1. General Provisions
1.1. ING Belgium respects the privacy both of internet users and any other individuals concerned, in line with the legislation and regulations in force, in particular the law dated 8 December 1992 relating to the protection of privacy and its executive orders.
Solely by accessing the website of ING Belgium SA/NV (www.ing.be), the internet user declares that he or she is familiar with the information below and authorises ING Belgium SA/NV (hereafter referred to as "ING Belgium") in line with what is outlined below, to process data of a personal nature which is transmitted via the website (including via online forms, e-mails sent to ING Belgium e-mail addresses, cookies, environment variables, etc.).
Those responsible for processing data of a personal nature relating to the individuals concerned which is transmitted via the ING Belgium website are ING Belgium SA/NV, whose head office is located at 24 avenue Marnixlaan, B-1000 Brussels (Belgium) (e-mail: email@example.com) and, where applicable, another ING Group company based in a European Union Member State as well as, where applicable, the other persons defined in point 1.3. below. Data provided at the initiative of individuals to other ING Group companies based in an EU Member State are processed by these companies in accordance with the information on the protection of privacy provided by them.
1.2. Personal data relating to individuals transmitted to ING via this company's website (www.ing.be) and/or in the context of services offered on this website (including via online forms, environment variables, etc.) is processed by ING Belgium for the purposes of request processing for internet users (in terms of accounts, payments, credits, administration of assets (investments), brokering services (in particular insurance or leasing), advertising aims and/or information regarding banking, financial, leasing, and/or insurance services), centralised customer management, marketing (incl. studies and statistics) of banking, financial, leasing and/or insurance services (unless opposed by the individual concerned), establishing an overview of the Customer, monitoring the regularity of transactions and preventing irregularities.
Data relating to individuals managed by ING's intermediaries (independent agents or brokers), including that relating to their financial transactions, is also processed by ING to ensure compliance by these intermediaries with their obligations imposed under the law, by regulations (including resulting from an FSMA/BNB circular) or contractually, including any duty of exclusivity owed to ING.
1.3. This data is not intended to be transmitted to third parties other than the persons designated for this purpose by the internet user, companies whose intervention is necessary or useful to fulfil one of ING Belgium's aims outlined above, ING Group companies based in a European Union Member State or not or insurance companies, in accordance with the provisions outlined below. It may thus be transferred to a non-EU member state whether or not this state provides an adequate level of personal data protection. ING Belgium will however not transfer data to a non-EU member state which does not provide an adequate level of protection except in the cases laid down in the law dated 8 December 1992 relating to Privacy Protection, for example ensuring that data is protected via appropriate contractual provisions.
The individuals concerned consent to the exchange of data concerning them between the companies – existing or to be created – of the ING banking, financial and insurance Group, based or not in a European Union Member State. The ING Group in the EU is a group of companies with activities in banking, insurance, leasing, asset management and/or an activity following on from those activities. This data exchange is intended to enable participating companies to carry out centralised Client management, to have a profile of Clients, to carry out studies, statistics and/or marketing actions (except e-mail advertisements and unless opposed by the individual concerned), to offer and/or to provide the aforementioned services, and to monitory the legality of the Transactions (including the prevention of irregularities).
Furthermore, the necessary data on private individuals is exchanged between ING Group companies established in another European Union Member State or elsewhere if it is required by those companies to comply with legal or regulatory provisions (including those arising from an FSMA circular) relating to their duties of care in respect of customers, the prevention of the use of the financial system for money laundering purposes or for the financing of terrorist activities and to prevent the proliferation of weapons of mass destruction. ING Bank nv (Bijlmerplein 888, NL-1102 MG Amsterdam Zuidoost, The Netherlands), acting as joint data controller, manages the interchange of data on private individuals between companies in the ING Group that is exchanged for these purposes.
An up-to-date list of ING Group companies in Belgium which take part in exchanging data is available on the ING Belgium website (www.ing.be) or from the bank on simple request. Any individual may ask ING Belgium for an updated list of ING Group companies based in a European Union Member State or in a non-Member State participating in this exchange of data concerning the private individual. These companies guarantee a high level of protection for exchanged personal data and are obliged to exercise professional discretion as regards this data.
The individuals concerned consent to the exchange of data concerning them with insurance companies outside the ING Group and based within the European Union, for which the bank acts as insurance broker (list available on request), provided it is necessary for the purposes of (where appropriate) conclusion and management of insurance (including assessment of insured risk), marketing, insurance services (except for e-mail advertising and not if the person concerned has, on request and at no expense to him/her, refused consent to direct marketing), centralising customer management and transaction monitoring (including the prevention of irregularities). All private individuals may check the data held on them and have them rectified if necessary.
Furthermore, the data concerning individuals collected by ING as an insurance broker is also passed on to the insurance companies concerned which are outside the ING Group and based in a European Union Member State (list available on request) for the purposes of assessment of the insured risk and, where applicable, the issue and management of the insurance policy, marketing their insurance products (to the exclusion of e-mail advertising), centralised customer management and monitoring the regularity of transactions (including preventing any irregularities). Any individual may request a list of insurance companies concerned.
The legal or administrative authorities or regulatory bodies, whether Belgian or international (e.g. US), may, in certain circumstances provided for by law or local regulations (inter alia for the purpose of preventing terrorism), demand, from ING or a company to which data has been transferred in accordance with the foregoing, that personal data relating to individuals be sent to it, either wholly or in part.
1.4. Any individual concerned may access the data concerning him, processed by ING, another ING Group company based in a European Union Member State or not, or an insurance company concerned (outside the ING Group) based in a European Union Member State and, if necessary, request that incorrect data be corrected or illegally processed data deleted.
The individual concerned may, at any time, on request and at no cost to him, object to:
- his personal data being processed by ING for direct marketing purposes;
- his data being exchanged between ING Group companies based in the European Union for the purposes of direct marketing;
- communication of the data concerning him which is collected by ING as an insurance broker to the insurance companies concerned (outside the ING Group) and based in a European Union Member State, for the purposes of direct marketing by these companies.
This will be taken into account as soon as possible.
1.5. Neither racial or ethnic data nor political, philosophical or religious data, nor data concerning affiliation or sexuality are processed, on the sole condition of the assumption that this results from data identifying the individual concerned (principally their first name, last name, address, nationality and profession) or that this results from a request made by the internet user in respect of themselves or a third party (for example, a request for banking, leasing and/or insurance services relating to a political party). Consequently, the individual concerned authorises this data to be processed if need be within the framework of their request, in accordance with Article 6 of the law dated 8 December 1992 relating to the protection of privacy. The categories of persons who have access to this data are ING Belgium staff members and if need be, those from companies whose intervention is necessary or from other ING Group companies based in a European Union Member State or from the insurance companies concerned (outside the ING Group) based in a European Union Member State, responsible for carrying out one or more of the transactions mentioned in points 1.2 and 1.3., as well as, where necessary, the persons specified by the internet user.
1.6. There is no legal requirement for the internet user to answer the questions asked by ING Belgium or another ING Group company based or not in a European Union Member State or an insurance company concerned (outside the ING Group) based in a European Union Member State, but not answering them may, depending on the circumstances, result in ING Belgium or another ING Group company based or not in a European Union Member State or an insurance company concerned (outside the ING Group) based in a European Union Member State being unable or refusing to enter into a (pre-)contractual relationship, to continue such a relationship or to carry out a transaction requested by the internet user concerned in respect of themselves or a third party.
1.7. Personal data relating to the individual concerned is processed with the strictest confidentiality by ING Belgium, the other ING Group companies based in a European Union Member State and companies whose intervention is necessary or useful to fulfil one of ING Belgium's aims outlined above. However, since the internet does not offer complete security, the respect for privacy can be guaranteed only if personal data is sent via communication routes explicitly indicated by ING Belgium as being protected.
"Cookies" are used in some parts of the ING Belgium website in order to provide the internet user with a better service. A cookie is a text file containing information about the behaviour of someone visiting a website. It is created by software on the website server but stored on the computer hard drive of the User. During a subsequent visit to the website, the contents of the cookie can be retrieved by the website's server.
Cookies generated by the ING Belgium website enable services to be personalised according to the areas of interest of each User, who can be identified by means of these cookies.
These cookies contain data concerning the user such as language or currency selected by the internet user, which will mean that they do not have to enter this data again each time they visit the website. They record data about the ING Belgium website pages visited by the internet user, and their aim is to provide information sessions, particularly by recording the information that the internet user provides in successive forms, as well as preventing the internet user from receiving the same advertisements or other announcements repeatedly.
User data recorded by the cookies is in addition processed by ING Belgium in order to draw up statistics or studies for the ING Belgium website and to ensure that the content of said website is improved.
These cookies are saved on the internet user’s computer for a maximum period of 12 months.
Most internet browsers are automatically configured to accept cookies. However, the internet user can configure his web browser to inform him of each cookie sent or to prevent them being saved on his hard drive. However, ING Belgium cannot guarantee the internet user access to its website in the event of him refusing to save cookies.
3. Environment variables
When the internet user visits the ING Belgium website, the following personal data, called "environment variables", are sent to ING Belgium and recorded by it via the user’s browser software:
- his TCP/IP address (identification number of the internet user’s computer on the web network),
- the brands and versions of his browser software and operating system,
- the language used by the internet user,
- all the information about the ING Belgium website pages visited by the internet user and those of other websites through which the user accessed the ING Belgium website.
This data is processed by ING Belgium so as to be able to take into account the specific configuration of the internet user’s computer so that the user can be sent the requested web pages in the correct format. In addition, they are processed with a view to drafting studies or statistics for the ING Belgium website and with a view to improving the content of the said website.