PRIVACY NOTICE

1. BACKGROUND AND PURPOSE OF THIS NOTICE

Protecting customers’ personal information is important to RMB Capital India Private Limited (‘RMB Capital’ and/or ‘the entity’). To do so, it follows general data privacy and protection principles.

RMB Capital has developed this customer privacy notice (notice) to enable its customers to understand how the entity collects, uses and safeguards their personal information.

RMB Capital collects personal information about its customers. This includes what customers tell the entity about themselves, what the entity learns by having a customer or when a customer makes use of a solution, as well as the choices customers make about the advice provided. This notice also outlines customers’ privacy rights and how the general data privacy and protection principles protects customers.

In terms of general data privacy and protection principles, this notice may also apply on behalf of other third parties (such as authorised agents and contractors), acting on the entity’s behalf when providing customers with solutions. If RMB Capital processes personal information for another party under a contract or a mandate, the other party’s privacy policy or notice will apply.

In this notice, “process” means how the collects, entity collects, stores, makes available, destroys, updates, discloses, or otherwise deals with customers’ personal information. As a general rule, the entity will only process customers’ personal information if this is required to deliver or offer a solution to a customer. The entity respects customers’ privacy and will treat their personal information confidentially.

RMB Capital may combine customers’ personal information and use the combined personal information for any of the purposes stated in this notice.

VERY IMPORTANT: If customers use RMB Capital’s solutions and service channels, or by accepting any agreement, contract, mandate or annexure with the or by entity utilising any solutions offered by the entity, customers agree that in order to:

conclude and fulfil contractual terms or obligations to a customer
comply with obligations imposed by law (where applicable), or
to protect or pursue customers’, the entity’s, or a third party’s legitimate interests, including offering solutions that best meet customers’ needs

customers’ personal information may be processed in RMB Capital and may be used for the purposes, in the manner, and with the appropriate controls as set out in this notice.

Where it is necessary to obtain consent for processing, the entity will seek customers’ consent separately. Customers should read the consent request carefully as it may limit their rights.

NOTE: RMB Capital may change this notice from time to time if required by law or its business practices. Where the change is material, the entity will notify customers and will allow a reasonable period for customers to raise any objections before the change is made. Please note that RMB Capital may not be able to continue a relationship with a customer or provide customers with certain solutions if they do not agree to the changes.

The latest version of the notice would be displayed on RMB Capital’s website and will apply to customers’ interactions with the entity and is available at: www.rmb.co.in.

2. RESPONSIBLE PARTIES

RMB Capital would be considered as responsible party that is responsible for determining why and how the entity will use customers’ personal information. When a customer uses a solution of the entity, the responsible party will be the company which the customer engages to take up the solution. It will be clear to customers from the documentation they receive when using or taking up a solution who the responsible party is who should be contacted in the first instance.

3. WHAT IS PERSONAL INFORMATION?

RMB Capital primarily deals with the non-retail customers. Accordingly, the personal information in this context of a customer refers to any information that identifies or specifically relates to a sponsor/promoter of RMB Capital’s counterparty. Personal information includes, but is not limited to, the following information about a customer:

marital status (married, single, divorced); national origin; age; language; birth; education
financial history (e.g., income, expenses, obligations, assets and liabilities or buying, investing, lending, insurance, banking and money management behaviour or goals and needs based on, amongst others, account transactions)
employment history and current employment status (for example when a customer applies for credit)
gender or sex (for statistical purposes as required by the law)
identifying number (e.g., an account number, identity number or passport number)
e-mail address; physical address (e.g., residential address, work address or physical location); telephone number
information about a customer’s location (e.g., geolocation or GPS location)
online identifiers; social media profiles
biometric information (e.g., fingerprints, signature or voice)
race (for statistical purposes as required by the law)
physical health; mental health; wellbeing; disability; religion; belief; conscience; culture
medical history, criminal history, employment history
personal views, preferences and opinions
confidential correspondence, or
another’s views or opinions about a customer and a customer’s name also constitute personal information

There is also a category of personal information called special personal information, which includes the following personal information about a customer:

religious and philosophical beliefs (for example where a customer enters a competition and is requested to express a philosophical view)
race (e.g., where a customer applies for a solution where the statistical information must be recorded)
ethnic origin
trade union membership
political beliefs
health including physical or mental health, disability and medical history (e.g., where a customer applies for an insurance policy)
biometric information (e.g., to verify a customer’s identity), or
criminal behaviour where it relates to the alleged commission of any offence or the proceedings relating to that offence

4. WHEN WILL RMB CAPITAL PROCESS CUSTOMERS’ PERSONAL INFORMATION?

RMB Capital may process customers’ personal information for lawful purposes relating to its business if the following circumstances apply:

it is necessary to conclude or perform under a contract the entity has with the customer or to provide the solution to the customer
applicable law requires or permits it
it is required to protect or pursue the customer’s, the entity’s or a third party’s legitimate interest
the customer has consented thereto
a person legally authorised by the customer, the law or a court, has consented thereto, or
the customer is a child and a competent person (such as a parent or guardian) has consented thereto on their behalf

5. WHEN WILL RMB CAPITAL PROCESS CUSTOMERS’ SPECIAL PERSONAL INFORMATION?

RMB Capital may process customers’ special personal information in the following circumstances, among others:

if the processing is needed to create, use or protect a right or obligation in law
if the processing is for statistical or research purposes, and all legal conditions are met
if the special personal information was made public by the customer
if the processing is required by law
if health information is processed, and the processing is to determine a customer’s insurance risk, or to comply with an insurance policy, or to enforce an insurance right or obligation, or
if the customer has consented to the processing

6. WHEN AND HOW WILL RMB CAPITAL PROCESS THE PERSONAL INFORMATION OF CHILDREN?

A child is a person who is defined as a child by Indian legislation, and who has not been recognised as an adult by the courts of India. RMB Capital processes the personal information of children if the law permits this and if any one or more of the following applies:

a person with the ability to sign legal agreements has consented to the processing, being the parent or guardian of the child
the processing is needed to create, use or protect a right or obligation in law, such as where the child is an heir in a will, a beneficiary of a trust, a beneficiary of an insurance policy or an insured person in terms of an insurance policy
the child’s personal information was made public by the child, with the consent of a person who can sign legal agreements
the processing is for statistical or research purposes and all legal conditions are met

7. WHEN, AND FROM WHERE, DOES RMB CAPITAL OBTAIN PERSONAL INFORMATION ABOUT CUSTOMERS?

RMB Capital collects information about customers:

directly from customers
based on customers’ use of entity’s solutions or service channels (such as group websites, applications ,) as applicable
based on how customers engage or interact with the entity, such as on social media, and through emails, letters, telephone calls and surveys
based on a customer’s relationship with the entity
from public sources (such as newspapers, company registers, online search engines, deed registries, public posts on social media)
from technology, such as a customer’s access and use including both assisted and unassisted interactions (e.g., on the group’s websites and mobile applications) to access and engage with the group’s platform
customers’ engagement with entity advertising, marketing and public messaging, and
from third parties that the entity interacts with for the purposes of conducting its business (such as partners, regulators and government departments or service providers)

RMB Capital collects and processes customers’ personal information at the start of, and for the duration of their relationship with the entity. The entity may also process customers’ personal information when their relationship with the entity has ended.

Depending on regulatory requirements, the entity might ask for customer consent before collecting personal information about them from third parties.

The third parties from whom RMB Capital may collect customers’ personal information include, but are not limited to, the following:

the customer’s spouse, dependents, partners, employer, joint applicant or account holder and other similar sources
people the customer has authorised to share their personal information, such as a person that makes a travel booking on their behalf, or a medical practitioner for insurance purposes
attorneys, tracing agents, debt collectors and other persons that assist with the enforcement of agreements
payment processing services providers, merchants, banks and other persons that assist with the processing of customers’ payment instructions, such as card scheme providers (including VISA or MasterCard)
insurers, brokers, other financial institutions or other organisations that assist with insurance and assurance underwriting, the providing of insurance and assurance policies and products, the assessment of insurance and assurance claims, and other related purposes
law enforcement and fraud prevention agencies, and other persons tasked with the prevention and prosecution of crime
regulatory authorities, industry ombudsmen, government departments, and local and international tax authorities
qualified information providers
trustees, executors or curators appointed by a court of law
the group’s service providers, agents and subcontractors, such as couriers and other persons the group uses to offer and provide solutions to customers
courts of law or tribunals
participating partners, whether retail or online, in the group’s customer rewards programmes
the group’s joint venture partners
marketing list providers
social media platforms, or
online search engine providers

8. REASONS RMB CAPITAL NEEDS TO PROCESS CUSTOMERS’ PERSONAL INFORMATION

The entity may process customers’ personal information for the reasons outlined below

8.1. Contract

RMB Capital may process customers’ personal information if it is necessary to conclude or perform under a contract the entity has with a customer or to provide a solution to a customer. This includes:

assess and process applications for solutions
to assess the group’s lending risks
to conduct affordability assessments
to provide a customer with solutions they have requested
to open, manage and maintain customer relationships with the group
to enable the group to deliver goods, documents or notices to customers
to communicate with customers and carry out customer instructions and requests
to respond to customer enquiries and complaints
to obtain personal information from credit bureaus regarding a customer’s credit history
to meet record-keeping obligations
to conduct market and behavioural research, including scoring and analysis to determine if a customer qualifies for solutions, or to determine a customer’s credit risk
to enable customers to participate in and make use of value-added solutions
for customer satisfaction surveys, promotional and other competitions

8.2. Law

RMB Capital may process customers’ personal information if the law requires or permits it. This includes:

to comply with legislative, regulatory, risk and compliance requirements (including directives, sanctions and rules)
to comply with voluntary and involuntary codes of conduct and industry agreements
to fulfil reporting requirements and information requests
to meet record-keeping obligations
to detect, prevent and report theft, fraud, money laundering, corruption and other crimes. This may include the processing of special personal information, such as alleged criminal behaviour or the supply of false, misleading or dishonest information when opening an account with the group, or avoiding liability by way of deception, to the extent allowable under applicable privacy laws
to conduct market and behavioural research, including scoring and analysis to determine if a customer qualifies for solutions, or to determine a customer’s credit
to enable customers to participate in and make use of value-added solutions
for customer satisfaction surveys, promotional and other competitions
to assess our lending risks
to conduct affordability assessments, credit assessments and credit scoring
to obtain personal information from credit bureaus regarding a customer’s credit history
for any other related purposes

8.3. Legitimate interest

RMB Capital may process customers’ personal information in the daily management of its business and finances and to protect the entity’s customers, employees, service providers and assets. It is to the entity’s benefit to ensure that its procedures, policies and systems operate efficiently and effectively.

RMB Capital may process customers’ personal information to provide them with the most appropriate solutions and to develop and improve solutions and the entity’s business.

RMB Capital may process a customer’s personal information if it is required to protect or pursue their, the entity’s or a third party’s legitimate interest. This includes:

to develop, implement, monitor and improve the entity’s business processes, policies and systems
to manage business continuity and emergencies
to protect and enforce the entity’s rights and remedies in the law (where applicable)
to develop, test and improve solutions for customers, this may include connecting customer personal information with other personal information obtained from third parties or public records to better understand customer needs and develop solutions that meet these needs. The entity may also consider customer actions, behaviour, preferences, expectations, feedback and financial history
tailoring solutions which would include consideration of a customer’s use of third-party products, goods and services and marketing of appropriate solutions to the customer, including marketing on the entity’s own or other websites, mobile apps and social media
to market entity solutions to customers via various means including on entity and other websites and mobile apps including social media
to respond to customer enquiries and communications including the recording of engagements and analysing the quality of the entity’s engagements with a customer
to respond to complaints including analytics of complaints to understand trends and prevent future complaints and providing compensation where appropriate
to enforce and collect on any agreement when a customer is in default or breach of the terms and conditions of the agreement, such as tracing the customer, or to institute legal proceedings against the customer. In such a scenario, the entity may aggregate the contact details provided to any of the companies in the entity to determine the customer’s most accurate contact details in order to enforce or collect on any agreement the customer has with the group
to meet record-keeping obligations
to fulfil reporting requirements and information requests
to comply with voluntary and involuntary codes of conduct and industry agreements
to detect, prevent and report theft, fraud, money laundering, corruption and other crimes. This may include the processing of special personal information, such as alleged criminal behaviour or the supply of false, misleading or dishonest information when opening an account with the group, or avoiding liability by way of deception, to the extent allowable under applicable privacy laws
to conduct market and behavioural research, including scoring and analysis to determine if a customer qualifies for solutions, or to determine a customer’s credit or insurance risk
for statistical purposes, such as market segmentation or customer segments (that is placing customers in groups with similar customers based on their personal information)
for customer satisfaction surveys, promotional and other competitions
to assess the entity’s lending risks
to obtain personal information from credit bureaus regarding a customer’s credit history
for any other related purposes

9. WHY DOES RMB CAPITAL FURTHER USE OR PROCESS CUSTOMERS’ PERSONAL INFORMATION?

At the time that RMB Capital collects personal information from a customer, it will have a reason or purpose to collect that personal information. In certain circumstances, however, the entity may use that same personal information for other purposes. The entity will only do this where there is applicable law that allows it to, and the other purposes are compatible with the original purpose/s applicable when the entity collected the customer’s personal information. The entity may also need to request a customer’s specific consent for the further processing in limited circumstances. Examples of these other purposes are included in the list of purposes set out in Section 10 below.

RMB Capital may also further use or process a customer’s personal information if:

the personal information about the customer was obtained from a public record
the customer made the personal information public, like on social media
the personal information is used for historical, statistical or research purposes, the results will not identify the customer
proceedings have started or are contemplated in a court or tribunal
it is in the interest of national security
if the entity must adhere to the law, specifically tax legislation, or
a regulatory body has exempted the processing

RMB Capital may also further use or process a customer’s personal information if the customer has consented to it .

Should a customer wish to exercise their privacy rights in terms of personal information provided to a company in the group or enquire about the centralised processing procedure, enquiries can be made through the contact details of the customer’s solution provider, as set out in the responsible parties table of this notice.

10. HOW RMB CAPITAL USES CUSTOMERS’ PERSONAL INFORMATION FOR MARKETING?

RMB Capital may use customers’ personal information to market other advisory or financial solutions to them.
If a person is not an entity customer, or in any other instances where the law requires, the entity will only market to them by electronic communications with their consent.
In all cases, a person can request the entity to stop sending marketing communications to them at any time.

11. WHEN, HOW, AND WITH WHOM DOES RMB CAPITAL SHARE CUSTOMERS’ PERSONAL INFORMATION?

In general, RMB Capital will only share customers’ personal information if any one or more of the following apply:

if the customer has consented to this
if it is necessary to conclude or perform under a contract with the customer
if there is applicable law that requires it, or
if it is necessary to protect or pursue the customer’s, the entity’s or a third party’s legitimate interest

Where required, each staff of RMB Capital may share a customer’s personal information with the following persons, which may include parties that the entity engages with as independent responsible parties, joint responsible parties or operators. These persons have an obligation to keep customers’ personal information secure and confidential:

members of the entity, any connected companies, subsidiary companies, associates, cessionaries, delegates, assignees, affiliates or successors in title and/or appointed third parties (such as its authorised agents, partners, contractors and suppliers) for any of the purposes identified in this notice
the entity’s employees, as required by their employment conditions
the customer’s spouse, dependants, partners, employer, joint applicant or account holder and other similar sources
people the customer has authorised to obtain their personal information, such as a person that makes a travel booking on the customer’s behalf, or a medical practitioner for insurance purposes
attorneys, tracing agents, debt collectors and other persons that assist with the enforcement of agreements
law enforcement and fraud prevention agencies, and other persons tasked with the prevention and prosecution of crime
regulatory authorities, industry ombudsmen, government departments, and local and international tax authorities and other persons the law requires the group to share customer personal information with
credit bureaus (if required by law at a future date)
financial services exchanges
qualification information providers
trustees, executors or curators appointed by a court of law
our service providers, agents and subcontractors, such as couriers and other persons the group uses to offer and provide solutions to customers
persons to whom the group have ceded its rights or delegated its obligations to under agreements, such as where a business is sold
courts of law or tribunals that require the personal information to adjudicate referrals, actions or applications
the general public, where customers submit content to group social media sites such as a group business’s Facebook page
the group’s joint venture partners with which it has concluded business agreements

12. WHEN AND HOW RMB CAPITAL OBTAINS AND SHARES CUSTOMERS’ PERSONAL INFORMATION FROM/WITH CREDIT BUREAUS?

The group may obtain customers’ personal information from credit bureaus for any one or more of the following reasons:

if the customer requested the group to do so, or agreed that it may do so
to verify a customer’s identity
to obtain or verify a customer’s employment details
to obtain and verify a customer’s marital status
to obtain, verify, or update a customer’s contact or address details
to obtain a credit report about a customer, which includes their credit history and credit score, when the customer applies for a credit agreement to prevent reckless lending or over-indebtedness
to determine a customer’s credit risk
to update a customer’s contact details
to conduct research, statistical analysis or system testing
to determine the source(s) of a customer’s income
to determine which solutions to promote or to offer to a customer

RMB Capital, being a Merchant Banker, is not required to share a customer’s personal information with the credit bureaus at this juncture, unless required by law in the future.

13. UNDER WHAT CIRCUMSTANCES WILL RMB CAPITAL TRANSFER CUSTOMERS’ PERSONAL INFORMATION TO OTHER COUNTRIES?

RMB Capital will only transfer a customer’s personal information to third parties in another country in any one or more of the following circumstances:

where a customer’s personal information will be adequately protected under the other country’s laws or an agreement with the third-party recipient
where the transfer is necessary to enter into, or perform, under a contract with the customer or a contract with a third party that is in the customer’s interest
where the customer has consented to the transfer, and/or
where it is not reasonably practical to obtain the customer’s consent, but the transfer is in the customer’s interest

This transfer will happen within the requirements and safeguards of applicable laws or privacy rules that bind RMB Capital.

Where possible, the party processing a customer’s personal information in another country will agree to apply the same level of protection as available by law in the customer’s country, or if the other country’s laws provide better protection, the other country’s laws would be agreed to and applied.

An example of RMB Capital transferring a customer’s personal information to another country would be when a customer makes payments if they purchase goods or services in a foreign country.

14. CUSTOMERS’ DUTIES AND RIGHTS REGARDING THE PERSONAL INFORMATION RMB CAPITAL HAS ABOUT THEM

Customers must provide RMB Capital with proof of identity when enforcing the rights below. Customers must inform RMB Capital when their personal information changes, as soon as possible after the change.

Customers warrant that when they provide the entity with personal information of their spouse, dependants or any other person, they have permission from them to share their personal information with the entity. The entity will process the personal information of the customer’s spouse, dependent or any other person which the customer has shared with it as stated in this notice.

14.1. Right to access

Customers have the right to request access to the personal information RMB Capital has about them by contacting it. This includes requesting:

confirmation that the entity holds the customer’s personal information
a copy or description of the record containing the customer’s personal information, and
the identity or categories of third parties who have had access to the customer’s personal information

RMB Capital will attend to requests for access to personal information within a reasonable time. Customers may be required to pay a reasonable fee to receive copies or descriptions of records, or information about, third parties. The entity will inform customers of the fee before attending to their request.

Customers should note that the law may limit their right to access information.

14.2. Right to correction, deletion or destruction

Customers have the right to request RMB Capital to correct, delete or destroy the personal information it has about them if it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, obtained unlawfully, or if the entity are no longer authorised to keep it. Customers must inform the entity of their request in the prescribed form that would be available on request.

RMB Capital will take reasonable steps to determine if the personal information is correct and make any correction needed. It may take a reasonable time for the change to reflect on the group’s platform/systems. The entity may request documents from the customer to verify the change in personal information.

A specific agreement that a customer has entered into with RMB Capital may determine how the customer must change their personal information provided at the time when they entered into the specific agreement. Customers must adhere to these requirements.

Where the law requires the entity to keep the personal information, it will not be deleted or destroyed upon the customer’s request. The deletion or destruction of certain personal information may lead to the termination of a customer’s business relationship with the entity.

In certain instances, a customer can give effect to this right by making use of the entity’s unassisted interfaces, e.g., using an entity app or website to correct their contact details.

14.3. Right to objection

Customers may object on reasonable grounds to the processing of their personal information where the processing is in their legitimate interest, RMB Capital’s legitimate interest or in the legitimate interest of another party.

Customers must inform the entity of their objection in the prescribed form that would be available upon request.

RMB Capital will not be able to give effect to the customer’s objection if the processing of their personal information was and is permitted by law, the customer has provided consent to the processing and the group’s processing was conducted in line with their consent, or the processing is necessary to conclude or perform under a contract with the customer.

RMB Capital will also not be able to give effect to a customer’s objection if the objection is not based upon reasonable grounds and substantiated with appropriate evidence.

The entity will provide customers with feedback regarding their objections.

14.4. Right to withdraw consent

Where a customer has provided their consent for the processing of their personal information, the customer may withdraw their consent. If they withdraw their consent, RMB Capital will explain the consequences to the customer. If a customer withdraws their consent, the entity may not be able to provide certain solutions to the customer. The entity will inform the customer if this is the case. The entity may proceed to process customers’ personal information, even if they have withdrawn their consent, if the law permits or requires it. It may a reasonable time for the change to reflect on the groups’ systems. During this time, the entity may still process the customer’s personal information.

Customers can give effect to this right by making use of the entity’s unassisted service channels, e.g., using an entity website, or through an assisted interaction to update their consent preferences.

14.5. Right to complain

Customers have a right to file a complaint with the entity or any regulator with about an alleged contravention of the protection of their personal information. The entity will address customer complaints as far as possible.

15. HOW RMB CAPITAL SECURES CUSTOMERS’ PERSONAL INFORMATION?

RMB Capital will take appropriate and reasonable technical and organisational steps to protect customers’ personal information in line with industry best practices. The entity’s security measures, including physical, technological and procedural safeguards, will be appropriate and reasonable. This includes the following:

keeping entity systems secure (such as monitoring access and usage)
storing entity records securely
controlling the access to entity premises, systems and/or records, and
safely destroying or deleting records

16. HOW LONG DOES RMB CAPITAL KEEP CUSTOMERS’ PERSONAL INFORMATION?

RMB Capital will keep customers’ personal information for as long as:

the law requires the entity to keep it
a contract between the customer and the entity requires it to keep it
the customer has consented to the entity keeping it
the entity is required to keep it to achieve the purposes listed in this notice
the entity requires it for statistical or research purposes
a code of conduct requires the entity to keep it, and/or
the entity requires it for lawful business purposes.

TAKE NOTE: The entity may keep customers’ personal information even if they no longer have a relationship with the entity or if they request the group to delete or destroy it, if the law permits or requires.

17. COOKIES

A cookie is a small piece of data that is sent (usually in the form of a text file) from a website to the user’s device, such as a computer, smartphone or tablet. The purpose of a cookie is to provide a reliable mechanism to “remember” user behaviour (keeping track of previous actions), e.g., remembering the contents of an online shopping cart, and actions the user performed whilst browsing when not signed up or logged into their online account.

The entity does not necessarily know the identity of the user of the device but does see the behaviour recorded on the device. Multiple users of the same device would not necessarily be distinguishable from one another. Cookies could, however, be used to identify the device and, if the device is linked to a specific user, the user would also be identifiable.

By using the entity websites or applications, customers agree that cookies may be forwarded from the relevant website or application to their computer or device. The cookie will enable the entity to identify that a customer has visited a website or application before and will identify the customer. The entity may also use the cookie to prevent fraud.

Please refer to the RMB Capital’s cookie notice for further information. The entity’s cookie notice is available on the entity’s website.

18. HOW RMB CAPITAL PROCESSES PERSONAL INFORMATION ABOUT PERSONS RELATED TO A JURISTIC PERSON

If a customer is a juristic person, such as a company or close corporation, the entity may collect and use personal information relating to the juristic person’s directors, officers, employees, beneficial owners, partners, shareholders, members, authorised signatories, representatives, agents, payers, payees, customers, guarantors, spouses of guarantors, sureties, spouses of sureties, other security providers and other persons related to the juristic person. These are related persons.

If customers provide the personal information of a related person to the entity, they warrant that the related person is aware that they are sharing their personal information with the entity, and that the related person has consented thereto.

RMB Capital will process the personal information of related persons as stated in this notice, thus references to “customer/s” in this notice will include related persons with the necessary amendments.

19. PERSONAL INFORMATION RMB CAPITAL MAY SHARE WITH OTHER BANKS OR REQUEST FROM OTHER FINANCIAL INSTITUTIONS

Another financial institution may ask RMB Capital, at the request of their customers or for the financial institution itself, to provide personal information about a customer’s financial position. This is done by issuing what is known as a banker’s reference and code. These banker’s references and codes are usually requested when a customer wishes to establish a relationship with the other bank or when a customer is applying for a trade account with another bank’s customer or if a customer is responding to a government tender.
This relates to personal information about the customer’s financial position. The banker’s references and codes will only be provided with a customer’s express, implied, or tacit consent.

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