PRIVACY POLICY

Banesto recognizes and respects how important personal privacy is to you.  Protecting your privacy, along with your financial assets, is at the core of our business.  We take very seriously our obligation to keep information about you and your accounts secure and confidential.  This notice provides details about the information we collect and disclose, and explains how we handle privacy as it relates to you and your account.  This notice covers Banco Español de Crédito, S.A., New York Branch (“the Bank”), and Banesto Securities, Inc. (“BSI”).

INFORMATION WE COLLECT

We collect nonpublic personal information about you from the following sources:

·         information we receive from you on applications or other forms,

·         information we collect by monitoring your use of our website,

·         information about your transactions with us or our affiliates, and

·         information we could receive from a consumer reporting agency.

We collect only the information necessary to comply with legal requirements or to deliver quality products and services to our customers.

We comply with the USA Patriot Act, Section 326.  To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.  When you open an account, we will ask for your name, address, date of birth (for individuals), and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

INFORMATION WE DISCLOSE

We do not disclose any nonpublic personal information about our customers or former customers to non-affiliated third parties, except as permitted or required by law, such as may be required to administer your accounts or in response to subpoena or other legal processes.

The law allows us to share with our affiliates any information about our transactions or experiences with you.  In addition, if you request us to buy, sell or custody securities on your behalf, then all of the information we collect will be shared freely between the Bank, BSI, and BSI’s clearing agent, but only in order that we may service your accounts.

CONFIDENTIALITY AND SECURITY

Only those persons who need it to perform their job responsibilities are authorized to have access to nonpublic personal information about you.  In addition, we maintain physical, electronic and procedural security measures that comply with federal regulations to safeguard customer information.