Privacy Statement: Advice & Mediation

 

1. Who are we?

Your personal data is processed by Alpina Financieel Zeker. This is the financial services provider that operates under the name Alpina and offers its services through www.alpina.nl and through various local branches throughout the Netherlands.

You can turn to us for financial services (such as advice and brokerage in insurance, mortgages, and pensions) as well as real estate brokerage. This privacy statement applies to both types of services provided by Alpina.

Alpina Financieel Zeker is part of Alpina Group B.V., a nationwide financial services provider. Several organizations operate within Alpina Group B.V. This privacy statement applies to the processing of personal data by Alpina Financieel Zeker (hereinafter: Alpina) and the branches operating under the Alpina name. Other organizations that are part of Alpina Group
B.V. but operate under their own names have their own privacy statements, which are available on their respective websites.

We believe it is important that your personal data is properly protected. As a financial services provider, we handle all information we receive from you with care and confidentiality. We process personal data in accordance with applicable laws and regulations, including the General Data Protection Regulation (GDPR).

In this privacy statement, we explain:

• what personal data we process;
• why we do that;
• with whom we may share data;
• how long we retain data;
• and what rights you have.

Contacting Our Data Protection Officer

Do you have any questions about this privacy statement or about how we handle your personal data? If so, please contact our Data Protection Officer at: privacy@alpinagroup.com

2. What personal data do we process?

We need personal data to provide our services properly. For example, to provide financial advice, to issue an insurance policy or mortgage, or to make a change. Sometimes we are required by law to retain or use certain data.

When we begin providing our services and you provide us with your information, we process and record that information in our systems. We also use your information when you contact us or visit our website. We usually receive this information directly from you, but sometimes we receive it from other reliable sources, such as an insurer, mortgage lender, or employer.

Depending on the service we provide for you, we may process the following types of
data:

• General and Contact Information
  We need this information so that we can contact you and verify your identity. This includes your name, address, city, email address, and phone number. We also use your date of birth, gender, and nationality. In some cases, we may request and process a copy of your identification document (only if permitted by law).
• Information about your personal situation
  In order to provide you with sound advice, we need to understand your personal situation. This includes your family composition, marital status, age, and living situation. Sometimes we also request and process information about your partner or family members, if necessary for the advice.4
• Employment and Income Information
  To provide advice on matters such as income insurance or mortgages, we need information about your employment and income. This may include your profession or job title, your employer or your own business, and details about your income or employment status.
• 
  Financial Data We process financial data to assess which products and financial solutions are best suited to your situation. This may include your bank account number, information about your assets and debts, and details about existing financial products (such as insurance policies or mortgages).
• Data in the Context of Real Estate Brokerage
  When we act as a real estate broker in the purchase, sale, rental, or appraisal of real estate, we process additional personal data. This may include data about the property (such as address and cadastral information, WOZ value, year of construction, square footage, and photos), data about the sale or rental process (such as asking price, showings, offers, and transaction details), and data necessary for drafting and executing a purchase or lease agreement. In addition, we may process information about your housing preferences or search profile, as well as data needed to assess financing options.
• Information from or through other parties
  Sometimes we receive information through other parties, such as from your employer regarding income insurance, from a pension provider regarding your pension, or from an insurer or bank.
• Sensitive Personal Data
  Sometimes we process special categories of personal data. This may include, for example, data about your health or criminal history (such as when applying for insurance). We process this data only when necessary and when there is a legal basis for doing so. In doing so, we take additional measures to protect your privacy.In certain cases, we process your Citizen Service Number (BSN), for example, when we are legally required to do so or when it is necessary to provide information on your behalf to a party that is required by law to receive the BSN.

  We process the BSN solely for the specific purpose for which it is legally permitted. If we disclose the BSN on your behalf, we do not retain it for longer than is necessary for that purpose. After that, we delete the BSN from our systems.

3. Why do we process your data?

We process your personal data to provide our services and to comply with legal obligations. Depending on the product or service you purchase from us, we use your data for the following purposes:

Consulting and Mediation

We process your data to advise you on and act as an intermediary for financial products and services, such as insurance, mortgages, income protection, and pensions. In doing so, we use your data, among other things, to:

• to assess your personal and financial situation;
• request quotes and compare products;
• to submit an application or make a change;
• to assist you with questions, changes, or claims processing;
• to maintain contact with banks, insurance companies, or other relevant parties.

Real Estate Agency

When we act as real estate agents, we process personal data to carry out brokerage assignments related to the purchase, sale, rental, or appraisal of real estate. In doing so, we use this data, among other things, to:

• organize showings and record offers;
• draft and execute purchase or lease agreements;
• maintain contact with relevant parties, such as buyers, sellers, tenants, or notaries;
• to perform appraisals or valuations.

Legal Obligations

As a financial services provider, we must comply with various laws and regulations. That is why we use personal data to:

• to verify your identity;
• to comply with the Financial Supervision Act (Wft), the Act on the Prevention
  of Money Laundering and Terrorist Financing (Wwft), and the Sanctions Act;
• report unusual transactions and monitor risks;
• share information with regulatory authorities, such as the Netherlands Authority for the Financial Markets
  (AFM), De Nederlandsche Bank (DNB), or the Dutch Data Protection Authority (AP), if required to do so.

Improving Our Services

In addition to providing our services, we also use personal data to improve our services as an organization. We do this, for example, to make our processes more efficient, improve the quality of our service, and better tailor our products to our customers’ needs. We may use your data for these purposes to:

• to analyze how customers and visitors use our services, website, and digital communications, so that we can further improve our processes, services, and customer communications;
• to evaluate complaints and feedback;
• to optimize our digital services and communications;
• to develop new products or services;
• to test and improve our systems.

Customer Relations and Marketing

We believe it’s important to stay in touch with you and keep you well informed. That’s why we may use your information to:

• to send service messages related to your product or our services;
• to inform you about changes, relevant developments, or important information regarding your product;
• to send newsletters or make offers tailored to your situation (from which you can always unsubscribe);
• to display relevant information, offers, or campaigns via online advertising platforms and other digital channels that are tailored to the products or services you purchase or have purchased from us;
• to better tailor our communications to your preferences;
• to analyze how you use our digital communications and online services, such as opening emails, clicking on links, visiting web pages, or filling out forms. We use this information to further improve our communications and services and to better tailor them to your interests.

Security and Fraud Prevention

We process personal data to prevent and investigate abuse, fraud, and other irregularities. In doing so, we may, among other things:

• record and analyze signs of fraud or abuse;
• share information with authorized employees within the Alpina Group;
• share data with other parties, such as insurers, banks, or research firms, to the extent necessary to prevent or combat fraud.

4. Why are we allowed to process your data?

Under the heading “Why do we process your data?” we have explained the purposes for which we process your data. The GDPR also requires us to explain the legal basis on which we are permitted to do so. We explain this below:

Performance of a Contract

We process your personal data to fulfill the agreement we enter into with you for our consulting, mediation, and brokerage services. This also applies to actions necessary prior to the establishment of these
services. Without your personal data, we cannot provide our services.

Compliance with Legal Obligations

We process your personal data to comply with the legal obligations that apply to us as a financial services provider. This includes obligations under the Financial Supervision Act (Wft), the Money Laundering and Terrorist Financing (Prevention) Act (Wwft), and the Sanctions Act, such as verifying your identity.

Legitimate Interest

In some cases, we process personal data based on a legitimate interest. This means that we use data when it is necessary for our business operations or to ensure the security and reliability of our services—but only if your privacy interests do not outweigh these interests. This may be the case, for example, when:

• preventing and combating fraud or abuse;
• improving our products, services, and processes;
• protecting the security of our organization and systems;
• marketing activities targeting existing customers.

In these situations, we always carefully balance our interests against your right to privacy.

Consent

In some cases, we use your data only if you have given your explicit consent. We do this only if there is no other legal basis for processing your data. You may withdraw your consent at any time. We will then stop using your data for the purposes for which you had given your consent.

5. To whom may we disclose information?

In order to provide our services effectively, we sometimes share your personal data with other parties. We do so only when necessary for the provision of our services or when required by law. We always proceed with due care and establish clear agreements with the parties we work with.

As a general rule, we process your data within the European Economic Area (EEA). We may transfer personal data to parties outside the EEA only when permitted by law. In such cases, we ensure appropriate safeguards are in place to protect your privacy, for example, by entering into (additional) contractual agreements with those parties regarding the security and use of your data. Below, you can read about the parties with whom we may share data.

External service providers

We work with other companies that assist us in providing our services. We only share the information necessary for them to perform their work. These parties are required to handle your information with care and may not use it for any other purposes. Examples include:

• mail and courier services,
• debt collection agencies,
• IT service providers,
• Expert Services,
• Appraisers, notaries, photographers, or surveying firms (real estate agencies).

Financial service providers

Depending on the services we provide, we may share your information with other financial institutions, such as insurers, mortgage lenders, or banks. We do so only if it is necessary to apply for or purchase a product or service on your behalf.
Sometimes we work with service partners who send offers or information about products on behalf of these institutions. They are responsible for how they handle your information.

When assessing an application or disbursing funds, these parties may also request information from reliable sources, such as the National Road Traffic Authority (RDW) or the Central Information System Foundation (CIS).

Collaboration with Specialized Service Providers

In specific situations, we may engage specialized third parties to support our services. In such cases, we share personal data only to the extent necessary and based on a valid legal basis. These parties may use the data only for the purpose for which we engage them.

Real Estate Platforms and Industry Associations

When we act as a real estate agent, we may share data with real estate platforms and industry organizations, such as NVM/Brainbay and Funda, for the purpose of publishing listings, registering transactions, or conducting market analyses. These parties process personal data under their own responsibility.

Government and Regulatory Authorities

Sometimes we need to share your information with government agencies. This may include, for example, the Tax and Customs Administration, the police, or the judicial authorities, or regulatory bodies such as the Netherlands Authority for the Financial Markets (AFM) or the Dutch Data Protection Authority (AP). This may also involve reports to the Financial Intelligence Unit – Netherlands (FIU-NL) under the Money Laundering and Terrorist Financing Prevention Act (Wwft). We do this only if required by law.

Online Advertising and Marketing Services

For the purposes of our marketing activities, we may share personal data with third parties who assist us in conducting and measuring online campaigns. This may involve, for example, displaying relevant advertisements or measuring the effectiveness of campaigns. Where necessary, we enter into data processing agreements or other appropriate arrangements with these third parties and ensure appropriate
safeguards for the protection of your personal data.

Divisions within the Alpina Group

The Alpina Group consists of several organizations that collaborate with one another, as needed, in the provision of services.

Personal data may be shared among organizations when necessary to provide you with the best possible assistance, to perform our services diligently, or to comply with legal obligations. Internal collaboration enables us to provide our services diligently and consistently. Internal data sharing may be necessary, for example, when we:

• We want to answer your questions carefully and thoroughly;
• want to process applications efficiently and accurately;
• need to understand the products you purchase from the Alpina Group;
• to prevent fraud, abuse, or other irregularities;
• or want to improve our services and internal processes.

We share personal data within the group only when permitted by law and to the extent necessary for the specific purpose.

6. How long do we retain your data?

How long we retain your personal data depends on the purpose for which we process it. We do not retain data for longer than is necessary to provide our services or to comply with legal obligations.

As a general rule, we retain personal data for up to seven years after our services have ended. We do this so that we can continue to support you even after our relationship has ended, for example, if you have questions about a previously purchased insurance policy. We may retain data for a longer period if required by law or if we need the data to handle a complaint or legal proceeding.

For products with a longer term, such as mortgages, we may retain personal data for the duration of the product. In some cases, this may mean that data is processed for a longer period, for example, for as long as the mortgage is in effect.

When we no longer need data, we delete or anonymize it. We may sometimes still use anonymized data for research, statistics, or product development, but in those cases, it can no longer be traced back to you personally.

7. Profiling and Automated Decision-Making

We use automated systems in the provision of our services. These may include systems that operate based on fixed rules or preset criteria, as well as systems that analyze data to identify patterns. For example, these systems assist our employees in assessing applications, processing changes, or identifying risks.

We implement these systems carefully and in accordance with applicable privacy laws.

Profiling

In some situations, we use profiling. This means that we analyze and combine personal data. This helps us gain a better understanding of your situation, risks, and preferences. It helps us provide our services with due care. For example, we use profiling to:

• to provide information or offers tailored to your situation;
• to have a provider determine the appropriate premium or terms and conditions;
• to prevent fraud, money laundering, or other forms of abuse.

We may also use profiling to gain a better understanding of the stage a (potential) customer is in. This allows us to better tailor our communication and services to your situation, provide relevant information at the right time, and determine when personal contact is desirable or appropriate. Before we use profiling, we assess whether it is necessary and proportionate. In doing so, we take measures to prevent inaccurate or unfair results.

Automated Decision-Making

In providing our services, we use automated processes that support our employees. This may involve, for example, checking applications for completeness, applying established rules of knowledge, or identifying unusual details in a file.

These systems help us work more efficiently and with greater care. The final assessment and responsibility for our services always rest with us.

To the extent that our services involve automated decision-making that may affect you, we ensure that appropriate human oversight is in place. In such cases, you have the right to:

• to ask for an explanation of the decision;
• to file an objection;
• to request human intervention;
• or to request a reassessment.

8. Use of Artificial Intelligence (AI)

We sometimes use AI to improve our processes and services. This means that systems learn to think independently or recognize patterns. Personal data may be used in this process. Of course, we do so with great
care.

We use AI in various ways, such as for:

• Training Objectives
  When necessary, we can train AI systems using appropriate data. This enables the system to recognize patterns and deliver better results.
• 
  Analysis We can use AI to analyze data and make predictions based on patterns in existing information. These analyses help us better tailor our services, reach out to customers in a timely manner, or improve processes. AI is used as a supportive tool in this process.
• For administrative processing
  AI can assist with administrative or support tasks, such as automatically sorting and forwarding emails to the appropriate department, linking mail to the correct customer file, and creating summaries of customer interactions.

We always use AI with care. That is why we build in safeguards to prevent incorrect or unfair outcomes. We take measures to prevent discrimination and unfair treatment. When necessary, we conduct a risk assessment in advance. In doing so, we consider the purpose, necessity, and consequences of using AI.

9. Visiting Our Website

When you visit our website, we collect general information about your visit. For example, we track which pages are viewed most often. This helps us understand what visitors find important and allows us to improve our website. This information is anonymous; we cannot identify you.

Our website uses cookies. A cookie is a small text file that is stored on your computer, tablet, or phone when you visit our website. Cookies ensure, for example, that the website functions properly, that your preferences are remembered, and that we can see which parts of the website are used frequently.

Some cookies allow us to improve our website and tailor its content to your interests. Cookies cannot contain viruses and do not harm your device. If you do not want to use cookies, you can adjust your browser settings accordingly. You can also use our cookie settings to specify which cookies you do or do not want to accept.

When you enter information on our website, such as your email address or phone number, this information may be shared with Google in a secure and encrypted format. Encryption means that the data is converted into a secure code so that it is not transmitted in a readable format.

Google uses this secure data solely to determine whether an ad led to a visit or action on our website. We receive only general reports on the use of our website and ads. Your personal data remains protected: we do not see any data that could be used to directly identify you.

When you visit our website or use digital forms, we may—depending on your cookie preferences and how you contact us—combine information from various digital touchpoints. This helps us better tailor our communications and services, provide relevant information at the right time, and avoid asking you to resubmit your information unnecessarily.

10. Social Media

If you contact us via social media, such as Facebook, LinkedIn, or X, we will use the information you share with us there. This privacy statement applies to that information.

Your use of social media is your own responsibility. This statement applies to how we handle your data. How social media platforms handle your data falls outside the scope of this statement. Many of these companies are based outside Europe and operate in countries with privacy rules that differ from those within the European Union. Therefore, always read the platform’s own privacy policy. It explains how they use your data and what rights you have there.

11. Phone Calls

When we record a phone call, you, as the caller, will always be notified in advance.

We sometimes record calls to improve our services, train employees, and ensure that complaints are handled carefully. Only calls made through our customer contact center may be recorded.

Recordings may only be listened to by authorized employees, such as a team leader or quality assurance representative. They use the recordings solely for quality assurance purposes or to address a complaint. We do not retain call recordings longer than necessary, and access to recordings is limited to employees with the appropriate authorizations.

12. How do we protect your data?

We take various technical and practical measures to ensure that your personal data is properly protected.

We process personal data based on the information we receive from you or from other reliable sources. If we have reason to believe that any data is incorrect or out of date, we will correct it. You may also request that we correct or supplement your data at any time.

Our systems are well secured. This prevents anyone from accessing your data without authorization, or from altering or sharing it. Our security measures are regularly reviewed by our security specialists.

Our employees are bound by a duty of confidentiality. They may only access your information if it is necessary for their work. Our business partners and service providers must also adhere to the same strict security rules.

13. What privacy rights do you have?

Under the law, you have various rights regarding your personal data. Would you like to exercise one of these rights?
Please contact us at privacy@alpinagroup.com

Below, you can read about your privacy rights and what they mean:

• Right to Information: You have the right to know what information we collect about you and how we use it.
• Right of access: You have the right to know what personal data we process about you.
• Right to correct data: You have the right to have inaccurate or incomplete data corrected.
• Right to erasure: You can ask us to delete your data.
• We will then assess whether that is possible. In some cases, we are permitted or required to retain data—for example, because we must comply with a retention period or because the data is still needed to provide our services.
• Right to restriction of processing: You may request that we process less of your data. In this case as well, we will assess whether this is permitted by law.
• Right to data portability: You may request that your data be transferred to you or to another organization. This can be useful if, for example, you switch to a different insurer or advisor.
• Right to object: You may object to the processing of your data or withdraw your previously given consent.

14. Can we amend this statement?

We may update this privacy statement. This may be necessary due to new developments in our business operations or changes in laws and regulations. The most recent version of this privacy statement always applies. You can always find the current version of this statement on our website,
.

Do you have any questions or suggestions regarding this privacy statement? If so, please contact our Data Protection Officer.

Download the PDF version of our privacy statement here.