ABN AMRO Pensioenfonds is an independent foundation responsible for the administration of the pension plans of the companies affiliated with it. In this context, ABN AMRO Pensioenfonds processes personal data relating to members and deferred members. ABN AMRO Pensioenfonds treats your personal data with due care. The processing of your personal data takes place within the context of data protection legislation and sound and controlled operational policies and processes.
In this Privacy Statement, we explain what personal data we process, why we process your personal data, how we treat your personal data and what your rights are.
This Privacy Statement forms part of the data protection policy of ABN AMRO Pensioenfonds. The data protection policy sets out the arrangements made by ABN AMRO Pensioenfonds with regard to data protection.
We only process personal data that is relevant to what we do. By personal data, we mean information that can be used to identify you, either directly or in combination with other information. This includes the following data:
Most processing operations are necessary to fulfil our obligations. To illustrate, we must comply with pension laws and regulations and the ensuing pension plan and administration rules. In this context, we process your personal data for the following purposes:
We also process personal data to protect our legitimate business interests We do this for the purpose of further improving our services (e.g. by performing statistical analyses) or to investigate suspicions of wrongdoing such as fraud.
In some cases, we need your consent to process personal data, such as your preferences concerning our newsletter in order to send you general information.
We process the data of:
We receive the personal data we need from:
We may share your personal data in the following circumstances:
Such third parties can only process your personal data for the above purposes and only in accordance with our instructions.
We do not transmit your personal data to countries outside the European Economic Area (EEA). The EEA comprises all EU countries plus Liechtenstein, Norway and Iceland.
We are committed to the protection of your personal data. For this reason, we have taken appropriate technical and organisational measures to protect your personal data against theft, loss or other unlawful use. The pension fund has also put in place management procedures to make sure that the information remains accurate and complete. We operate in accordance with these management procedures. For a summary of your pension at ABN AMRO Pensioenfonds, please go to ‘Mijn Pensioen’. You can only log in with your DigiD user name and password plus an extra code that will be sent to you by text message or via the DigiD app.
Your personal data is only retained for as long as necessary for the purpose for which it was collected or is processed. We retain some data for a longer period because we are legally required to do so. In that case, we adhere to the statutory retention period.
You can view, and in some cases change, your data in ‘Mijn Pensioen’. You can also use the contact details below to submit a request to exercise the following rights concerning your personal data. Before considering your request, we may ask you to provide further information in order to verify your identity. If we reject your request, we will give the reasons for the rejection.
You have the right to request a copy of your personal data that we have and certain information about our use of this data.
We take reasonable measures to ensure that the personal data we have about you is accurate and complete. You can request us to update or change your personal data.
You have the right to ask us to erase your personal data, for instance if we no longer need your personal data in relation to the aforementioned purposes or if you withdraw your consent for processing, or if you rightfully object to a processing operation that we carry out in order to protect our legitimate interests. A request to erase personal data is weighed up against other factors. We may, for instance, be under a legal obligation to retain your personal data.
You have the right to request us to restrict the processing of your personal data, for instance if you think that the personal data is inaccurate. The restriction will then apply for the duration of the period we require to verify the accuracy of the data. If you object to processing, you can also request that processing is restricted while you await the decision on your objection. You then have the right to the restriction of processing of personal data if that processing is unlawful but you do not wish to erase the relevant data, or if you still require the personal data but ABN AMRO Pensioenfonds no longer does.
Restriction of processing means that the relevant personal data cannot be processed. Processing is, however, permitted in the following situations:
We will inform you before a processing restriction is lifted.
You have the right to object to the processing of personal data that is based on our legitimate interest. Unless we have compelling grounds for such processing, we will no longer process your personal data on the grounds of this legal basis if you lodge an objection.
You have the right to withdraw your consent for the receipt of general communications, such as our newsletter.
Insofar as legally applicable, you have the right to receive your personal data, or, where technically feasible, to arrange for your personal data to be transmitted to a third party, in a structured, commonly used and machine-readable format. This right relates only personal data that concerns you and that you provided to us.
You have the right to lodge a complaint about the processing of your personal data with the Dutch Data Protection Authority (Dutch DPA), for example if you believe that ABN AMRO Pensioenfonds violated your privacy when using your personal data. See: https://autoriteitpersoonsgegevens.nl/nl/zelf-doen/privacyrechten/klacht-indienen-bij-de-ap
Automated decision-making is said to exist if information that has been obtained is enriched automatically (without any human intervention) using “own opinions”, following which the data subject is classified using a profile. This profile is then used as the basis for further processing (profiling).
As ABN AMRO Pensioenfonds does not make use of automated decision-making and profiling, you cannot invoke this right.
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We use analytical cookies to measure how many visitors look at our website, which sections are viewed the most and which percentage of recipients read the newsletter. The collected statistical information is used to tailor the content on the website and our newsletter to the needs of visitors or readers. We make use of Google Analytics (https://www.google.com/policies/technologies/cookies/).
We have signed a processing agreement with Google; this agreement formalises the protection of your personal data. We make no use of other Google services in combination with Google Analytics cookies and have switched off the data sharing option, so that Google does not share your data or use it for its own purposes, such as advertising. We have also agreed with Google that the last octet of your IP address is obscured before being saved by Google.
The use of Google Analytics cookies means that personal data might be transmitted to the United States. If so, the personal data is adequately protected by the EU-US Privacy Shield. You can read more about this privacy shield at www.privacyshield.gov.
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We may change this Privacy Statement and advise you to consult this page from time to time. This Privacy Statement was last updated on 2 January 2019.
Contact us by email at firstname.lastname@example.org: