Privacy Policy

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 You provide personal data directly to us or authorize us to obtain it from a third party. A client provides information about its personnel (such as you) in connection with its use of the TxB services; or a prospective client provides information about its personnel in connection with its due diligence or application to use the TxB services. You communicate with us (e.g., by email, over the phone, by post, through our social media platforms, via your account profile or using any other method). We also record all telephone calls (as permitted and/or required under applicable laws) and record the phone number from which the call was received. You visit our website, or use our products or services. Our customers receive or send payments (e.g., when you authorize a transaction on behalf of a client, or if you are listed as a contact person in connection with a payment). We also record personal data that other banks share with us when processing payments to and from non-TxB accounts. We request personal data from third parties, whom we use to check your identity and risk profile. In particular, we use fraud prevention agencies and providers of identity verification checks. 

 Data used to verify your identity, for background checks, monitoring, due diligence and compliance data. This includes date of birth, nationality, country of residence/domicile, social security number (if applicable), documents required for anti-money laundering checks and monitoring (including a copy of your passport or national identity card), records of any required disclosures, and of restrictions on your ability to invest (such as any insider status or political exposure), and other details of your affiliations and/or of our relationship with you as necessary to enable us to meet applicable laws and regulations, including fulfilling regulatory reporting requirements and identifying any conflicts of interest. Usually, we only collect information you provide to us but we’ll verify some identity data with third parties. We sometimes collect this information from publicly available sources (which can include social media) 

 Call recordings and correspondence This can include recordings of your telephone calls and telephone number, your name, email address, your correspondence, and social media contact details. Records connected with offering and providing products and services to our clients and prospective clients This includes notes from interactions, meetings and conversations that you have with us or affiliates (including records of your instructions and to the extent permitted by law, recordings of telephone calls), records of correspondence, or other services made available electronically by us to you (including data transmitted by your browser and automatically recorded by our server). This also includes account details, records of agreements, payments, investments, trades and other transactions that contain your name or other personal data, and any identifiers that we or Goldman Sachs affiliates assign to records associated with you 

 Why we use personal data We use personal data for the following purposes and as otherwise described in this Privacy Policy or at the time of collection: To meet our legal obligations We use personal data to help us comply with the relevant laws and regulations that apply to us and our products and services, including laws and regulations which relate to: 

 the provision of corporate banking services; • anti-money laundering, terrorist financing and the prevention and detection of unlawful acts and criminal activity - this includes performing prudential and regulatory compliance checks on an ongoing basis, account and transaction monitoring, transaction reporting, monitoring our management of client accounts and client interactions; • complying with requests from public authorities, regulators, governmental bodies or law enforcement agencies, and investigating and preventing fraud and other crime; • meeting our regulatory record keeping obligations; • third party access (for example, in relation to powers of attorney); and • taxation – this includes tax reporting and making disclosures to, and complying with requests from tax authorities. When using personal data is necessary for our legitimate business interests We use personal data where it is within our legitimate business interests to do so. The table below includes details of our legitimate interests to use personal data, but in each case we may have other legal reasons for using it, for example, to meet our legal obligations and ensure appropriate documentation of compliance, to fulfil our rights or obligations under a contract, or to establish, exercise or defend our legal claims.