Last updated April 2025
Online Privacy Policy
For CMBEU Online Banking clients
Your privacy is important to us. Please read the following carefully.
China Merchants Bank (Europe) S.A., with registered address at 20, Boulevard Royal, L-2449 Luxembourg, Grand Duchy of Luxembourg, and registered with the Luxembourg Registre de Commerce et des Sociétés under number B239267 (“CMBEU”, “us”, “we” or “our”) is established and operates from the Grand Duchy of Luxembourg and is therefore subject to the data protection obligations set out in the EU General Data Protection Regulation 2016/679 (GDPR). To comply with the GDPR, CMBEU has implemented data protection principles on a global scale, through its Personal Data Protection Policy & Procedure (PDPP). It applies to us when we process Personal Data that belongs to the individuals mentioned in Section 1 below (‘you’).
This Online Privacy Policy explains how China Merchants Bank (Europe) S.A. (“CMBEU”, “us”, “we” or “our”) collects, shares, uses/processes and protects information when you visit or use our website, use one of the downloadable China Merchants Bank EU-Corp App (CMBEU App), and any other online services offered by CMBEU (collectively, our “online services” or “website”).
As you review this Online Privacy Policy, please be aware of the following:
· It is important that you read this privacy notice together with any privacy policy or provisions we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices, privacy policies or our other contractual business terms and is not intended to override them (the Policies).
· Our CMBEU App (defined below) may have additional terms from this policy about the privacy of your information. Please review the privacy policy for the specific online service you are using.
Information we collect
Personal Information
We may collect personal information from or about you, including, but not limited to, your name, email address, mailing address, telephone number(s), fax numbers, account numbers, user name and password. As a customer of CMBEU please refer to our General Terms and Conditions in order to have an exhaustive view of all the personal information we may collect within our business relationship with you.
As a matter of principle we do not collect Sensitive personal data (as defined by the GDPR namely, personal data relating, for instance, to your health, ethnicity, religious or political beliefs or biometric data as well as data relating to criminal convictions and offences (e.g. information on fraud).
Other information we collect online
We may also collect certain information about your use of our online services. For example, we may collect usage, viewing and technical data, including your device identifier or IP address, when you visit our website, third-party sites or open emails we send. We or our third-party partners may also collect browser information, information collected through cookies, pixel tags, web beacons and other technologies, demographic information, other information provided by you, and aggregated and de-identified data. Where permissible under applicable laws and regulations, we may also use data that we collect on an aggregate or de-identified basis for various business purposes.
Mobile Services
For your convenience, we offer you the ability to access to your account balance information. When you interact with us through our CMBEU App, we may collect information such as unique device identifiers for your mobile device, your screen resolution and other device settings, about your location, and analytical information about how you use your mobile device. We may ask your permission before collecting certain information (such as your precise geo-location information) through our CMBEU App.
Information We Collect Through Automatic Data Collection Technologies
When you download, access, and use the CMBEU App, or in some cases when visiting our website, we may use technology to automatically collect:
· Usage Details. When you access and use the CMBEU App, , we may automatically collect certain details of your access to and use of the CMBEU App, including location data, logs, and other communication data and the resources that you access and use on or through the CMBEU App.
· Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
· Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our CMBEU.
· Web Beacons. Pages of the CMBEU App and our email messages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Bank, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
How we use the information you provide
We may use the personal information you provide us to:
· provide better services and products to you and our other users,
· provide you with the information you have requested,
· verify your identity and combat fraud,
· facilitate and complete merchant-initiated or authorized transactions,
· manage your preferences,
· analyze usage of products and services to tailor content, including marketing messages, to improve, develop and provide other value-added services,
· comply with the GDPR and Luxembourg laws and regulations, relevant industry standards, and our contractual obligations, or
· for any purposes that we may specifically disclose at the time you provide or we collect your information.
We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual customers) for various business purposes, where permissible under applicable laws and regulations.
How we share your personal information
We may share the information we collect in accordance with applicable laws and regulations, and your preferences as may be applicable, including with the following:
· CMBEU affiliates to provide and improve our products and services,
· Third-party service providers we utilize to deliver our products and services,
· Companies that provide services, products or programs that you have requested; or
· Third parties in order to comply with our legal obligations, such as responding to subpoenas, court orders and other types of legal process, to enforce our account agreements, policies, and other legal rights.
We require all third parties to respect the security of your personal data and to treat it confidential and in accordance with applicable laws and regulations, including the GDPR. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
We share your personal data within the China Merchants Bank Co., Ltd., Group. This will involve transferring your data outside the European Economic Area (EEA).
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· A transfer of personal data to a third country may take place where the European Commission has decided that the third country in question ensures an adequate level of protection. Such a transfer shall not require any specific authorisation.
· EU Model clauses, when applicable, we use standardised contractual clauses in agreements with service providers to ensure personal data transferred outside of the European Economic Area complies with the GDPR.
Please contact us if you want further information on the specific safeguard used by us when transferring your personal data out of the EEA.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data (please refer to the privacy notice appearing on our web site https://luxembourg.cmbchina.com/).
Linking to third party websites
We may provide links to websites or mobile apps operated and maintained by third parties for which CMBEU has no control. Privacy policies on such linked websites or mobile apps may be different from our privacy policy and security practices. You access such linked websites or mobile apps at your own risk. You should always read the privacy policy of a linked website or mobile app before disclosing any personal information on such website or mobile app.
Security
CMBEU has several safeguards in place to protect your personal information, including use of sophisticated encryption and authentication tools, to protect the security of the information that you share with CMBEU. Please note, the information you send over the Internet may not be secure when it is transmitted to us. We highly recommend that you do not use unsecure connections, channels or sites to communicate sensitive or confidential information (such as your passwords or Social Security number) to us.
We urge you to keep your password in a safe place and not to divulge it to anyone. Also remember to log off your account and close your browser window when you have finished visiting our website. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place such as a library or Internet cafe. Please visit our Security Commitment page for additional information.
Updating your information
It is very important that your account information is accurate. If your account information is incomplete or inaccurate in anyway, please contact us using one of the following:
· China Merchants Bank (Europe) S.A.,
20, Boulevard Royal
L-2449 Luxembourg
· Email: DataPrivacyOfficer@eu.cmbchina.com
* Please do not include account details or personal information in an unencrypted e-mail message.
Updates to this Online Privacy Policy
This Online Privacy Policy is subject to change. Please review it periodically. If we make any changes, we will let you know by appropriate means such as by posting the revised policy on this page with a new “Last Updated” date. Any changes to this Online Privacy Policy will become effective when posted unless indicated otherwise. Your use of our online services following any changes to this Online Privacy Policy means that you accept the terms stated in the updated Online Privacy Policy.
Jurisdiction and Governing Law
The CMBEU App is controlled and operated by us from the Grand Duchy of Luxembourg. The laws and regulations of the Grand Duchy of Luxembourg will apply to the online services and CMBEU App.