Privacy Statement

1. Introduction

Blacksmith is a “Know Your Customers” (“KYC”) platform that which facilitates the KYC process by aggregating KYC data, providing customized data set and gap analysis.

In this statement, the expressions "we", "us" and "our" are a reference to ING Bank N.V. Singapore branch as represented by the Blacksmith ING Labs initiative and “you” or “your” means the partner or customer (whether individual or corporate) and includes any user authorised by such partner or customer.

If you visit our website or in any other way contact Blacksmith, we process your personal data. By ‘processing’ we mean everything we can do with this data such as collecting, recording, storing, adjusting, organizing, using, disclosing, transferring or deleting that data.

This Privacy Statement aims to explain in a simple and transparent manner what data we gather about what information we might have, what we can use it for, and when we may need to share it with others. Related details are set out in our online Terms and Conditions, which should be read alongside this Statement.

As Blacksmith is a part of ING Bank N.V., please also refer to the ING Privacy Statement located at https://www.ingwb.com/ for further information about how ING processes data and your privacy rights and obligations.

2. The type of personal data we collect

Personal data refers to any information that tells us something about you and that we can link to you. We may collect and use the following information about you:

  • Information you give us

    You may give us information about you by filling in forms on, or interacting with, Blacksmith, or by corresponding with us by phone, email or otherwise. The information you give us may include your name, address, email address and phone number.

  • Information we collect from you

    When you use Blacksmith we may automatically collect technical information (including IP address, device details and your login information) and information about each visit you make to the Blacksmith portal (such as page response times and length of visit).

3. What we do with your personal data

We only use your personal data for legitimate business reasons. We may use the personal data about you to:

  • deliver our services to you;
  • validating interest in Blacksmith proposed goods and services;
  • improve and assess the use of Blacksmith;
  • perform research and trend analysis;
  • manage your user experience and provide you with support;
  • take action if we need to rely upon our rights under the Blacksmith Terms and Conditions;
  • contact you about Blacksmith and Blacksmith’s proposed initiatives; and
  • comply with laws and regulations, as well as any sector-specific guidelines and regulations.

4. Who we share your personal data with and why

We may disclose your personal data to third parties if required to do so under the law; our service providers and agents (including their sub-contractors) if such disclosure is required for a particular assignment for example where they help us run the technology systems that are needed to develop and operate Blacksmith and performing other services and operations (such as customer resource management and report and ) and; if we are to share your personal data to any other partners that are not our service providers we will ask for your further consent.

5. Marketing

Unless you consent, we will not use your personal data for third party marketing or third party promotional purposes.

6. Data Retention

We are only allowed to keep your personal data for as long as it’s still necessary for the purpose we initially required it.

7. Your Rights

We respect your rights to determine how your personal information is used. These rights include:

  • Right to access personal data: You have the right to ask us for an overview of your personal data that we process by sending an email to support@blacksmithkyc.com
  • Right to rectify personal data: if your personal data is not correct, you can ask us to rectify your personal data by sending an email to support@blacksmithkyc.com
  • Right to complain: Should you not be satisfied with the way we have responded to your concerns you have the right to submit a complaint to us. If you are still unhappy with our response to your complaint, you can escalate it to the Data Protection Officer at DPOSingapore@asia.ing.com

Please refer to the ING Privacy Statement for a full overview of your rights and how to exercise them.

8. Changes

We may change our Privacy Statement and the Cookie Statement from time to time. The date of the last adjustment was 16th of June 2020. Please check our Privacy Statement and Cookie Statement regularly for the latest version.