Privacy

If you request a quotation, take out a savings or mortgage product, visit our website, subscribe to a newsletter, are already an existing customer, or have been in contact with us by other means, then we require your data. This data often reveals something about you or can be linked to you as an individual in various ways.

We usually ask for your name, address, e-mail address, telephone number and date of birth, but sometimes we also ask for additional information depending on the product you choose. Examples include your financial data and information about the collateral when you are taking out a mortgage, or your bank account number for the automatic deduction of the monthly mortgage payments.
We may also request data in order to verify your identity. This often occurs via iDIN or personal identification on-site by AMP.

Usually, you provide us with your data yourself, for example when taking out a product and subscribing to a newsletter. We may sometimes receive your data by different means. For instance, if you have an independent consultant, they will provide us with your data. We can also request your data from external public and semi-public sources or registers, for example from the Credit Registration Office (BKR).

We may process the following categories of personal data relating to you.

Personal data category	Example
Account data	Username, user ID and avatar
Audiovisual data	Camera and video recordings, recorded chat and telephone conversations
Professional information	Occupation, position, employer, company location
Contact data	Address, e-mail address, phone number
Due Diligence data	PEP, Sanctions list, IVR and EVR assessments
Financial data	Bank account number, transactions, income, balance data, assets, loan information, payment arrears, debts/arrears
Data concerning devices, operating systems, online behavior and preferences	IP address, MAC address, operating system, device type, version and/or brand, and cookie settings
Personal identification data	Name, address, place of residence, postcode, date of birth, place of birth, citizen service number (BSN)/tax identification number (TIN), customer number and nationality
Legal status	Relationship status, marital status and family composition
Collateral data	Address of the collateral property, purchase and contract sum, market value
Education data	Education completed and level of education achieved
Sensitive personal data	Special personal data
Criminal record data	Criminal convictions and offences

We always process your data with a purpose, and only if your data is necessary to achieve that purpose. For instance, we may use your data to:

enable you to perform an online calculation on our website. This data will then be used solely for that calculation, unless you decide to take out the product.
to maintain contact with you so we can answer your questions.
to keep records on how and when we contacted you.
to assess whether the desired product is suitable. This may also be a credit score if that is necessary.
to offer you a suitable product (including, but not limited to relationship management, promotion and marketing).
to enter into and perform an agreement with you.
to identify your products at Achmea, as well as assess your needs, satisfaction and preferences.
to better align our products with your needs.
to develop and/or improve products.
to manage, administer, develop and test IT systems.
to monitor your visit to the website and app, where applicable.
to enable you to make use of your personal environment (such as Centraal Beheer and Acier Financieringen).
to provide you with account information services and payment initiation services (PSD2).
to perform financial and balance transactions.
to assess/estimate our financial and other risks in order to protect our financial position, including through our Advanced Internal Ratings-Based (AIRB) risk model for determining financial reserves and stress testing.
to enhance your financial resilience and avoid payment arrears, for example by using models to identify potential payment issues at an early stage.
to protect your interests and ours from fraud and other types of crime.
to ensure the security of our customers, ourselves and the financial sector by reducing risks and detecting and preventing fraud. For this purpose, we conduct a customer survey prior to and during the customer relationship, and we monitor your transactions using data that you have provided, or by consulting data held by external sources. We may use analyses, risk parameters, risk profiles or other indicators for this purpose. We can also make use of our incident management system and the internal reference register, as well as the incident registration system and the external reference register (EVR) in the context of the Financial Institutions Incident Warning System (PIFI) protocol. You can find more information later on in this statement under ‘incident management/incident registration system/IVR/EVR’.
to fulfil our gatekeeper function and to combat money laundering and the financing of terrorism.
to map the sustainability and climate risks of the properties we have financed for internal purposes and regulators/regulatory reports, or to offer assistance to customers or to make offers with respect to improving the sustainability of financed collateral properties.
to be able to handle complaints and disputes.
to settle a product after the death of a customer.
to enter into and perform contracts and agreements with suppliers and other parties with whom we collaborate.
to provide to the government, if we are required to do so.
to be able to conduct audits, accountancy controls and investigations, or have them conducted.
to conduct material, formal checks and horizontal monitoring.
to conduct market, scientific or historical research, research for statistical purposes, and archiving.
to implement and improve business processes and their quality control.
to manage financial and other risks for the bank.
to prepare management reports.
for the development and validation of risk and other models.
to be able to train, coach, develop and assess our employees.
to determine our general strategy and policy.
for benchmarking purposes (for example, making a comparison with other organisations).
to process your job application.
for the electronic signing of documents.
to comply with the legislation and regulations.

You can find the complete list in the Achmea privacy statement.

If you request another product from us, then we can also take into account information about other products you have with us when assessing your application.

Usually, you provide us with your data yourself, but sometimes we receive your data by different means. In addition, we sometimes share your data or verify it with other companies, depending on the product you choose. We do not sell your personal data.

We may exchange data with the following:

other Achmea entities, components and brands, such as Centraal Beheer.
other financial institutions, in relation to:

a financial/balance transaction or in the context of combating fraud, terrorism, or money laundering;
individual savings and investment transactions of customers.

our suppliers and business partners, such as:

Quion and Stater for processing mortgage administration.
Topicus for processing savings and investment administration.
Equens and Currence IDEAL B.V. (Wero) for the settlement of online payment transactions.
iDIN for identification and verification of new and existing customers and the use of Secure Login (2FA) on the online customer portal.
AMP Group for identification and verification of new and existing customers on-site (in person).
Ockto(ID) or I-Wise for providing us with information or documents for the purpose of a mortgage application (including identification).
SurePay for verification of account/contra account holder names (IBAN Name Check).
Aryza (CreditNavigator) for preventive and special management.
I-Tek for security matters and preventive and special management.
Calcasa for the valuation of collateral.
DM Interface – Impress B.V., Koninklijke Kampert and Helm Rotaform B.V. and PostNL for the printing and mailing of postal items.
Raisin, if you have taken out a product with us through the Raisin platform.
investors in our mortgage portfolios (such as pension funds).
Cloud providers.

public and/or external registers, such as:

the Credit Registration Office (BKR, Stichting Bureau Krediet Registratie) for matters such as access to or registration (if applicable) in your BKR/credit registrations (Central Credit Information System), the BKR score, and the joint fraud prevention system known as the external reference register (EVR, Externe Verwijzingsregister) for identifying and reporting fraudsters with other Dutch financial institutions.
Foundation for the Combating of Mortgage Fraud (SFH, Stichting Fraudebestrijding Hypotheken).
Verification Identification System via the Dutch Credit Registration Office (BKR) for checking the validity of an identity document.
The banking information reference portal, for the automated provision of data requested by investigative authorities or the Tax Administration (Verwijzingsportaal Bankgegevens).
Valuation of Immovable Property Act (WOZ) register (Ministry of Finance).
The Land Registry, for consulting collateral data (Kadaster).
the Dutch Banking Association sector organisation (NVB, Nederlandse Vereniging van Banken) and the Dutch Association of Insurers (VvV, Verbond van Verzekeraars).
Chamber of Commerce (KVK, Kamer van Koophandel) for the general KVK register (Commercial Register) and UBO register.

intermediaries, mortgage consultants, service providers, appraisers, brokers, legal service providers, administrators, bailiffs, collection agencies, credit intermediaries and/or notaries.
Tax Administration (Belastingdienst).

In certain cases, we are required to share your data with a foreign tax administration. We are obliged to do this under the International Assistance (Levying of Taxes) Act (WIBB) or the Foreign Account Tax Compliance Act (FATCA). In this event, your account details will be sent to the Dutch tax administration, which will then forward them to the relevant foreign tax administration. For more information, visit the WIB or FATCA sites.

investigative authorities, such as the police, the Public Prosecution Service, and intelligence services.
regulatory authorities, such as:

the Dutch Authority for the Financial Markets (AFM, Autoriteit Financiële Markten).
De Nederlandsche Bank (DNB).
the European Central Bank (ECB).
the Netherlands Authority for Consumers and Markets (ACM, Autoriteit Consument en Markt).
the Dutch Data Protection Authority (AP, Autoriteit Persoonsgegevens).

complaint bodies, such as the Financial Services Complaints Tribunal (Kifid) and judicial authorities or lawyers in the context of a dispute.
our internal and external accountant(s) and auditors.
Homeownership Guarantee Fund (WEW, Stichting Waarborgfonds Eigen Woningen), in connection with National Mortgage Guarantee (NHG).
Statistics Netherlands (CBS, Centraal Bureau voor de Statistiek) for statistical analyses and activities.
Foundation Central Information System (CIS, Stichting Centraal Informatiesysteem) for PEP and sanctions list checks.
public sources, such as public registers, newspapers, the internet, and public social media.
municipalities, in connection with payment arrears (Early Warning Pilot). We are participating in a national pilot in which lenders and municipalities collaborate to identify mortgage payment arrears at an early stage. The aim is to prevent arrears from developing into problematic debts, and to provide timely support. We can provide limited information to your municipality. This data does not concern other financial products or your complete financial situation. You will be informed in advance about this provision of data, and may object to it at that time if you wish.
members of the Association for Debt Counselling and Social Banking (NVVK) in the context of debt assistance regarding residual debt on mortgages.
companies, for the purpose of benchmarking
heirs and executors who succeed you in your rights and obligations in the event of your death.
other parties to whom you have granted consent, such as service providers from Centraal Beheer Climate Store (Klimaatwinkel).

When you transfer money from an Achmea Bank product to a payment or other account at another financial institution, this financial institution will also receive your data.

In certain cases, we use automated decision-making and create a profile of you based on the data we have about you (profiling). You can read more about this below.

What if you take out a savings product or investment service directly online (through one of our brands)?
In this case, we will automatically process your personal data in order to evaluate certain personal aspects. We use this information to automatically assess whether or not you meet our acceptance criteria, which may directly result in automated rejection. We also obtain data from external sources or registers. We will then examine matters such as whether the information you provided about yourself is accurate and whether you are not registered externally (for example in sanctions lists). We also check for fraud indicators and make a risk assessment based on your data and other public sources and registers. This risk assessment can have repercussions for acceptance. In this regard, we can make use of profiling, which involves analysing some of your personal aspects such as your preferences, behaviour or financial situation. After you have applied for a product, the acceptance may take place automatically without human intervention. Before we decide not to offer you a product, at least one employee will conduct a substantive assessment, after which the employee will make the actual decision.

What happens if you submit a mortgage application to us yourself or through your consultant?
In this event, we are required to make an accurate and up-to-date assessment of your credit risk; in other words, we have to assess whether a mortgage is suitable for you and whether you will be capable of consistently repaying a mortgage in the long term. We do this based on data we have received from you and from external public sources and registers (such as the Credit Registration Office, BKR). Based on this information, we will endeavour to make a risk assessment in order to determine whether we can offer you a mortgage. This also involves the use of risk and other models, which automatically assess a risk and assign you a credit score. We may make use of profiling for this purpose. The credit score is merely an indication for us. The final assessment or the decision is always made by at least one authorised employee, so that there is always human intervention involved that ensures a wise, fair and unbiased decision. In this process, only profiling is involved - we do not use automated decision-making for this. If the assessment appears to reveal that you are at a higher risk, we may decide not to grant you a mortgage.

Are you a customer with us?
If so, then we are required to take measures to prevent fraud, money laundering, and the financing of terrorism (just as we do if you apply for a product). We are also required by law to know our customers well and regularly check that the information is still current. We want to be certain about who our customers are and prevent our products from being misused for fraud, money laundering or other illegal activities. For example, we monitor payment transactions and repayments in an automated manner. To ensure effectiveness, we also create risk profiles (profiling) relating to our customers, which we maintain periodically. If there is suspicion of an unusual transaction or if there is a possibility that your information is no longer up to date, our employees may contact you. In the event of a suspicion of fraud, we must report this immediately to the authorities. We also check periodically whether you are on a sanctions list. No automated decisions are ever made about you in this regard.

We also utilise profiling to tailor our marketing communications to suit your personal preferences, behaviour and interactions on our website. We process things such as your personal data, click behaviour and stated interests for this purpose. We do this on the basis of legitimate interest in order to provide you with more relevant offers and to improve our services. You can always unsubscribe from a marketing message.

If you have a mortgage with us, our risk and other models can automatically assess the risk relating to your loan and the likelihood of you experiencing a payment default. We may make use of profiling for this purpose. The reason for this is to identify and mitigate any risks for you and us as early as possible. To minimise this risk as effectively as possible, a staff member from Preventive and Special Management may assess the situation and contact you.

Provision of information in automated decision-making
We always inform you prior to an automated decision being made. If you disagree with an automated decision, you may always inquire about it or submit an objection. You may also inquire about the reasons and ask us to make a new decision. For security reasons, we may not be able to provide all or any further details regarding the manner in which we conduct the aforementioned investigations.

When we process your personal data, our intention is to do so transparently. To this end, you may make use of your legal rights, which are as follows:

the right to request your personal data from us or view it.

This enables you to check your personal data.

the right to correct your personal data if it is inaccurate.

You can ask us to amend or supplement your personal data when it is incorrect or incomplete.

the right to have your personal data deleted.

Bear in mind we may often be unable to delete your personal data, either because we still require it, or because we are required to retain it in compliance with a law.

the right to object to certain use of your personal data.

For example, you may no longer wish to receive e-mails from us with offers. You can use the unsubscribe link in our e-mails to unsubscribe, or you can call us.
You may also prefer that we do not share your personal data with SurePay for the purpose of the IBAN Name Check. Please note that we do this so that you can check whether you have entered the correct account number when transferring to your savings account.
Whatever the situation, you should always clearly indicate the reasons for your objection so that we can assess it properly.

the right to withdraw your consent or unsubscribe

If you gave us consent to use your personal data, for example for personal offers or newsletters, you may withdraw your consent at a later date. We will no longer use your personal data from that moment on. To unsubscribe from the newsletter, please use the link at the bottom of the newsletter. After that, you will no longer receive the newsletter.

the right to have your personal data transferred.

If you have provided us with personal data based on our agreement or with your consent, you can have it transferred to another party or to yourself.

the right to have the use of your personal data temporarily restricted.

An example is if you have objected to the use of your personal data. We will always assess this on its merits.

We may not always be able to comply with your request, or we may require more information to fulfil your request. In either case, we will contact you.