products, services, systems and client experience;
communicate with you regarding your accounts and our services; and
conduct other activities reasonably necessary for the operation of our business.

Sharing of Personal Information

In the ordinary course of providing financial services, SRDB may need to disclose personal information to its affiliates, counterparties, service providers and other third parties.

Where permitted or required by applicable law, information may be disclosed to:

SRDB affiliates and related companies;
correspondent banks, custodians, brokers, exchanges, payment processors and other financial institutions;
technology, administration, data processing and other service providers;
auditors, accountants, lawyers and other professional advisers;
credit, identity verification and compliance service providers;
regulatory, supervisory, governmental, tax and law enforcement authorities;
courts, tribunals or other persons where disclosure is required by law or legal process;
parties involved in FATCA, Common Reporting Standard ("CRS") or other applicable tax reporting arrangements; and
any other person where you have authorised us to make the disclosure or where disclosure is otherwise permitted by law.

Information may be transferred to or processed in jurisdictions outside Samoa where this is reasonably necessary to provide our services, process transactions, work with international financial counterparties or meet applicable legal and regulatory obligations.

Where we engage service providers to process personal information on our behalf, we expect such parties to handle the information appropriately and in accordance with applicable confidentiality, contractual and legal requirements.

Regulatory and Legal Disclosure

As a regulated international financial institution, SRDB may be required to disclose information notwithstanding a client's preference that such information remain confidential.

This may include disclosures necessary for:

anti-money laundering and counter-terrorism financing compliance;
sanctions and financial crime prevention;
regulatory supervision;
tax reporting and exchange of financial account information;
court orders or other lawful processes;
requests from competent governmental, regulatory or law enforcement authorities; and
other obligations imposed by applicable Samoan or international laws and regulations.

Nothing in this Privacy Policy limits SRDB's ability or obligation to make disclosures required or permitted by applicable law.

Your Choices and Rights

Subject to applicable law and SRDB's legal, regulatory and record-keeping obligations, you may contact us to:

request information regarding personal information we hold about you;
request that inaccurate or incomplete information be corrected;
update your contact or other personal information;
withdraw or amend certain marketing preferences; or
raise a question or concern regarding the way your personal information is being handled.

Certain information cannot be deleted, withheld or restricted where SRDB is required to retain, use or disclose it in order to satisfy legal, regulatory, contractual or legitimate business requirements.

Marketing Communications

From time to time, SRDB may provide information regarding products, services, market developments or other matters that we believe may be relevant to clients.

Where required, you may choose not to receive certain marketing communications by following the unsubscribe instructions contained in the communication or by contacting us.

Opting out of marketing communications will not prevent us from sending account-related, transactional, regulatory or other service communications that are necessary for our relationship with you.

Protection of Your Information

SRDB maintains physical, administrative, electronic and procedural safeguards designed to protect personal information against unauthorised access, disclosure, loss, misuse or alteration.

Access to non-public personal information is restricted to employees, officers, agents and service providers who require such information for legitimate business, operational or regulatory purposes.

While we take appropriate measures to protect personal information, no electronic transmission, storage system or method of communication can be guaranteed to be completely secure.

Retention of Personal Information

We retain personal information for as long as reasonably necessary to:

maintain and administer our relationship with you;
provide our products and services;
satisfy legal, regulatory, tax, accounting and reporting requirements;
resolve disputes or complaints;
enforce contractual rights; and
support fraud prevention, financial crime compliance and risk management.

Information may therefore be retained after an account has been closed or a client relationship has ended where required or permitted under applicable law.

Website and Digital Information

When you access SRDB's website or digital services, certain technical information may be collected automatically, including information such as your IP address, browser type, device information, access times and pages visited.

We may use cookies and similar technologies to support website functionality, maintain security, remember preferences and better understand how our digital services are used.

You may manage certain cookie settings through your browser or, where available, through the cookie preferences provided on our website.

Definitions

For the purposes of this Privacy Policy:

Affiliates means financial or non-financial entities related to SRDB through common ownership, control or other group relationships.

Personal Information means information relating to an identified or reasonably identifiable individual.

Service Providers means third-party organisations engaged by SRDB to provide operational, professional, technological, administrative, financial or other services.

Non-Affiliates means persons or organisations that are not related to SRDB through common ownership or control, including service providers, professional advisers, financial counterparties and competent authorities.