We treat your personal data with care
Protecting your data is extremely important to BeFrank PPI NV. The privacy statement stated below explains clearly what we do with your data and how we protect your data.
BeFrank PPI NV enters into administration agreements with employers in order that pension can be accrued for their employees. Pension capital is accumulated for employees by means of investments. These schemes are known as defined contribution schemes. Your employer usually pays the pension contribution, or a part of it. BeFrank PPI NV will sell your investments when you retire, and the proceeds are used to fund your pension. For example, this could be for a retirement pension and a partner’s pension.
BeFrank PPI NV is part of the Nationale Nederlanden Group. BeFrank PPI NV has delegated the administrative processing of the administration agreement to BeFrank NV. BeFrank PPI NV uses the services of AZL for the performance of the contracts concluded under the name of Essentiepensioen. BeFrank PPI NV monitors that the administrative procedures are performed by BeFrank NV and AZL correctly and fully and in a timely manner. This monitoring includes supervision of the security of your personal data and supervision of the processing of your personal data in accordance with the requirements under the General Data Protection Regulation (GDPR) and other legislation and regulation.
This privacy statement is formulated by the person responsible for processing your data. This is BeFrank PPI NV, for convenience referred to hereinafter as BeFrank.
I What is personal data?
When your employer purchases a product from us so that you can accrue a pension, we ask your employer for personal data such as your name and address. When you visit our websites, we also collect your personal data, such as the IP address of your computer.
Personal data are data that say something about you or that we can link to you. The collection, storage and usage of your data is known as the ‘processing’ of your personal data. This is a statutory term. BeFrank complies with legislation and regulation when processing your personal data, including the provisions of the General Data Protection Regulation (GDPR) and the Insurers’ Code of Conduct for the Processing of Personal Data (Gedragscode Verwerking Persoonsgegevens Verzekeraars). The following explains why we process your personal data and which data may be involved.
II Why do we process personal data?
We store and use your personal data only for purposes that are established with care. In most cases, we receive personal data from your employer or from you yourself, because you accrue pension with us or have accrued pension with us in the past. The law covers the processing of data that is necessary for the preparation or performance of an agreement. What this means is that we cannot help you if we have no data on you or are not allowed to store these data.
Your personal data are also used because we maintain a central customer administration, we carry out marketing activities, we aim to prevent and combat fraud, or we use the data for risk management. The law speaks of ‘processing due to legitimate interests’. This can also be in your interest, because we can help you more effectively and can combat fraud. We also process your data in order to meet our statutory obligations. Further information on the basis on which we process your personal data is provided below.
We use your data
To combat fraud
We process your personal information for risk management and to prevent and combat fraud, to protect both your security and the security of financial institutions. This means we can exchange data within Nationale-Nederlanden, with other financial institutions or with external research agencies.
To better assess risks
We process personal data for statistical analysis, in order to better assess risk and to set the prices of our products efficiently. We store data so that we have the correct information available in case of complaints or disputes.
Processing data of third parties
In some cases we record data on persons other than our customers, such as injured parties, administrators, beneficiaries and people providing collateral for a customer. We do this solely to the extent necessary for the performance of the agreement with the customer.
For your safety as well, we are obliged to ask for your personal data in order to establish your identity.
We also also obliged to share your data with the Tax & Customs Administration for the performance of certain products. The Tax & Customs Administration will then share data on persons who due to having a connection with the United States may qualify as Specified US Persons with the US tax authorities.
In exceptional cases, we are obliged to share your personal data with other parties such as supervisory authorities, the police, the courts or the intelligence services.
III What personal data do we process?
Personal data we obtain from you for the performance of the agreement. This involves:
Additional data means data that we have not obtained from you or your employer but data we have obtained from public sources. For example, consulting information in order to combat terrorism and money laundering. Or consulting information held at the Credit Registration Agency (BKR). We do this in some cases to assess a risk or to meet our statutory obligations. Further information on this is provided on this page under ‘From whom do we obtain your data?’.
We keep a record of when you contact us. To improve the quality of our service, and for training, coaching and evaluation of our employees, we record some of our telephone conversations.
Your visits to our websites and apps
IV From whom do we obtain your personal data?
If you purchase a pension and an insurance with BeFrank via your employer, we receive your data from your employer, or in some cases from the Municipal Personal Records Database (the BRP). If necessary for the administration of your pension scheme we can also obtain information from other banks and insurers. Information about your health we receive from your employer, a docter (after your permission) or the UWV.
We use public data and data from market research agencies to obtain better understanding of our customers and services. If we process personal data we have obtained from third parties, we do so only if you have given the party in question permission for this.
V To whom can we provide your personal data?
We can provide your personal data to the persons, companies and institutions stated below. We will do this only if:
We will provide your data to one or more of the parties listed below only if one of the above statements applies.
VI How we protect your personal data
We keep your data secure
We devote much time and attention to the security of our systems and the personal data that are stored within these systems. BeFrank monitors the security of personal data and the use thereof. Data traffic is continually monitored. If something goes wrong, action is taken immediately. We resolve data leaks and register such incidents. We are required to do this by law. We also notify incidents to the supervisor and to you, if necessary.
How we process personal data is supervised
We have signed a confidentiality statement
All our employees have signed a confidentiality statement and taken an oath or solemn affirmation. We treat the data you entrust to us with care. Only authorised personnel can access and process your data.
VII What are your rights?
As a customer, you have certain rights with respect to your personal data. These rights are explained below.
You have a right of inspection
This means you can inspect the personal data we have registered for you and what we use these data for. You can also find these data on your personal pension page at BeFrank (www.befrank.nl/login).
You have a right to amend, remove or restrict the use of data
You have the right to have your personal data amended if these are not correct. You also have the right to have your personal data removed if your personal data have been wrongfully processed, are no longer necessary for the purpose for which they have been processed, or because you have withdrawn your permission and BeFrank has no other valid reason for the processing of your data. You also have the right to restrict the use of your personal data. This means that you can state that your data may not be used for a temporary period. You may use this right if your personal data are not correct, have been wrongfully processed, are no longer necessary for the purpose for which they were obtained or processed, or if you object to the processing of your data and your objection is still pending with us.
You have a right to have your data transferred
This means that in certain cases you have the right to ask us to transfer the personal data you have provided to us to yourself and to another service provider.
You have a right to object
You may object to the processing of your personal data if we use your personal data for purposes other than those necessary for the performance of an agreement or for complying with a statutory obligation. We will review your objection with care and will cease to process your personal data if necessary.
VIII How long do we keep your data?
We keep your data for as long as you are our customer. We also do this for some time if you no longer have a particular product from us. In this case we apply the statutory retention period. After this, we use the data only for statistical purposes and for dealing with complaints and legal proceedings. In this case we keep the data in a closed archive.
IX Where do we process your data?
Your data are usually processed within the European Union (EU). In some cases personal data are processed outside the EU. Some of our suppliers and partners are also located outside the EU or provide these services outside the EU. The regulation in these countries does not provide the same protection of personal data as the European regulation in all cases. To ensure that your personal data are secure, we take measures by concluding agreements that stipulate similar agreements with respect to the security of personal data. In other words, as we do within the EU. We refer to these agreements as EU model contracts.
If you have a question about you personal data, please contact our customer service via firstname.lastname@example.org.
XI Do you want to have a look at of change your personal data?
You can review your personal data on your personal pension page (www.befrank.nl/login). You have a right to ask us to provide a statement of the data on you that are processed by us. You also have a right to know who has provided your personal data to BeFrank and to whom BeFrank has provided your personal data.
You can also request us in writing to provide a statement of your personal data as registered with us. We can request you to identify yourself, for instance by submitting a copy of a valid proof of your identity. If we request you to submit a copy of proof of your identity, BeFrank advises you to make your BSN invisible on this copy and to state that the copy is provided for BeFrank along with the date of submission.
If in your opinion the statement we provide contains inaccuracies or you believe that the processing of your data is wrongful, you may submit a written request to have your data amended or removed. You may also withdraw previous permission for the processing of your personal data. We will inform you as to whether we can comply with your request within four weeks of receiving it.
Please send your request to:
Attn. Customer services
1000 CB Amsterdam
If you have a complaint regarding how BeFrank deals with your personal data, you can submit your complaint to the management of BeFrank:
Attn. Customer services
1000 CB Amsterdam
You will receive a response from BeFrank within four weeks. If you are not satisfied with this response, you may refer the matter to the Financial Services Complaints Tribunal (Klachteninstituut Financiële Dienstverlening), Postbus 93257, 2509 AG The Hague, telephone 070-3338999, website www.kifid.nl.
Furthermore you can submit a complaint to the Dutch Data Protection Authority.
BeFrank is entitled to amend this privacy statement. We advise you to consult this privacy statement regularly. In any case, at such time as you provide your personal data to BeFrank.