Privacy
We handle your personal data with care
Fidamy attaches great importance to your privacy, and that is why we handle your personal data with care. For this, we take both visible and invisible measures. In this privacy statement, you can find information about how we handle your personal data.
What is personal data?
For example, if you want to take out a product with us or submit a claim, we ask you for personal data such as your name and address. Also, if you visit our websites, we may collect personal data from you, such as the IP address of your computer.
Personal data is information that says something about you or that we can relate to you. We call the collection, storage, and use of your data the 'processing' of your personal data. That is a term from the law. Fidamy complies with the laws and regulations, including the provisions of the General Data Protection Regulation (GDPR) and the Code of Conduct for the Processing of Personal Data by Insurers, when processing your personal data. Below you can read what we process personal data for and what data that may be.
For what purposes do we process personal data?
We only store and use your personal data for carefully defined purposes. In most cases, we receive personal data from you because you are taking out one or more products from us, or want to do so. The law then speaks of data processing that is necessary for the preparation or execution of an agreement. It comes down to the fact that we cannot help you as a customer if we do not have or are not allowed to store data about you.
Your personal data is also used because we keep a central customer administration, carry out marketing activities, want to prevent and combat fraud, or use the data for risk management. In the law, this is called 'processing due to legitimate interests'. This can also be in your own interest, because then we can help you better and combat fraud. In addition, we process your data in order to comply with our legal obligations. Below you will find more information about the basis on which we process your personal data.
For the performance of our agreements
Based on a legitimate interest
To comply with legal obligations
What personal data do we process?
Personal data that we receive from you for the performance of the agreement. This includes:
General information such as your name, address, telephone number, e-mail address, and date of birth.
Data to be able to identify you, such as a copy of your identity card or passport and a selfie.
Your bank account number to receive payments from you or make payments to you. Data that we need for a specific product, such as a license plate for car insurance.
For the risk assessment for non-life insurance, we may ask whether there is a criminal history. For the risk assessment of an insurance policy, for example a non-life insurance policy, Fidamy may ask about the existence of a criminal history of you or another interested party in the requested insurance policy. In that case, we would like to know whether you or someone else who has an interest in the insurance policy has been in contact with the police or the judiciary in the past 8 years. By this we mean an ongoing investigation, that you are or have been a suspect (dismissal), a conviction, the execution of a sentence or measure, or dismissal from all legal proceedings. If this was the case more than 8 years ago, you do not have to report it. You also do not have to report any criminal data to us if we do not specifically ask for it. Fidamy uses the reported criminal history for the assessment of the insurance application and for invoking non-compliance with the applicant's duty of disclosure. In addition, Fidamy can process the criminal data to prevent and combat fraud and abuse. We process this data on the basis of Article 33 of the GDPR, the Code of Conduct for the Processing of Personal Data by Insurers (GVPV) and we adhere to the Protocol Incident Warning System for Financial Institutions (PIFI).'
Location data (from your phone or tablet). For security reasons, we look at data that shows where you are during the identity check. We only use this location data for this.
Special categories of personal data
We may - only if necessary to comply with legal obligations or if you have given us explicit consent - process special categories of personal data. These are, for example, data that provide information about political opinions, trade union membership, medical data, and biometric data to identify you. That is the case, for example, if we ask you to identify yourself, to verify your identity document.
Additional data
Additional data refers to extra data that we have not received from you, your intermediary, or advisor, but that we retrieve from (public) sources. Think of consulting information to combat terrorism and money laundering. Or consulting information from the Credit Registration Office (BKR). We do this in some cases to assess a risk or to comply with our legal obligations. You can find more information about this on this page under 'From whom do we receive your data?
Contact history
We record when and what you have contact with us about. With a view to improving our business operations, including the quality of the service, as well as training, coaching, and assessment of employees, we record telephone conversations and record the content of chats. With the help of AI, we can automatically convert conversation recordings into text (speech-to-text) or make a summary of them and perform analyses on them for the aforementioned purposes. On our websites, we can also communicate with you via chatbots. In doing so, we make use of a limited form of AI (Natural Language Processing).
Your visit to our websites and apps
We record data about your visit to our websites or apps. For example, which pages you have visited, when you logged in to the Fidamy policyholder portal, or what search query you made. With this we make the site work better and give you a personal experience. We also use this data for marketing activities. We do this, among other things, by placing cookies. You can find more information about the use of cookies in our Cookie Statement. We also process your IP address. This is the number of your computer, tablet, or mobile on the internet that makes you visible to other computers, tablets, and mobile phones.
From whom do we receive your personal data?
We receive most personal data from you, from our partners where you have purchased a product and also taken out insurance with us or your financial advisor. If you are insured with Fidamy through your employer, for example for a pension or income insurance, we receive your data from your employer or sometimes through the Personal Records Database (BRP). If necessary for the execution of an agreement, we can also receive data from other banks and insurers.
When assessing an application for a non-life product or when handling a claim, we also use various sources such as the Credit Registration Office (BKR), Chamber of Commerce (KvK), and fraud registers and the Central Information System Foundation (CIS). CIS is the central information system of insurers in the Netherlands. This system is managed by the CIS Foundation. The system is intended to control risks and combat insurance crime. We can have your personal data included in CIS, for example if you have committed fraud. We can also request information about you via CIS, for example when assessing an application or claim. We only do this under strict conditions. More information about CIS and the CIS privacy regulations can be found on the website of the CIS Foundation: https://www.stichtingcis.nl
If you are a customer of managing general agent Fidamy B.V., Nationale-Nederlanden Schadeverzekering Maatschappij N.V. will also receive your personal data.
We only process personal data that we receive from third parties if that party is allowed to provide it and we do not use this personal data for purposes other than those for which we obtained it.
To whom can we provide your personal data?
We may provide your personal data to the persons, companies, and authorities mentioned below. We only do that if:
that is necessary for the execution of the agreement;
we have a 'legitimate interest' for this and the provision of your data is necessary for this. You can find the explanation of this under 'For what purposes do we process personal data';
it is legally required to provide your data;
you have given permission.
Only if at least one of the above reasons applies, we provide your data to one or more of the parties below.
Nationale-Nederlanden Schadeverzekering Maatschappij N.V. insofar as this is necessary for business operations and for complying with legal obligations.
Companies to which we outsource work ('processors'). These companies then work on our behalf, such as in the identity verification process.
Your advisor, intermediary, or representative, your employer, and his advisor if you are insured through your employer.
Companies that we engage in the settlement of a claim by providing expert services or repair and advisory work for non-life insurance.
Companies that we engage in the assessment of an application for a product or a claim report.
Public services such as regulators, police and judiciary, and the Tax and Customs Administration, if we are legally obliged to do so.
Other insurance companies. This also includes reinsurers.
Bailiffs, collection agencies, and/or notaries.
External registers such as CIS, BKR, External Reference Register (EVR). A reference application can be used to check whether (personal) data has been included in these registers. The Referral Application of the Insurers is managed by the Central Information System Foundation (CIS) and that of the other participants by the Credit Registration Office Foundation (BKR).
Automated decision-making
For a number of products, such as electronic equipment insurance, we assess the application and/or a claim via an automated process. In doing so, we may also use Artificial Intelligence (AI).
In the application process, we check whether you meet our acceptance criteria. Among other things, we check whether the information you provided about yourself or about the object you want to insure when applying is correct. In the event of a claim, we check whether the claim meets the policy conditions that we have agreed with you and whether you can claim a payment based on the information you have provided.
We also check applications and claims against a number of fraud indicators and make a risk assessment based on your data and data from other (public) sources. These checks can have consequences for the amount of your premium for insurance products. In the case of a fraud registration, one of our employees always assesses your application.
If we check whether you are still entitled to a periodic benefit and check your identity to meet the legal requirements, that identity check is partly an automated process. In doing so, we may also use AI to check your passport photo on your identity document and the photo you took of yourself (selfie). In the event of an error between the selfie and your passport photo, one of our employees always assesses your application.
If we use an automated process, you have the right to have a decision submitted to an employee, to get an explanation, to let us know what you think about it, and to object if necessary.
This is how we take care of your personal data
We ensure good security
We spend a lot of time and attention on the security of our systems and the personal data stored in them. We constantly monitor the security of our data traffic. If something goes wrong, we take immediate action. We resolve and register data leaks. We are also required to do this by law. We also report them to the regulator and to you, if necessary.
There is supervision on how we process personal data
The Dutch Data Protection Authority (AP) checks whether we comply with the GDPR.
The Netherlands Authority for Consumers and Markets (ACM) supervises how we handle cookies, direct marketing via e-mail, and telemarketing.
De Nederlandsche Bank (DNB), the European Central Bank (ECB), and the Netherlands Authority for the Financial Markets (AFM) supervise the financial sector in general and therefore also Fidamy.
Internally, the Data Protection Officer supervises the way in which we handle your personal data. This person can be reached via our Privacy Form
We have signed a confidentiality agreement
All our employees have signed a confidentiality agreement, have been screened and have taken an oath. We handle the data you entrust to us with care. Only authorized personnel may view and process your data.
What are your rights?
As a customer, you have a number of rights that relate to your personal data. These rights are explained below.
You have the right to access
This means that you can request which personal data we have registered about you and for what purposes we use it.
B. You have the right to rectification, erasure, and restriction
You have the right to have your personal data corrected if it is incorrect. You also have the right to have your personal data deleted if your personal data has been processed unlawfully, is no longer necessary for the purpose for which it was processed, or because you have withdrawn your consent and Fidamy no longer has any other valid reason for processing your data. You also have the right to restrict your personal data. This right means that you can indicate that your data may not be used temporarily. You can make use of this if your personal data is incorrect, is processed unlawfully, is no longer necessary for the purpose for which it was collected or processed, or if you object to the processing and your objection is still being processed by us.
C. You have the right to data portability
This means that in certain cases you have the right to ask us to transfer the personal data that you have provided to us to yourself and/or another service provider.
D. You have the right to object
You can object to the processing of your personal data if we use your personal data for purposes other than necessary for the performance of an agreement or necessary for compliance with a legal obligation. We carefully assess your objection and stop processing your personal data if necessary.
E. Set your preference for offers
You can always easily adjust your choice for receiving offers via e-mail. You can do this by clicking on the link at the bottom of the e-mail or by informing us of this by telephone.
How long do we keep your data?
As long as you are a customer with us, we keep your data. This also applies if you are not a customer and we process your personal data for, for example, claim settlement:
We delete the policy data seven years after termination of the agreement.
We delete the claim data seven years after termination of the claim.
Data from a sanction investigation will be deleted 12 years after termination of the agreement;
Data with a 'hit' on a sanctions list will be deleted 5 years after the sanction has been lifted;
After the retention period, we only keep necessary data for statistical purposes, which are not identifiable to a person.
Where do we process your data?
Your data is usually processed within the European Union (EU). In some cases, personal data is processed outside the EU. Some of our suppliers and cooperation partners are also established outside the EU or provide services outside the EU. The regulations in these countries do not always offer the same protection of personal data as the European regulations. To ensure that your personal data is still safe, we take measures in those cases by concluding agreements ourselves in which we make similar agreements about the security of personal data, just as we do within the EU. We call these EU model contracts.
Which companies does this privacy statement apply to?
You probably only know us as Fidamy, because we operate under this brand name. This privacy statement applies to Fidamy BV and all its subsidiaries. These companies work together and share data with each other. If you are a customer with us, you may receive an offer from these companies.
Do you have questions?
Do you have general questions about your personal data? Then contact us via our Privacy Form.
Do you want to view or change your personal data?
Then take a look at your personal online environment. Here you can view and change the most important personal data, such as your address or e-mail address. You can also request more data via your Fidamy policyholder portal and make use of your other rights, for example the right to transfer data. This can be done, among other ways, via our form by clicking the link under “Do you have questions?” section.
Do you have a complaint?
Do you have a complaint about the way in which Fidamy handles your personal data? Then you can submit it via the Complaints Form.
You can also submit a complaint to the Dutch Data Protection Authority.
Have you submitted a complaint with us and are you not satisfied with our response? Then you can contact the Financial Services Complaints Institute (Kifid)
Kifid
Postbus 93257
2509 AG Den Haag.
Kifid is also reachable through phone when calling to 070 333 89 99 or online through the following website: www.kifid.nl
About this privacy statement
This privacy statement may be amended due to changed laws and regulations and/or the way in which we process personal data. This version is from 26 February 2025. You can always find the most recent version at www.fidamy.com/documents/privacy.