California Consumer Privacy Act

As of January 1, 2020, Rabobank has updated its Privacy Policy to include a Privacy Notice which informs you of the information that we may collect and how that information may be used in the furtherance of our business relationship. Below is the text of that Privacy Notice. The full Privacy Statements are available as follows:

Rabo AgriFinance LLC:   https://www.raboag.com/security-privacy/privacy-statement-157
Coöperative Rabobank U.A. New York Branch:   https://www.rabobankwholesalebankingna.com/privacy-statement/ 

 

Rabobank Privacy Notice

 

Rabobank Privacy Notice

This Privacy Notice serves to inform individuals of the personal information Rabo AgriFinance LLC, Coöperatieve Rabobank U.A. New York Branch, and their affiliates (collectively referred to herein as ‘Rabobank’) collect and the purpose in which that information is used.  This Privacy Notice supplements the information contained in the online Privacy Statement of Rabobank.   The link to this statement is included at the end of this Notice.    For residents of California, this notice complies with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”).

 

Your Personal Information We Collect and the Purpose (Use)

Rabobank collects personal and other information that you voluntary provide in order to enable us to deliver the products or services that you have requested, which may come from the following sources:

 

• Information we receive directly from you, including but not limited to information on applications or other forms;
• Information about your transactions with us;
• Information about your transactions with our affiliates; and
• Information from third parties including a consumer reporting agency.
• Information to satisfy our legal and regulatory obligations under anti-money laundering, terrorist financing or similar laws.

 

Additionally, the following are the general categories of personal information that we may collect and provide to third parties for the business purpose of providing financial services for you:

• Name(s)
• USPS Mailing Address and Physical Address
• Location Device – Internet Provider (IP) Address information: city, region, country internet service provider
• Email address
• Signatures
• Account Name
• Government-Issued (Federal or State) Identification and Numbers
• Phone number(s)
• Banking Information
• Credit Information
• Financial and Identity Verification Information from Credit Reporting Agencies 
• Loan Details/Business Needs and Operational Information, including transactions
• Video/Audio recordings
• Business Entity Information
• Financial Information
• Military Status
• Citizenship
• Marital Status
• Date of Birth
• Inferences on your preferences
• Personal Information from U.S. and Foreign Government Registries, as necessary
• Browser type and/or operating system
• User login/authentication data
• Functionality settings that recall user preferences 

 

We categorize the above Personal Data in the following way:

1. Identifiers — Personal unique identifiers, such as full name and federal or state issued identification numbers, including Social Security number, driver’s license number, and passport number;

2. Personal Information — Personal information, including contact details such as telephone number and address, signature, financial information (e.g., account number and balance), payment card details (e.g., credit and debit card numbers), and medical and health insurance information;

3. Characteristics of Protected Classes — Characteristics of protected classes or groups under state or federal law, such as sex, age, disability, citizenship, primary language, immigration status, and marital status;

4. Purchase Information — Purchase information, such as products and services obtained and histories of transactions;

5. Biometric Information — We do not collect Biometric Information;

6. Internet or Online Information — Internet or online information (e.g., browsing history) and information regarding interaction with our websites, applications, or advertisements;

7. Geolocation Data — We do not collect precise Geolocation data;

8. Audio and Visual Information — Audio, electronic, visual, or similar information, such as call and video recordings;

9. Employment Information — Professional or employment-related information, such as work history and prior employer, information from background checks, resumes, and personnel files;

10. Education Information — such as university attended, areas of study and references to graduation status; ,

11. Inferences — Inferences based on information about an individual to create a summary about, for example, an individual’s preferences and characteristics; and

12.  Sensitive Personal Information —

a. Social Security number, driver’s license, state identification card, or passport number;

b. 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 – We do not collect combinations of your external account and external access information that would allow us access to any of your external accounts beyond performing transactions you request;

c. Precise geolocation – We do not collect Precise geolocation;

d. Racial or ethnic origin, religious or philosophical beliefs, citizenship, or immigration status – We do not collect information on your religious or philosophical beliefs;

e. The contents of mail, email, and text messages unless we are the intended recipient of the communication;

f. Biometric information processed to uniquely identify an individual – We do not collect Biometric information; and

g. Health information, sexual orientation – We do not collect Heath information nor sexual orientation information.

 

We will not collect categories of personal information other than those disclosed in this notice.  If we intend to collect additional categories of personal information or intend to use the personal information for additional purposes that are incompatible with the disclosed purpose for which the personal information was collected, we will provide a new notice at collection and request explicit consent.

 

Personal Information does not include: Information that is lawfully made available from federal, state, or local government records and consumer information that is de-identified or aggregate consumer information. 

 

Processing (Use) of Your Personal Information

 

We process personal and other information of individuals or of entities (“Subject Entity”) with whom we have, wish to have, or previously had, a direct or indirect relationship. We also provide personal and other information to third parties, to allow us to provide products or services which you seek.

 

The table below shows, for each Personal Data category we may have collected, the categories of third parties to whom we disclosed for our business purposes information from that Personal Data category during the preceding 12 months. The table below contains brief descriptions of the categories of Personal Data and third parties.

 

Personal Data Type	Third Party Category to Whom We Disclosed Personal Data for Business Purposes
Personal Identifiers	· Rabobank divisions and subsidiaries* · Third party vendors for the business purpose of providing financial products and services, processing transactions, data hosting, supporting our everyday operations, or business management and development · Representatives of clients when legally obligated such as a power of attorney or accountant · Government agencies to fulfill both legal and regulatory requirements · Third party vendors in connection with routine or required reporting
Personal Information	· Rabobank divisions and subsidiaries* · Third party vendors for the business purpose of providing financial products and services, processing transactions, data hosting, supporting our everyday operations, or business management and development Representatives of clients when legally obligated such as a power of attorney or accountant · Government agencies to fulfill both legal and regulatory requirements · Third party vendors in connection with routine or required reporting
Characteristics of Protected Classes	· Rabobank divisions and subsidiaries* · Third party vendors for the business purpose of providing financial products and services, processing transactions, data hosting, supporting our everyday operations, or business management and development Representatives of clients when legally obligated such as a power of attorney or accountant · Government agencies to fulfill both legal and regulatory requirements · Third party vendors in connection with routine or required reporting
Purchase Information	· Rabobank divisions and subsidiaries* · Third party vendors for the business purpose of providing financial products and services, processing transactions, data hosting, supporting our everyday operations, or business management and development Representatives of clients when legally obligated such as a power of attorney or accountant · Government agencies to fulfill both legal and regulatory requirements · Third party vendors in connection with routine or required reporting
Biometric Information	· We do not collect Biometric information
Internet or Online Information	· Rabobank divisions and subsidiaries* · Third party vendors for the business purpose of providing financial products and services, processing transactions, data hosting, supporting our everyday operations, or business management and development Representatives of clients when legally obligated such as a power of attorney or accountant · Government agencies to fulfill both legal and regulatory requirements · Third party vendors in connection with routine or required reporting
Geolocation Data	· We do not collect Geolocation Data
Audio and Visual Information	· Rabobank divisions and subsidiaries* · Third party vendors for the business purpose of providing financial products and services, processing transactions, data hosting, supporting our everyday operations, or business management and development Representatives of clients when legally obligated such as a power of attorney or accountant · Government agencies to fulfill both legal and regulatory requirements · Third party vendors in connection with routine or required reporting
Employment Information	· Rabobank divisions and subsidiaries* · Third party vendors for the business purpose of providing financial products and services, processing transactions, data hosting, supporting our everyday operations, or business management and development Representatives of clients when legally obligated such as a power of attorney or accountant · Government agencies to fulfill both legal and regulatory requirements · Third party vendors in connection with routine or required reporting
Education Information	· Rabobank divisions and subsidiaries* · Third party vendors for the business purpose of providing financial products and services, processing transactions, data hosting, supporting our everyday operations, or business management and development Representatives of clients when legally obligated such as a power of attorney or accountant · Government agencies to fulfill both legal and regulatory requirements · Third party vendors in connection with routine or required reporting
Inferences	· Rabobank divisions and subsidiaries* · Third party vendors for the business purpose of providing financial products and services, processing transactions, data hosting, supporting our everyday operations, or business management and development Representatives of clients when legally obligated such as a power of attorney or accountant · Government agencies to fulfill both legal and regulatory requirements · Third party vendors in connection with routine or required reporting
Sensitive Personal Information	· Rabobank divisions and subsidiaries* · Third party vendors for the business purpose of providing financial products and services, processing transactions, data hosting, supporting our everyday operations, or business management and development Representatives of clients when legally obligated such as a power of attorney or accountant · Government agencies to fulfill both legal and regulatory requirements · Third party vendors in connection with routine or required reporting

 

* Only if the disclosure of data is reconcilable with the purpose for which the personal data were collected and if this is compliant with other requirements following from applicable privacy laws and regulations.

 

Please note: if your business or organization provides us with personal information of employees, you are under the obligation to inform your employees thereof. You may provide your employees with this privacy notice so that they may see how Rabobank treats their personal information.

We require personal and other information to understand your interests and business needs, and in order to provide you with a better consumer experience related to the products and/or services that you seek. In particular, we process personal and other information to:

• enable you to select the business interest and financial needs you seek;
• enable you to engage with business partners that help serve your mission and business goals;
• potentially improve our products and services or inform you about new services or other information that we believe you may find applicable; or, 
• enable you to register with our website and subsequently, to receive an email notification that confirms the user’s website account was successfully established.

 

The activities in which we may require personal information from an individual or from an individual associated with a Subject Entity to perform a service or deliver a product include, but are not limited to: 

 

a) Responding to an inquiry for the purposes of describing, marketing or selling goods and/or services to you.

b) Entering into a relationship to become a Rabobank client, or if you, as an individual are associated with an entity that wishes to purchase a new product or a new service.  This may include carrying out an investigation to review whether we can accept the individual or Subject Entity as a client or whether we can provide a loan.

c) Receiving a loan or business credit application submitted by an individual.

d) Enabling the establishment of loan account completed by an individual.

e) Providing access to an account established by an individual.

f) Maintaining a relationship with you and to execute payment orders received.

g) Concluding and executing agreements with suppliers and corporate clients in order to ascertain for example, that you are authorized to represent your company or to grant you access to our offices.

h) To protect your interests as well as our own.

i) Developing and improving of our products and services.

j) Engaging in promotional and marketing activities that may be of interest to you, or to better anticipate your needs.

k) Compiling statistics for analysis of visits and use of our websites.

l) Complying with legal requirements or the lawful basis of a contract or to protect your personal interests or that of our organization (such as combating or investigating fraud).

m) Complying with national and international laws and regulations for example, to initiate a (further) investigation if you have certain assets, collaboration with other parties that may pose a risk, or in the event of an unusual transaction in your account or to disclose data about you to a government or regulatory body inside or outside of the United States. 

n) For the purposes of our operations.

o) Archiving data only for the potential use in legal proceedings, or for historic, statistical or scientific purposes. 

 

We have collected information such as that described above in the last twelve months.   We may disclose personal information to our affiliates as reasonably necessary for the purposes, and on the legal basis, set out in this notice to include the processing and delivery of a product or service.  We may also disclose your personal information to third parties that are not related by common ownership or control, such as service providers, credit bureaus and other nonaffiliated third parties when required and permitted by law. 

We do not collect more personal information than is necessary for the purposes set forth above.  We require that you do not supply any other person's personal information to us, unless we prompt you to do so.

We will not collect, use, retain, and/or share your personal information for any purpose that is unrelated or incompatible with the purpose(s) for which the personal information was originally collected or processed.  We will request explicit consent if we intend to collect, use, retain, and/or share your personal information for any purpose that is unrelated or incompatible with the purpose(s) for which the personal information was originally collected or processed.

 

Sensitive Data Processing

Sensitive data are special types of personal data, as demonstrated here:

• Social Security number, 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 – We do not collect combinations of your external account and external access information that would allow us access to any of your external accounts beyond performing transactions you request;
• Precise geolocation – We do not collect Precise geolocation;
• Racial or ethnic origin, religious or philosophical beliefs, citizenship, or immigration status – We do not collect information on your religious or philosophical beliefs;
• The contents of mail, email, and text messages unless we are the intended recipient of the communication;
• Biometric information processed to uniquely identify an individual – We do not collect Biometric information; and
• Health information, sexual orientation – We do not collect Health information nor sexual orientation information.

We process your sensitive data on limited basis and only in order to fulfill requirements for providing financial services to you. We disclose your sensitive personal data to our vendors, but only to the extent they need the information in order to fulfill requirements for assisting us in providing financial services to you and only when you have been informed prior to the disclosure to our vendors.Rabobank participates in incident registers and alert systems for the financial sector and may process data concerning criminal records for that purpose. The purpose of an incident register or alert system is to protect the interests of financial institutions and their clients, e.g. by detecting fraud. Furthermore, we will process sensitive data only if so required by law, to protect your vital interests (but only where it is impossible to obtain consent first), to the extent necessary for reasons of substantial public interest, with your consent, or at your request. If you request us to record sensitive data about you, or if you disclose such data yourself, we will only process them if that is necessary for our services.

 

 

Sharing/Sale of your Personal Information

We may disclose your personal information to a third party for a business purpose.  We also may disclose your personal information to an affiliate, subject to certain limitations as described in our Privacy Statement.  At Rabobank, we do not sell your personal information to any person or to third parties nor do we share the information for the purpose of cross-contextual behavioral advertising to you. This also includes the sale or sharing of the information of minors.  

 

Other Privacy Information

Subject to Rabobank’s verification of a consumer’s identity per statutory laws and regulations, you/consumers may exercise any one of the following consumer right(s) with Rabobank listed below. When communicating your request, please select one of the following 2 options:

Submit your request to the following email address: (RaboPrivacyOffice@raboag.com) or submit your request by using the following toll free phone number to reach a Customer Connect Service Representative to assist you: (855-722-7766).

In order for Rabobank to respond to a request, you will be asked to provide, over the phone, personal information that will assist us in verifying your identity. This step is for your protection and to ensure Rabobank’s due diligence to demonstrate our commitment to preventing identify theft or fraudulent activities of individuals who may attempt to claim the identity of an individual for which they are not. Information which you might be asked to provide includes, but is not limited to, Tax ID information, address, date of birth, loan information such as account number, loan date, and transactional information. If you authorize someone else, such as an authorized agent, to request information on your behalf, Rabobank will require that you provide evidence of this authorization, prior to executing any actions on your behalf.  Rabobank reserves the right to determine in its sole discretion, information/documentation that is appropriate to evidence a consumer’s authorization of an agent.

COMPLAINTS: When you/consumer has a general question about the processing of personal data or a complaint, the above email address or phone number is applicable. Rabobank will, together with you/consumer, look for a solution.   If you remain dissatisfied with our handling of your request, you may register a complaint with a regulatory agency.

Right to Know About Personal Information Collected, Disclosed or Sold

You have the right to know about the personal and other information which we collect, use, disclose and sell. More specifically, you may request information regarding the following:

• The categories of personal information that we have collected about you;
• The categories of sources from which the personal information was collected;
• The business purpose or commercial purpose for collecting the personal information;
• The categories of third parties with whom or which the personal information is disclosed; and,
• The specific pieces of personal information we have collected about you.

Rabobank is obligated to respond to no more than two right-to-access requests in a 12-month period.

Right to Rectification

If you believe that your personal information has been processed incorrectly or incompletely, or if you believe that such processing was unnecessary, then you may file a request for editing, supplementation or removal of your personal information with the Rabobank using the one of the two methods and guidance provided earlier in this section titled “Exercising your Individual Rights”.

Right to Restriction

You may request that we temporarily restrict the personal data relating to you that we process. This means that we will temporarily process less personal data relating to you.

Please be aware that if we are able to restrict the personal data you are requesting, it will only be done within the terms of any agreement we have in place with you.

Right to Data Deletion

With certain exceptions, you have the right to request deletion of your personal information which we maintain. A verifiable consumer request, as described above, for deletion of any personal information collected will be honored by Rabobank, insofar that the request does not conflict with legal and regulatory data retention and record keeping requirements to which Rabobank must adhere. Rabobank will also request and make reasonable efforts to ensure that our service providers delete your personal information as well. 

Right to Opt-Out of Personal Information Sold

An individual has the right to instruct a business that sells personal information not to sell the consumer’s personal information – also known as the Right to Opt-Out. Once a consumer opts out, the business must honor the opt-out request for at least 12 months, but subsequently may sell the consumer’s personal information if the consumer provides his or her “express authorization”. At Rabobank, we do not sell your personal information to any person or to third parties. This also includes the sale of information of minors.  

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights (Equal Service and Price)

You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the California Consumer Privacy Act. However, Rabobank is permitted to offer different products or services if the difference is reasonably related to the value of the consumer’s data.  At this time, Rabobank does not offer different products or services based upon the value of a consumer’s data.  Should our data practices change, we will update this statement as provided later in this section titled “Changes to this Privacy Policy”.

Right to Notification of Personal Information to be Collected

When Rabobank collects an individual’s personal or other information, we must disclose through a notice at or before the time of collection:

• A list of categories of your personal information collected.
• For the categories of personal information collected, the business or commercial purpose for which it is to be used.
• If the business sells personal information, a link to opt-out of the sale of information, or a statement that no sale or disclosure was made; and
• A link to this Privacy Statement. 

As noted above, Rabobank does not sell any personal information to any person or to third parties.

Right to Data Portability

As part of your options for receiving a copy of the specific personal information we retain about you, it includes an electronic format that is in a readily usable format. 

Object to Direct Marketing

We may also disclose the following information provided below to our affiliates that are financial service providers:

Transaction and experience information from our account records, such as:

• Name
• Address
• Types of accounts you hold

Personal information we receive from you on applications or other forms, such as:

• Social security number
• Assets and liabilities
• Income

Our affiliates may use this information to make marketing solicitations to you about their products and services. You may opt-out of the disclosure to our affiliates of personal information, excluding information required for our transactions and experiences with you (i.e. information we receive from you on applications or other forms). You may also elect not to receive marketing solicitations from our affiliates. Please note that if you make this election, we will still call you and send you mail in order to service your existing relationship with us or to provide account related information (and when doing so, our mailings may include pre-printed marketing materials).   If you opt-out, it is effective within thirty days of receipt and will remain effective until you tell us to change your choice.  When you are no longer a customer, we continue to disclose your information as disclosed in this notice, unless otherwise advised by an opt-out action you have exercised.  You may contact us using option 1 or option 2 to request to opt-out status as describe above in the section titles “Exercising Your Individual Rights.”

Data Retention and Your Personal Information

Our data retention policies and procedure are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information. Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. However, we may need to hold Personal Data beyond these retention periods due to regulatory requirements or in response to a regulatory audit, investigation, or other legal matter. These requirements also apply to our third-party service providers.

 

In some cases it is not possible for us to specify in advance the periods for which your personal information will be retained. Notwithstanding the other provisions of this statement, we may retain your personal information where such retention is necessary for compliance with a legal obligation and in accordance with banking regulations to which we are subject, or in order to protect your vital interests or the vital interests of another person.

Rabo AgriFinance Privacy Statement:

https://www.raboag.com/security-privacy/privacy-statement-157

Rabobank Wholesale Banking North America Privacy Statement:
https://www.rabobankwholesalebankingna.com/privacy-statement/

 

Contact Information 

If you have questions regarding this statement, you may contact us using the following information:

Rabobank
P.O. Box 411995
Chesterfield, Missouri 63017
Attn: Customer Connect
(855) 722-7766
RaboPrivacyOffice@raboag.com

 

You may also contact our Privacy Office as identified below:
Rabobank
P.O. Box 411995
Chesterfield, Missouri 63017
Attn: Privacy Office
(855) 722-7766
RaboPrivacyOffice@raboag.com

 

Last Updated: June 26, 2023