Privacy Statement

Read our cookie statement here. In this statement, we explain how we use cookies. A cookie is a text file that is installed on your computer, tablet, or mobile phone when you access our website. There are circumstances where installing cookies is not allowed. We may need your permission to install cookies. To find out how exactly we use cookies and handle permissions, please read our cookie statement.

Given our commitment to personal data protection, APG has appointed a Data Protection Officer (DPO). The DPO sees to it that APG complies with privacy laws and regulations. He also fulfills an advisory role at the company on these matters.

All our workers have signed the APG code of conduct. This means they have committed to maintaining your personal data confidential. Only appropriately authorized staff members have clearance to process your personal data.

Your personal data is in safe hands with us. We will see to it that your personal data is kept secure at all times. To make sure of that, we have taken appropriate measures to prevent your personal data from being lost or stolen. We also ensure that unauthorized persons cannot gain access to your personal data.

When you call us, we may record your call. This is something we do to help our staff improve the quality of the service they provide, so as to empower them to serve you even better. Whenever a call will be recorded, we will let you know at the start of the call. 

Personal data is information from which you can be identified. Personal data is information relating to you from which you can be identified directly or in combination with other personal data. Personal data includes your name, address, place of residence, date of birth, telephone number and email address. But customer details, such as with the (pension) funds we work for, insurance policy details, (bank) account numbers, social security number, login or password details, and Internet Protocol (IP) addresses are also classed as personal data.

It is impossible to give an exhaustive list of all information that is considered personal data.

We are authorized to process the personal data that we use as part of our operations as a financial services provider, as a company, and as an employer because we:

• need the personal data from you for the performance of a (pension, insurance, employment, or supply) contract that we have entered into with you or to take measures requested by you to be able to enter into such a contract;
• are under an obligation to comply with a legal requirement, such as to share data with the Dutch Tax Administration, the Employee Insurance Agency (UWV) or the Social Insurance Bank (SVB), or regulatory authorities;
• have a legitimate interest to process the personal data. Legitimate interests include marketing activities or making product offers to you that are in line with products or services that you already purchase from us or from parties to which we provide our financial services. In processing your personal data, we always weigh whether or not such processing is detrimental to your (privacy) interests;
• have your explicit consent to process your personal data. You can withdraw your consent at any time. If we seek your consent, we will also make you aware of the possibility to withdraw your consent.

We obtain your personal data in various ways:

• you submit your personal data to us, for example when you:
  
  • • apply for and/or take out a product or service from us or from parties to which we provide our financial services;
    • provide a product or service to us;
    • enter into an employment contract or other contract with us;
    • visit our websites or offices and submit or leave details;
• we receive personal data on you from other parties, such as your employer, your local authority, your organization, government agencies such as the Employee Insurance Agency and the Social Insurance Bank, the Dutch Tax Administration, and the general population register. We receive these personal data on you as part of:
  • • the services we provide ourselves or on behalf of parties to whom we provide our financial services;
    • procure a product or service from you or your company or organization;
    • the employment contract or other contract you have entered into with us

We only process your personal data to the extent that this is necessary and relevant for the purposes for which we are allowed to and must process your personal data. This may mean that you are under an obligation to submit your personal data to us. This is specifically the case if:

• you have agreed to submit your personal data to us;
• we have entered into a (pension, insurance, employment, or supply) contract with you and the personal data is needed to be able to perform the contract;
• you are required by law to submit your personal data to us.

In all other situations not covered by these obligations, you are free to decide whether or not to submit your personal data to us.

If you are under an obligation to submit your personal data to us and you fail to do so, there may be consequences for you. This depends entirely on the reason why you are asked for the data, the nature of the obligation to which you are subject, and the effect that non-compliance with this obligation will have on our services and other operations.

These consequences may be that we are:

• unable to (fully) perform the contract entered into with you. In an extreme case, this may lead to you not receiving your pension, salary, benefit, or other payments;
• unable to comply with a request by you to process your personal data or forward your personal data to third parties;
• unable to meet our (legal) obligations, as a result of which we or you may face (damage) claims.

In situations where you are not under an obligation to submit your personal data to us, choosing not to submit your personal data to us will not have any consequences for you.

We share your personal data only with third parties if that is necessary, compulsory, and allowed for the work we do as a financial services provider, as a company, and as an employer.

We do so if:

• you have consented to it. As soon as you withdraw your consent, we will cease to share your data with these third parties;
• we are required by law to share your personal data with judicial authorities, Dutch Tax Administration, Employee Insurance Agency, Social Insurance Bank, regulatory authorities, or other bodies;
• this is necessary to be able to perform the (pension, insurance, employment, or supply) contract that we have entered into with you or to take measures requested by you to be able to enter into such a contract.

As part of our operations, there may be times when we need personal data concerning your health from you. We may ask you to fill in a health statement. If we have reason to do so, we may, with your consent, also ask your medical practitioner for data concerning your health. This is a special category of personal data. We process such data with extra care.

The processing of data concerning your health happens under the responsibility of a medical advisor. The medical advisor uses this data to determine the medical risk. The medical advisor and the members of his or her team are subject to a duty of confidentiality. For the performance of a contract, the medical advisor may need to forward data concerning your health to APG staff. They, too, will then be subject to a duty of confidentiality.

By signing the health statement, you consent to the medical advisor processing data concerning your health. The health statement will be kept in your medical file along with any other medical documents. The medical advisor shall manage this medical file in compliance with current regulations.

When it comes to the processing of data concerning our employees’ health, we have made arrangements with our occupational health and safety service provider on the registration of such data in cases of sickness absence and for procedures to help sick employees return to full-time work. Any such arrangements comply with the law and respect the duty of confidentiality.

If you want to know whether or not we are processing your personal data, and if so, what personal data we process, you can submit a request to us to inform you about the processing of your personal data.

If you want to have your personal data rectified because it contains errors or is incomplete, you can request that we rectify your personal data.

If you want to have your personal data erased, you can request us to do so. You can request erasure of your personal data in cases such as:

• when the personal data is no longer needed for the purpose for which it is processed;
• when you withdraw your consent for the processing of your personal data;
• when you have objected to a processing operation:
  
  • when processing is based on the grounds of necessary for the purpose of a legitimate interest of APG; or
  • for direct marketing purposes;
• when your personal data has been processed unlawfully.

You can request to cease the processing of your personal data if:

• you contest the accuracy of your personal data;
• the processing is unlawful;
• you object to the processing of your personal on grounds of legitimate interest pending resolution of the question whether APG’s legitimate interests do indeed outweigh yours.

If you have consented to the processing of your personal data or if we process your personal data for the performance of a (pension, insurance, employment, or supply) contract with you, you can request that we transfer the personal data you have submitted to us, back to you.

If you do not want us to use your personal data for direct marketing purposes, you can object to such processing operations. We will then stop processing your personal data for that purpose.

If you do not want us to use your personal data on the grounds of a legitimate interest, you can object to processing for that purpose. If your interests outweigh ours, we will then stop processing your personal data.

If you do not want us to track your behavior on our websites (any longer), you can disable tracking on our Cookie page and/or by using the delete cookies option in your internet browser settings.

If you believe that we, in using your personal data, have breached your privacy or violated data protection laws and regulations, and the General Data Protection Regulation in particular, you can lodge a complaint with the Dutch Data Protection Authority. 

If you believe that we, in using your personal data, have breached your privacy or violated data protection laws and regulations, and the General Data Protection Regulation in particular, you can bring legal action against us.  

If you are of the opinion that our processing of your personal data has resulted in (in)tangible loss or damage, you can ask us for compensation.

Given that a large part of our work consists in providing financial services on behalf of third parties, and we therefore process your personal data on the instruction of these third parties, you can also exercise the aforementioned rights directly with these third parties. These third parties include the pension fund, pension provider, or insurer with which you have entitlements that we administer on their behalf.

If you do choose to exercise your rights with us, you can do so by sending an email to: functionarisgegevensbescherming@apg.nl. You may then be asked to provide proof of identity.

This is the privacy statement of APG Groep N.V., abbreviated as APG. APG has its registered office at Oude Lindestraat 70, 6411EJ Heerlen, Netherlands. APG is registered with the Chamber of Commerce under CoC number 14099616.

If you have any questions about this privacy statement or our processing of your personal data, please contact our Data Protection Officer on functionarisgegevensbescherming@apg.nl.

APG reserves the right to amend this privacy statement. The most recent amendment is dated 30 July 2020. This Privacy page always contains the most recent version.