The fine print, made clear.

1. Company information & supervision

UNITRUST Investment Bank is a trading name of UNITRUST Investment Bank N.V., registered in the Netherlands, company number 84729105, registered office Zuidas 142, 1077 AM Amsterdam. Authorised and regulated by De Nederlandsche Bank (DNB) and the Netherlands Authority for the Financial Markets (AFM) under licence number 739218.

You can verify our authorisation in the public registers of DNB and the AFM. UNITRUST does not provide services through tied agents and does not outsource client advice. Our services are offered to residents of the European Economic Area and to non-residents only where local law allows it.

2. Privacy notice

Controller: UNITRUST Investment Bank N.V., Zuidas 142, 1077 AM Amsterdam. Data Protection Officer: write to our registered office (attn. Data Protection Officer) or use the contact form and address your message to the DPO.

This notice explains how we process personal data under the EU General Data Protection Regulation (GDPR), the Dutch GDPR Implementation Act (UAVG) and sector rules that require banks to collect and keep certain information. It applies to clients, prospective clients, representatives and ultimate beneficial owners of business clients, and anyone who contacts us.

2.1 What we collect

• Identity and contact data — legal name, date of birth, nationality, residential address, e-mail address and telephone number.
• Identity-document data — document type, issuing country and expiry date. We store only the last four characters of the document number together with a keyed one-way fingerprint used to detect duplicates; we do not keep a readable copy of the full number.
• Customer due-diligence data — occupation, employer, income band, source of funds and wealth, purpose of the account, politically-exposed-person (PEP) status, sanctions-screening results and your risk classification.
• Tax data — tax residency and the last four characters of your tax identification number, for international tax reporting.
• Beneficiary data — the name, date of birth, relationship, e-mail address, address and (optionally) telephone number of the person you nominate to receive your balances if you die. If you nominate someone, please tell them that you have shared their details with us and refer them to this notice.
• Estate data — if a client dies: the date of death, death-certificate and certificate-of-inheritance references, who notified us, and the identity checks on the heirs and the beneficiary.
• Account and transaction data — IBANs, balances, payments, counterparties, references and statements.
• Communication data — messages you send through the contact form or Messages in online banking, and our replies.
• Security data — the times you sign in and records of two-step verification. We do not record IP addresses or the names of your devices or browsers, and we do not store your authenticator codes. Our hosting and authentication providers necessarily see the network address of your device while it connects; they use it only to deliver and protect the service, and we do not receive or keep it.
• Browser storage — we do not use tracking or advertising cookies. Online banking keeps your sign-in session only in the storage of the browser tab you use; it is removed when you sign out or close the tab. Your light/dark theme choice is saved on your device.

2.2 Why we use it and our legal basis

2.3 Automated decisions and profiling

When you become a client we assign a risk classification (low, medium or high) based on objective factors such as PEP status, country risk and source of funds. It determines your payment limits and how closely we monitor your account. Payments that meet review thresholds are held for a decision by a member of our compliance team — not by a machine alone. You may ask for human review of any decision, express your view and contest it.

2.4 Who receives your data

We never sell personal data. We share it only where needed: with payment schemes and correspondent banks to execute payments (SEPA and SWIFT); with our IT and hosting providers under data-processing agreements; with identity-verification and sanctions-screening providers; with auditors; and with authorities when the law requires it — including DNB, the AFM, FIU-Nederland, the Dutch Tax Administration and law-enforcement agencies.

2.5 International transfers

We store client data within the European Economic Area. Where a provider or a payment requires a transfer outside the EEA — for example a payment to a bank in the United States — we rely on an adequacy decision of the European Commission or on the Commission's standard contractual clauses with additional safeguards.

2.6 How long we keep it

2.7 Your rights

You have the right to access, rectify and — where we are not legally required to keep it — erase your data; to restrict or object to processing based on legitimate interests; to data portability; and to withdraw consent at any time. Clients can submit a request in online banking under Settings → Privacy & data; others can use the contact form. We respond within one month, extendable by two months for complex requests, and we may need to verify your identity first. Some data must be kept despite an erasure request because of the retention obligations above.

You can lodge a complaint with the Autoriteit Persoonsgegevens (Dutch Data Protection Authority), although we would welcome the chance to resolve your concern first.

3. General terms & conditions

These terms apply to every account and service of UNITRUST Investment Bank N.V. together with the product terms, the fee schedule in section 5 and the payment-services terms in section 4. If they conflict, product terms prevail over these general terms.

Article 1 — Becoming a client

1. Accounts are available to natural persons aged 18 or over and to legal entities registered in the EEA, subject to successful identification and verification under the Wwft.
2. You must provide complete and accurate information, including your source of funds and the purpose of the account, and tell us about changes — for example a new address, tax residency or nationality, or a change in PEP status — within 30 days.
3. For business clients we must identify the representatives and ultimate beneficial owners. Information from the Dutch UBO register and the Commercial Register may be used.
4. We may refuse to open an account without giving reasons where the law prevents us from explaining.

Article 2 — Your accounts

1. Each account has a Dutch IBAN and is held in euros, US dollars or pounds sterling. Balances in foreign currency are not converted unless you instruct us to.
2. Accounts may not go overdrawn. We may refuse a payment that would exceed your available balance; held funds are not available.
3. The Savings Account and Investment Cash Account are not intended for everyday payments to third parties.
4. Joint accounts and accounts for minors are not currently offered.

Article 3 — Online banking and security

1. You access online banking with your e-mail address, a personal password and two-step verification using an authenticator app. You must keep these security credentials personal and secret, keep your devices protected and up to date, and never share codes with anyone — including people who claim to be from UNITRUST.
2. A temporary password issued by us must be changed at your first sign-in. Sessions end automatically after 15 minutes of inactivity.
3. Tell us without undue delay if you suspect that someone else knows your credentials or has accessed your account (see section 10). We may block access to protect you and will tell you why unless the law forbids it.
4. We may suspend online banking for maintenance; we announce planned maintenance in advance where possible.

Article 4 — Communication

1. By agreeing to electronic communication you accept that statements, notices and changes to terms are provided electronically through online banking or by e-mail. You can ask for information on paper free of charge.
2. Secure messages are exchanged through Messages in online banking or our contact form. We will never ask for your password, authenticator codes or a transfer to a so-called safe account.
3. Your monthly statements are available in online banking. Check them and report any discrepancy promptly.

Article 5 — Interest and fees

1. Interest rates are variable unless stated otherwise, are calculated daily on the balance and paid monthly. Changes to reference-based rates may apply immediately; other changes are announced at least two months in advance.
2. Fees are listed in section 5. We show every fee and exchange rate before you confirm a transaction.

Article 6 — Changes to these terms

We give at least two months' notice of changes to these terms or our fees. If you do not agree, you may terminate the agreement free of charge before the change takes effect; otherwise you are deemed to have accepted it. Changes that are solely in your favour may apply immediately.

Article 7 — Termination

1. You can close your account at any time free of charge by sending us a message.
2. We may terminate the relationship with two months' notice. We may terminate with immediate effect where required by law or where there is fraud, a serious breach of these terms, a sanctions concern, or where you fail to provide information we are legally required to obtain.
3. On termination we transfer any remaining balance to an account in your name at another bank after deducting amounts due.

Article 8 — Liability

1. We are liable for loss caused by our failure to perform our obligations, except where the failure results from abnormal and unforeseeable circumstances beyond our control, or from obligations under EU or Dutch law.
2. We are not liable for indirect or consequential loss, except in the case of intent or gross negligence on our part.
3. Your liability for unauthorised payments is set out in section 4.

Article 9 — Beneficiary and death of the account holder

1. When you open an account you nominate one beneficiary: the person who is to receive the balances of all your UNITRUST accounts when you die. The nomination covers every account you hold with us, in every currency, including accounts opened later. You can change your beneficiary at any time by a signed instruction or a message in online banking; we verify the instruction with you and confirm every change in online banking.
2. As soon as we are notified of your death we block access to online banking, freeze your accounts and cancel payments that were awaiting review, returning any reserved amounts to the balance. Direct debits and incoming payments are not executed while the accounts are frozen. Interest continues to accrue until the balances are transferred.
3. We release the balances only after we have received and checked (a) an official death certificate (akte van overlijden or equivalent), (b) a certificate of inheritance (verklaring van erfrecht) issued by a Dutch civil-law notary, a European Certificate of Succession under Regulation (EU) No 650/2012, or an equivalent document recognised in the Netherlands, and (c) the identity of the beneficiary. We may ask for a certified translation of documents not in Dutch or English.
4. Your nomination is an instruction to us about who receives the balances. It does not override Dutch inheritance law (Book 4 of the Dutch Civil Code), a will, the rights of a surviving spouse or registered partner, or the statutory share (legitieme portie) of children. If the certificate of inheritance names other heirs or an executor (executeur), or the documents conflict with your nomination, we follow the documents and may require a joint instruction from all heirs, the executor, or a court decision before releasing any funds.
5. We transfer the balances to an account in the beneficiary’s name at UNITRUST. If the beneficiary has no account with us, we open one after completing customer due diligence under the Wwft; balances held in US dollars or pounds sterling are transferred to an account in the same currency, without conversion. If customer due diligence cannot be completed, or the beneficiary is under 18, we transfer the balances as instructed by the executor or the legal representative.
6. Every release of funds from an estate is approved by two members of staff (four-eyes principle) and recorded in our audit trail. After the transfer, the deceased’s accounts are closed. We do not charge a fee for settling an estate.
7. Where the law requires it, we provide the Dutch Tax Administration with the balances on the date of death for inheritance tax (erfbelasting). We keep the estate file for at least five years after the estate has been settled.

Article 10 — General

1. Our records, including the audit trail, serve as evidence unless you prove otherwise.
2. In addition to these terms, the General Banking Conditions (Algemene Bankvoorwaarden) of the Dutch Banking Association apply; you can request a copy at any time.
3. Dutch law applies. Disputes may be submitted to the competent court in Amsterdam or to Kifid (section 11).

4. Payment services (PSD2)

This section contains the information we must give you under the second EU Payment Services Directive (PSD2), as implemented in Title 7B of Book 7 of the Dutch Civil Code.

4.1 Authorising a payment

You authorise a payment to another person by confirming it in online banking with a new 6-digit code from your authenticator app (strong customer authentication). Each code authorises one payment only. Transfers between your own UNITRUST accounts are confirmed within your verified session. You cannot revoke a payment once we have received it, except where the payment has not yet been executed.

4.2 Unique identifier

We execute payments on the basis of the IBAN (or account number and BIC) you provide. If the identifier is incorrect, we are not liable for incorrect execution, but we will make reasonable efforts to recover the funds free of charge.

4.3 Execution times

Every transfer to an account at another bank is checked by our payments team before it is sent. Until the transfer is approved or declined, it shows as Pending in online banking and the amount is reserved in your account, so it can’t be spent twice. We decide on euro transfers within the EEA in time to meet the execution time above. Payments to other UNITRUST clients that meet our review thresholds are held in the same way.

If we decline a payment, it shows as Declined, the reserved amount is returned to your available balance straight away, and we tell you why unless the law forbids it. You can download a receipt for every payment — pending, completed or declined — from Activity in online banking.

4.4 Limits

Payments to third parties are subject to a 24-hour limit that depends on your risk classification (see section 5). You can ask for a higher limit by sending us a message; we may ask for supporting documents.

4.5 Unauthorised or incorrectly executed payments

• Notify us without undue delay, and no later than 13 months after the debit date, of any unauthorised or incorrectly executed payment.
• We refund an unauthorised payment immediately, and in any event no later than the end of the next business day after we became aware of it, unless we have reasonable grounds to suspect fraud and report those grounds to the competent authority.
• Before you notify us, you bear losses from lost or stolen credentials up to a maximum of €50 — unless you acted fraudulently or failed to meet your security obligations intentionally or with gross negligence, in which case you bear the full loss. After you notify us, you bear no further loss unless you acted fraudulently.
• Sharing authenticator codes or approving a payment at the request of a caller, texter or e-mailer is generally considered gross negligence.

4.6 Blocking

We may block your access or a payment for objectively justified reasons relating to security, suspected unauthorised or fraudulent use, or legal obligations. We will inform you, where possible before blocking and otherwise immediately afterwards, unless this would compromise security or is prohibited by law.

5. Fees, interest rates & limits

All fees are shown before you confirm a transaction. Prices include VAT where applicable; most banking services are exempt from Dutch VAT.

5.1 Fee schedule

5.2 Interest rates

AER (annual equivalent rate) shows what the interest rate would be if interest were paid and compounded once a year. We do not charge negative interest on balances.

5.3 Exchange rates

Indicative rates against the euro are shown on our website and in online banking. The rate that applies is fixed when you confirm the exchange; the 0.50% conversion fee is deducted from the converted amount and shown separately before you confirm.

5.4 Payment limits and review thresholds

6. Deposit guarantee — depositor information sheet

Eligible deposits are protected by the Dutch Deposit Guarantee Scheme (Nederlandse Depositogarantie) up to €100,000 per depositor. Investments are not deposits, are not protected by the scheme, and their value can go down as well as up — you may get back less than you invest. Exchange rates shown are indicative.

Which deposits are not covered

Deposits of financial institutions, public authorities and certain other professional parties, and deposits arising from transactions in connection with which there has been a criminal conviction for money laundering, are excluded. Investment products and financial instruments are not deposits and are not covered by the scheme.

When you open an account you receive this information sheet and we ask you to confirm receipt. Your statement shows that your deposits are eligible.

7. Investor compensation scheme

If you receive investment services from us and we are unable to return money or financial instruments that we hold or manage for you, you may be eligible for compensation under the Dutch Investor Compensation Scheme (Beleggerscompensatiestelsel), up to a maximum of €20,000 per person. The scheme does not protect you against losses from falls in the value of investments.

Cash held in the Investment Cash Account is a deposit and falls under the Deposit Guarantee Scheme in section 6, not under the Investor Compensation Scheme.

8. Anti-money laundering, sanctions & tax

8.1 Our gatekeeper role

Under the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) we must know who our clients are, understand the purpose and nature of the relationship, establish the source of funds and, where relevant, the source of wealth, and monitor transactions throughout the relationship. For politically exposed persons and clients with a higher risk profile we apply enhanced due diligence.

8.2 What this means for you

• We may ask questions about payments, deposits or your circumstances, and ask for supporting documents such as payslips, contracts, invoices or deeds of sale.
• We may delay or refuse transactions while we assess them, and freeze funds where the law requires it.
• We must report unusual transactions to the Financial Intelligence Unit Netherlands (FIU-Nederland). By law we may not tell you whether a report has been made.
• If you do not provide information we are legally required to obtain, we may have to end the relationship.

8.3 Sanctions

We screen clients, representatives, beneficial owners and payments against the sanctions lists of the European Union, the United Nations and the Netherlands under the Sanctions Act 1977 (Sanctiewet 1977). We do not provide services to sanctioned persons or for prohibited activities, and we may refuse payments involving high-risk jurisdictions identified by the Financial Action Task Force (FATF).

8.4 International tax reporting

Under the Common Reporting Standard (CRS) and the agreement between the Netherlands and the United States on FATCA, we must establish the tax residency of our clients and report accounts of foreign tax residents to the Dutch Tax Administration (Belastingdienst), which exchanges the information with the relevant tax authorities. You must tell us within 30 days if your tax residency changes. We do not give tax advice.

9. Risk disclosures

• Investment risk. The value of investments can fall as well as rise; past performance is not a reliable indicator of future results; you may get back less than you invest. Investment services are provided under the MiFID II rules, including an assessment of whether a product is suitable or appropriate for you.
• Currency risk. Balances in US dollars and pounds sterling fluctuate in value against the euro. Exchange rates on our website are indicative and change throughout the day.
• Interest-rate risk. Variable interest rates can go down as well as up.
• Bank risk. Deposits above the €100,000 guarantee limit are exposed to the risk of the bank's failure. In a resolution, the resolution authority may write down or convert certain liabilities (bail-in); covered deposits up to €100,000 are excluded from bail-in.
• Operational and cyber risk. Online services can be disrupted. Never rely on a single bank account for urgent payments without a fallback.

10. Security & fraud

10.1 What we will never do

• Ask for your password, authenticator codes, or the set-up key of your authenticator app — by phone, e-mail, text message, chat or in person.
• Ask you to move money to a “safe account”, to install remote-access software, or to approve a payment you did not start.
• Send you links that lead to a sign-in page. Always type our address yourself or use a saved bookmark.

10.2 What we do to protect you

• Two-step verification on every sign-in and a fresh code for every payment to someone else.
• Automatic sign-out after 15 minutes of inactivity; sessions are kept only in your browser tab.
• Review of large and unusual payments by our compliance team before release.
• Encryption of data in transit and at rest, strict access controls for staff, and a tamper-evident audit trail of every staff action.

10.3 Reporting fraud or lost access

If you think someone knows your password, has your device or has made payments you did not authorise, change your password immediately, sign out all other sessions in Settings and report it to us through the contact form (or Messages in online banking). Fraud reports are handled first, around the clock, and we will block access where needed. If you are a victim of a crime, also report it to the police.

11. Complaints procedure

We want to put things right. You can complain free of charge through our contact form, through Messages in online banking, or by post to UNITRUST Investment Bank N.V., attn. Complaints, Zuidas 142, 1077 AM Amsterdam.

11.1 How we handle your complaint

1. We acknowledge your complaint within 2 business days and tell you who is handling it.
2. We investigate independently of the team involved, keep you informed, and may ask for additional information.
3. For complaints about payment services we send our final response within 15 business days; in exceptional circumstances within 35 business days, in which case we explain the reason for the delay.
4. For other complaints we send our final response within 8 weeks.
5. Our final response explains our decision, any remedy, and your options if you are not satisfied.

11.2 If you are not satisfied

You can refer your complaint free of charge to the Financial Services Complaints Institute (Klachteninstituut Financiële Dienstverlening, Kifid), The Hague, generally within three months of our final response. Kifid's decisions can be binding on both parties. Alternatively, you can bring the dispute before the competent Dutch court.

Concerns about how we use your personal data can also be raised with the Autoriteit Persoonsgegevens. You may report concerns about our conduct to the AFM or DNB; they supervise UNITRUST but do not resolve individual complaints.

11.3 Learning from complaints

We record every complaint, analyse root causes and report trends to our management board and, where required, to our supervisors.