US Privacy Policy

NWMSI and its US-based subsidiaries, divisions, and affiliates (sometimes referred to as “Company,” “us,” “we,” or “our”) adopted this privacy policy (“Policy”) to describe our policies and practices concerning the personal information we collect about individuals through online and offline channels. 

This Policy, more specifically, is intended to provide individuals with information about how we collect, use, disclose, retain, and safeguard personal information we gather about them such as through the:

• Use of our websites, including mobile websites, applications (collectively, the “Site”)
• Visits to our offices or attendance at one of our events
• Phone and email communications
• Social media interactions, such as through LinkedIn and YouTube
• Viewing our online advertisements

It also describes options individuals may have concerning their personal information. 

Please read this Policy carefully before using the Site or submitting personal information to us. By accessing or visiting the Site, you indicate your understanding that the collection, use, disclosure, and retention of your personal information is subject to the terms of this Policy and our Terms of Use. Except as otherwise noted, any capitalized terms not defined in the Policy have the meaning set forth in the Terms of Use. If you do not consent to the collection, use, disclosure, and retention of your personal information as described in this Policy, please do not provide us with such information. This Policy does not apply to third-party websites accessible through our Site or other applications.

From time to time, we may change our privacy policies. We will notify you of any material changes to our Policy by posting an updated copy on our website. Please check our Site periodically for updates. Your continued use of the Site after the effective date means that the collection, use, and sharing of your personal information is subject to the updated Policy.

As described below, we may collect the following categories of personal information (“PI” or “personal information”).  We may add to the categories of PI we collect and the purpose(s) for which we collect and use it. In those cases, we will inform and update this section of the Policy.

• Identifiers – such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, or other similar identifiers.
• Other elements – such as name, signature, characteristics or description, address, telephone number, education, bank account number, or credit card number.
• Characteristics of protected classifications under California or federal law – such as race, religion, and age.
• Education information – this means  information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
• Internet or other electronic network activity –such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement; online and social media information and activity based on your interaction with us on our websites applications and social media profiles, including for example, your Internet Protocol (IP) address, device information, location coordinates, your communications with us and any information or content you visited or downloaded.
• Biometric information – such as an individual’s physiological, biological, or behavioral characteristics used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. 
• Geolocation data – such as location information while using one of our apps.
• Audio, electronic, visual, thermal, olfactory, or similar information – such as identifiable information obtained about you from voicemail messages, while speaking with our service representatives, including on the telephone; visual images captured by video cameras and personal appearance (such as copies of identity cards or surveillance camera images).
• Professional or employment-related information – such as information on job applications, information needed during onboarding for payroll and benefits, and information needed for evaluating performance.
• Sensitive Information - Sensitive information means a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious beliefs; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health, and data related to citizenship or immigration status.
• Other - Politically Exposed Person (PEP) details; criminal records; and financial information, including account and transactional information and history.

We collect and use your PI for the following business or commercial purposes. We may change or add to the purposes we collect PI. In that case, we will inform you and obtain your consent, if required by law. 

• To provide information, products, or services you request.
• To process payments and transactions.
• To communicate with you. 
• To ensure accuracy of your information and to personalize communications to you. 
• To manage our recruiting efforts and employment and workforce relationships. 
• To protect the rights, property, security and safety of us, our employees, our consumers and clients, our information systems, and the public. 
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• For risk management.
• For customer onboarding.
• For customer servicing and management.
• For direct marketing and communications.
• For event and roadshow management.
• For market, product, industry or customer satisfaction research. 
• For legal compliance.
• To respond to law enforcement requests, court orders, subpoenas, governmental regulations, or other lawful processes.
• For legal proceedings including obtaining legal advice and facilitating dispute resolution, protecting, enforcing or defending our contractual and legal rights and obligations.  
• For operational purposes such as monitoring, maintaining and improving our website and applications, processes, procedures and technology; ensuring network and information security; performing general, financial and regulatory accounting and reporting, and; managing and monitoring our properties including using surveillance cameras, for security and safety purposes. 
• To address client dietary or accessibility requirements when we organize client events.
• For identification and verification purposes and to help prevent fraud or other crimes. 
• Where permitted by law, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime, to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and for international sanctions; to investigate suspected financial crimes, fraud and threats and share data between banks and with law enforcement and regulatory bodies.

• You. We may collect personal information that you provide during your interactions with us, such as through our website or mobile applications, by email, or when you communicate with us online, by phone, or at one of our locations. We may also collect information when you attend an event, or through your use of our products, services and technology. We collect information when you are an applicant for employment with us and employed by us. We also collect information through certain online tracking tools such as cookies as set out in our Cookies Policy.
• Related Entities and Affiliates. We may collect information about you from our related parties and affiliates, including joint ventures.
• Social media and related services. We may collect information from your interactions with us through social media (e.g., LinkedIn  and YouTube), consistent with your settings, from public websites as permitted by their terms of use, and from the technology you use to access our services.
• Service providers and contractors. When you obtain products and services from us, we may collect your PI from service providers and contractors who collected information about you that is needed to provide those products and services. 
• Other. While performing our services or marketing activities, we or third parties on our behalf may conduct research, identify target audiences, serve you targeted ads,  and other activities resulting in the collection of PI about you. We may also collect information from your employer or a third party acting on your behalf; any organization where you’re an ultimate beneficial owner; your agents or representatives; or third parties who provide services to you or us. We may also collect information from publicly available sources, such as the media (including social media), electoral and company registers, and online search engines.

We will only use and share your personal information for the purposes set forth herein, as required or permitted by law, or where we have your or your agent’s permission. 

Related entities, affiliates, and business partners. Your information may be shared with and processed by other NatWest Group companies, including their officers, employees, agents or directors (“Affiliates”), ,  to fulfil one or more of the purposes set out in this Policy and to lawfully carry out our business activities, including but not limited to: managing our risk, supporting our decision making processes, providing you with products and services, marketing, internal reporting, or where those companies provide service to us.  

Service providers and similar third parties. We might also share your personal information with third parties outside the NatWest Group where it’s needed to provide a product or service, for payment processing, or to fulfil a request for a service or an application for a product, including to financial institutions or intermediaries we deal with to process transactions; and for website, software, platform, cloud, data storage and other technical services. 

Vendors, suppliers, and agents. We may disclose your personal information to business partners, ad network and marketing vendors, suppliers, agents, or independent contractors providing services to support our business.

Third parties in connection with regulatory, legal or business obligations. We may disclose your personal information to law enforcement, between banks, to regulatory bodies or with other third parties as needed when required to by law, or by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world, including for trade reporting, reporting suspicious activity and complying with production and court orders, investigating suspected financial crimes, fraud and threats; to exercise or defend legal claims; or where it’s needed for a proposed sale, reorganization, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business. 

Professional advisors such as lawyers, consultants and auditors.

Third parties at your direction.  

We may transfer your information to organizations in other countries (including to other NatWest Group companies) provided that certain safeguards are applied.

The following chart lists the categories of PI we collect and the categories of third parties to whom we disclose them. For California residents whose personal information is subject to the California Consumer Privacy Act, this chart also covers our collection and disclosure of personal information during the preceding 12 months.

Cookies. As is true of most websites, we gather some PI automatically and store it in log files. Small files called "cookies" may be attached to your Web browser. These files identify your browser and save information such as passwords so that websites can recognize you. This information also may include the Internet Protocol (IP) address, browser type, language, internet service provider (ISP), referring and exit page, operating system, and date/time stamp. 

In addition to the purposes above, we use this PI to understand and analyze trends, to administer the Site, to learn about user behavior on the Site, and to gather demographic information about our user base as a whole. To monitor use of the Site and improve its quality, we may compile statistical information concerning the use of the Site through analytics services. Examples of this information may include: the number of visitors to the Site or to sections or pages within the Site, patterns of traffic flowing through the Site, length of time spent on the Site, or in sections or pages of the Site, the other sites that refer visitors to the Site, the pages of the Site that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Site. 

We also may use this PI in our marketing and advertising services. These cookies help with tasks which may include  providing relevant advertising to you, measuring its effectiveness or limiting the number of times you see it, serving you targeted advertisements across the Internet based on your interests and use of the Site, supporting our remarketing campaigns, helping with user identification, or performing analytics or engagement/audience measurement. These cookies may record your usage of the Site including the links you follow to other websites, collect information such as the details about the device you use to access the Site (e.g., your computer or mobile phone), your IP address, browser type and operating system and similar information. Some of these cookies may follow you when you leave the Site and travel to other websites. We may place some of these cookies on your device or third parties, such as our advertising partners, service providers, or social media platforms may place them when you visit the Site. Our online advertising partners or similar vendors may associate the information they collect with other personal information they or others have collected about you. If you view or click on an ad on the Site, the ad provider may get a signal that someone visited the page that displayed the ad, and they may determine it is you through the use of cookies or similar technologies. These ad providers may also use cookies or tracking technologies to manage or measure the performance of advertisements displayed or to deliver advertising to you.

See our Cookies Policy for more information and to manage your preferences. You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. Most browsers will allow you to block or refuse cookies. However, you may need to manually adjust your preferences each time you visit a site. For more information, see the Help section of your browser. Please note that if you block certain cookies, some of the services and functionalities of our Site may not work.

Social Media Sharing. This Site may offer social media sharing features or other integrated tools which let you share actions you take on this website with other media, and vice versa. These features may collect information about your IP address and which page you are visiting on our Site, and they may set a cookie or employ other tracking technologies. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. Social media sharing features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with those features are governed by the privacy policies of the companies that provide them. For more information about the purpose and scope of data collection and processing in connection with social media sharing features, please visit the privacy policies of the third parties that provide these features.

Embedded Content. The Site may contain embedded content (e.g., videos). Embedded content may place third party cookies on your device that track your online activity to enhance your experience or assess the success of their application. We have no direct control over the information these cookies collect, and you should refer to their privacy policy for additional information. 

Do Not Track. “Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you.  However, because our Site is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.

Some portions of our Site may contain links to other websites or resources outside of our Site that are neither under our control nor maintained by us. Third party integrations are websites or platforms that synchronize with our Site to provide you with additional functionality, tools, or services such as maps, sending requested information, etc. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that we are providing these links to you only as a convenience, and you agree that we are not responsible for the content of such websites. Your use of these other linked websites is subject to the respective terms of use and privacy policies located on the linked websites.

Our websites and device applications are not created for or directed at children. To our knowledge, we do not collect information online from children under 18. If you are a parent or guardian and think we have information about your child, please email the NatWest Markets Privacy Officer.

We don’t keep your information for longer than we need to. We normally keep your personal information for a defined period after your relationship with us has ended, unless we are required to keep it for longer (for example due to a court order or an investigation by law enforcement agencies or our regulators). 

In general, we retain your personal information for as long as necessary to serve our customers and comply with applicable regulations in accordance with the Company’s data retention schedule. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, collect fees, etc. or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. 

To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; and applicable legal requirements. We might, in exceptional circumstances, retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators, or where we are otherwise required to do so by applicable law.

While we use reasonable measures to protect our site and your information, the Internet is not 100% secure. The measures we use are reasonable for the type of information we collect. We cannot guarantee use of our Site is 100% secure. We encourage you to use caution when using the Internet. If you’d like to know more about the steps we’re taking to protect your information please visit our Security Center.

This Policy is governed by the laws of the State of Connecticut, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Policy shall lie exclusively with the state and federal courts within the State of Connecticut. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.

The Company operates in accordance with the laws of the U.S. When you access our Site, we may transfer the PI that we collect from you to a location outside of your jurisdiction, including the U.S. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using this Site, you acknowledge that these laws may provide a different standard of protection and you consent to the transfer of your personal data to other jurisdictions, including the U.S.  However, we will seek to ensure that a similar degree of protection is afforded to your personal information by ensuring that, where possible, we have put in place appropriate safeguards (such as standard contractual clauses approved by the European Commission) in accordance with applicable legal requirements, or otherwise transfer personal information in accordance with applicable laws, such as, where the transfer is necessary for the performance of a contract between you and us or between us and a third party in your interest, where the transfer is necessary to establish, exercise or defend legal claims, or where the transfer is made for important reasons of public interest.

If you have any questions about our processing of your personal information, you can contact nwmprivacyofficer@natwestmarkets.com, or uscolleagueservices@natwestmarkets.com (for questions relating to employment or candidate information).