Privacy Policy
Privacy Policy
Expat Mortgage Platform
We respect your privacy and we treat your personal data with the utmost care. This Privacy Policy explains in detail which personal data we collect, why we collect it, on what legal grounds we process it, with whom we may share it, how long we keep it and which rights you have. It applies to our website, our online tools and applications, and to all advisory, intermediary and related financial services we provide.
Because we provide mortgage advice and act as a financial intermediary, we process personal data within a strictly regulated environment. We do so in accordance with the General Data Protection Regulation (GDPR / AVG), the Dutch GDPR Implementation Act (UAVG), the Financial Supervision Act (Wet op het financieel toezicht, Wft) and the guidelines of the Financial Services Complaints Institute (Klachteninstituut Financiële Dienstverlening, KiFiD).
1. Who we are
Expat Mortgage Platform (“we”, “us”, “our”) is the controller responsible for the processing of your personal data as described in this Privacy Policy.
Trading name: Expat Mortgage Platform Legal entity: ExpatMortgagePlatform B.V. Chamber of Commerce (KvK) number: 86841343 Registered address: Aelbrechtskade 65, 3022 HP Rotterdam AFM registration number: 12016498 Email: [email protected] Website: https://expatmortgageplatform.nl
If you have any questions about this Privacy Policy or about how we handle your personal data, you can reach us using the contact details above or through the contact form on our website.
2. Definitions
In this Privacy Policy we use a number of terms that have a specific meaning under the GDPR. “Personal data” means any information relating to an identified or identifiable individual. “Processing” means any operation performed on personal data, such as collecting, storing, using, sharing or erasing it. “Controller” means the party that determines the purposes and means of the processing, which in this case is us. “Processor” means a party that processes personal data on our behalf and under our instructions.
3. The personal data we collect
The personal data we collect depends on how you interact with us. We have set out the main categories below.
3.1 Data you provide to us
When you visit our website, subscribe to a newsletter, respond to a survey, use our live chat, complete a form, request a calculation, request advice or otherwise contact us, you may provide us with personal data such as your name, email address, telephone number, postal address and the content of your message.
When you proceed to an advice request, an application or the conclusion and performance of a (mortgage) agreement, we may collect significantly more detailed personal data, including but not limited to: your full name, date of birth, place of birth, nationality, residence status and residence permit details, marital and family situation, employment and income details, employer information, assets and liabilities, existing loans and credit obligations, bank account details, tax position, pension information and details of the property concerned.
3.2 Data we collect automatically
When you use our website, certain data is collected automatically through cookies and similar technologies, such as your IP address, device and browser type, the pages you visit, the date and time of your visit, your approximate location and the way you use our website. More information about this is set out in the Cookies section below and in our separate Cookie Statement.
3.3 Data we receive from third parties
In order to provide our services, we may receive personal data about you from third parties, such as lenders, banks, insurers, credit registration agencies (including Bureau Krediet Registratie, BKR), valuers, the Land Registry (Kadaster), tax authorities and other parties that are relevant to your advice or application. We may also receive data from publicly available sources where this is permitted.
3.4 Special categories of personal data and your citizen service number (BSN)
In limited cases we may process special categories of personal data, for example health data when this is necessary for a specific insurance product associated with your mortgage. We only process such data where the law allows it and where it is necessary for the service you have requested.
We process your citizen service number (Burgerservicenummer, BSN) only where we are legally permitted or required to do so, for example in the context of mortgage and insurance products where lenders and insurers are obliged to register it.
4. The legal grounds on which we process your data
We only process your personal data where we have a valid legal ground under the GDPR. Depending on the situation, we rely on one or more of the following grounds.
We process your data because it is necessary for the performance of an agreement with you, or in order to take steps at your request before entering into an agreement, for example when we prepare advice, perform calculations or submit an application on your behalf.
We process your data to comply with a legal obligation to which we are subject, for example obligations arising from the Wft, anti money laundering legislation, tax legislation and the supervisory requirements that apply to financial service providers.
We process your data on the basis of our legitimate interests, for example to run, secure and improve our business and our website, to prevent and combat fraud against financial institutions, to carry out statistical analysis, to manage our client relationships and to market our own comparable products and services to existing clients. When we rely on legitimate interests, we always weigh our interests against your rights and freedoms.
Where the law requires it, we process your data on the basis of your consent, for example for certain cookies or for specific marketing communications. Full policy can be found here. You may withdraw your consent at any time, without this affecting the lawfulness of processing carried out before the withdrawal.
5. The purposes for which we use your data
We use the personal data we collect for the following purposes:
To accept, assess and process advice requests, calculations, applications and other forms you submit to us. To enter into and perform (mortgage) agreements and related financial products. To personalise your experience and to provide you with the content, product offerings and information that are most relevant to you. To operate, maintain, secure and improve our website and our services so that we can serve you better. To respond to and handle your customer service requests, and to follow up after correspondence through live chat, email or telephone. To send periodic emails regarding your request, your application, your agreement and other products and services. To conduct marketing activities and relationship management. To prevent and combat fraud against financial institutions. To carry out statistical analysis. To comply with applicable statutory and supervisory requirements.
All data submitted through advice requests, calculations or other forms is processed in accordance with the guidelines of the Financial Services Complaints Institute (KiFiD), the Financial Supervision Act (Wft) and the General Data Protection Regulation (GDPR / AVG).
6. Sharing your data with others
We do not sell your personal data. We only share your data with others where this is necessary for the purposes described in this Privacy Policy or where we are legally required to do so.
We may share your data with lenders, banks, insurers, mortgage providers, credit registration agencies (including BKR), valuers, notaries and other parties whose involvement is necessary to prepare, submit or perform your advice or application. We may also share your data with service providers (processors) who process data on our behalf, such as IT, hosting, software and administration providers, and with our advisers such as accountants and lawyers. Where required, we share data with supervisory authorities, tax authorities and other competent public bodies.
Where we engage processors, we enter into a data processing agreement that obliges them to handle your data securely, confidentially and only in accordance with our instructions. Once your data has lawfully been shared with an independent third party such as a lender or insurer who then determines its own purposes, that party is responsible for its processing under its own privacy policy.
7. International data transfers
Your personal data is in principle processed within the European Economic Area (EEA). If, in exceptional cases, your data is transferred to a country outside the EEA, we will ensure that an appropriate level of protection is in place, for example through an adequacy decision of the European Commission or through the use of standard contractual clauses.
8. How long we keep your data
We do not keep your personal data longer than is necessary for the purposes for which it was collected, unless we are required by law to keep it for a longer period.
For advisory and intermediary files relating to financial products, we are subject to statutory retention obligations under the Wft and tax legislation, and we apply the retention periods that follow from those obligations. Data that is only used for general enquiries, marketing or website use is kept for a shorter period and is deleted or anonymised once it is no longer needed. Telephone recordings are kept no longer than is strictly necessary for the purposes described below.
9. How we protect your data
Your personal data is stored behind secured networks and is only accessible to a limited number of persons who have special access rights to such systems and who are required to keep the information confidential. In addition, the information you supply is encrypted using Secure Socket Layer (SSL) technology. We implement a range of technical and organisational security measures when you enter, submit or access your information, in order to maintain the safety of your personal data and to protect it against loss, misuse and unauthorised access.
10. Cookies
When you visit our website, cookies are used for statistical purposes and to improve the ease of use of our website. A cookie is a small text file with data that your browser stores on your device. When you visit the website again, the cookie allows your browser to be recognised, so that, for example, your settings can be preserved or information that may be of interest to you can be shown more clearly.
We use different types of cookies, including functional, analytical, tracking and performance cookies. Functional cookies are necessary for the website to work. Analytical and performance cookies help us understand how the website is used. Tracking cookies may be used to show you relevant information and offers. You can manage or disable cookies through our cookie consent banner or through your browser settings. If you disable certain cookies, parts of our website may not function properly. More detailed information is available in our separate Cookie Statement.
11. Telephone call recording
For the purposes of training, coaching and employee assessment, incidental telephone calls may be recorded. These recordings are kept secure and are not accessible to unauthorised persons. The recordings are not stored for longer than is strictly necessary for these purposes.
12. Direct marketing and your choices
We may send you information about our products and services, for example by email. Where you are an existing client, we may do so on the basis of our legitimate interest in marketing our own comparable products and services. Where the law requires consent, we will ask for it. You can object to direct marketing at any time and you can unsubscribe from our newsletters using the link included in each message or by contacting us.
13. Automated decision making and profiling
We do not subject you to decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you, unless this is permitted by law or necessary for entering into or performing an agreement and appropriate safeguards are in place. We may use tools such as calculators to support our advice, but a qualified adviser remains involved in the assessment of your situation.
14. Your privacy rights
Under the GDPR you have a number of rights in relation to your personal data. You have the right to request access to the personal data we hold about you. You have the right to have inaccurate or incomplete data corrected. You have the right to request erasure of your data in certain circumstances. You have the right to request restriction of processing and to object to processing that is based on our legitimate interests. You have the right to data portability, which means receiving certain data in a structured, commonly used and machine readable format. Where processing is based on your consent, you have the right to withdraw that consent at any time.
Please note that some of these rights are limited, in particular where we are legally required to keep your data, for example under the retention obligations that apply to financial advisory files. To exercise your rights, please contact us using the details in this Privacy Policy. We may ask you to verify your identity before we act on your request.
15. Children’s privacy
Our services are not directed at children. We do not knowingly collect personal data from children without the involvement of a parent or legal guardian where this is required.
16. Third party websites and links
Our website may contain links to websites of third parties. This Privacy Policy does not apply to those websites. We are not responsible for the content of third party websites or for the way in which they handle your personal data. We recommend that you read the privacy statement of any website you visit.
17. Complaints
If you have a question or a complaint about the way we handle your personal data, we ask you to contact us first so that we can try to resolve it together. If we are unable to resolve your complaint, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). For complaints relating to our financial services, you may also be able to turn to the Financial Services Complaints Institute (KiFiD).
18. Changes to this Privacy Policy
We reserve the right to make changes to this disclaimer, our cookie policy and this Privacy Policy without prior notice. The most recent version published on our website applies. We recommend that you consult this Privacy Policy regularly so that you are aware of any changes.
19. Contact
If you have questions about this Privacy Policy or about the use of your personal data, you can contact us through the contact form on our website or using the contact details set out in section 1 of this Privacy Policy.
- To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To improve our website in order to better serve you.
- To allow us to better service you in responding to your customer service requests.
- To send periodic emails regarding your order or other products and services.
- To follow up with them after correspondence (live chat, email or phone inquiries)
- To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To improve our website in order to better serve you.
- To allow us to better service you in responding to your customer service requests.
- To send periodic emails regarding your order or other products and services.
- To follow up with them after correspondence (live chat, email or phone inquiries)