Who is responsible for your data?
The Pension Fund that administers your pension plan is responsible for the processing of your personal data. The Pension Fund has outsourced the asset management to Goldman Sachs Asset Management B.V. (GSAM). GSAM processes your personal data under the authority of the Pension Fund. GSAM has its registered office at Prinses Beatrixlaan 35, 2595 AK The Hague, e-mail: info@mijnpensioen.nnip.com, website: https://mijnpensioen.gsam.com. GSAM is part of Goldman Sachs Group Inc.

GSAM does everything it can to ensure that the processing of your personal data takes place in such a manner that your privacy is protected and safeguarded as much as possible. We comply with the applicable legislation and regulations, including the provisions of the General Data Protection Regulation (GDPR). Information on how we process your pension data can be found below.

What is personal data?
Personal data concerns all information about a person. This includes data that tells some-thing about someone indirectly. Some examples are your name, address, date of birth, telephone number and email address. We obtain this data from your Pension Fund. We can also obtain personal data from you when you fill in a form or send a letter or email.

Whose personal data do we process?
We may process personal data of all persons with whom we have contact, or who use our service via the member portal. The processing of personal data includes the collection, retention and use of that information.

Which personal data is used, and what for?
GSAM collects, in any case, the following personal data: name, gender, address, date of birth, telephone number, email address, Social Security Number (‘BSN') and financial details. We process your personal data for carefully defined purposes. Below you can read about the purposes for which we process your personal data:
•We use personal data that we need to administer your Pension Fund's pension plan. This is data about you yourself, such as your name, gender, address, date of birth, telephone number, email address, Social Security Number and financial details
•We may record telephone calls for coaching and evaluation purposes and also for the verification and investigation of orders and transactions and in the event of disputes From whom do we obtain your personal data? We obtain most of your personal data from the Pension Fund. It may also be that we obtain personal data from you.

With whom may we share your personal data?
We may provide your personal data to the persons, companies and institutions named below. We do that only if:
•That is necessary in order to carry out the agreement; or
•We have a justified interest in it, and the provision of your data is necessary for this reason; or •It is required by law to provide your data; or
•You have given permission.

We provide your personal data to the following parties only if we have one of the reasons mentioned above:
•Our staff, as far as they need this data for their work;
•Companies to whom we outsource activities (‘processors’). These companies then work under our authority. Examples are IT companies;
•Your Pension Fund;
•To public services, such as regulatory authorities, the police and judicial authorities, if we are required by law to do so.

How long do we keep your personal data?
We keep the personal data as long as necessary for the purpose for which we use the data and as long as we are required to keep it by law. We apply the following rules in this regard: Personal data processed by GSAM As soon as your Pension Fund has entered into an agreement with GSAM, we keep your personal data as long as necessary during the contract. When the contract is terminated, we keep your personal data, in principle, for a period of seven years on the basis of statutory obligations.

Personal data collected from telephone calls and emails
Recorded calls are saved for a period of one year after the call takes place. Personal data is also kept for the duration of a current investigation or legal claim, unless this is in violation of the legislation and regulations. Emails are kept for seven years.

Data collected through cookies
GSAM uses cookies. A cookie is a small text file stored by your browser on the hard drive of your computer when you visit a website. We use functional and analytical cookies which are necessary to optimise this website. These can be anonymous cookies or session cookies. Anonymous cookies contain no personal data, such as an IP address, and are automati-cally deleted after 30 days. Session cookies are deleted immediately after leaving the website. We also use non-functional cookies. These are cookies that can be used for internal purposes. You can change your preference for the use of these cookies at all times. GSAM collects and/or shares the following information for this purpose: the date and time you visit the website, the browser type, browser language, the number of hits, pages visited and duration of the user session. For more information about the sharing of data, please see With whom may we share your personal data.

Where do we keep your data?
Your personal data is generally processed within the European Union (EU). Personal data is processed outside the EU in some cases. Some of our suppliers and business partners are also located outside the EU or provide these services outside the EU. The regulations in those countries do not always provide the same level of personal data protection as European regulations. In those cases, we guarantee an appropriate level of protection by taking measures ourselves, such as making contracts containing further, appropriate guarantees (‘EU model contracts’).  

Protection of your personal data
Safeguarding your privacy and protecting your personal data are paramount to us. GSAM has therefore taken appropriate technical and organisational measures to protect personal data from loss or unlawful processing. Your rights with respect to personal data The General Data Protection Regulation (GDPR) gives you certain rights with respect to the personal data processed by us. You are entitled to request and change the personal data processed by us, to have it deleted, have its use restricted for certain purposes, transfer personal data and to object. If you wish to exercise your rights, please contact us via info@mijnpensioen.nnip.com.

Right to inspect
You may request to inspect the personal data that GSAM processes about you. This means that you may request which personal data GSAM has registered and for what purposes this personal data is used.

Right to change
GSAM does its best to keep your personal data accurate and up to date. You are entitled to have your personal data changed if it is not correct.* A request to this extent will be ful-filled by GSAM in consultation with the Pension Fund.

Right to removal
You are also entitled to have your personal data deleted if your personal data is unlawfully processed*, no longer necessary for the purpose for which it is collected or processed* or because you have withdrawn your permission and GSAM has no other legal grounds for processing your data. The handling of a request to this extent will be coordinated with the Pension Fund. *In the cases marked with an *, you are also entitled to restrict the processing of your personal data. You also have this right in the case you object to the processing of your data and your objection is still being handled by us.

Right to transfer your personal data
You are entitled in certain cases to request us to take the personal data that you provided to us and transfer it electronically to you and/or another service provider. We will handle such a request in consultation with the Pension Fund.

Right to be forgotten
You are entitled to ask us to delete your personal data. We will be unable to comply with this request as long as we still use your personal data for administering your Pension Fund's pension plan, need it on the basis of statutory obligations and/or in the case of a potential legal dispute.

Right to object
You may lodge an objection to the processing of your personal data by GSAM if we use your personal data for purposes other than necessary for carrying out an agreement or necessary for complying with a statutory obligation. We will carefully assess your objection and stop processing the data if necessary. We will inform you about this as soon as possible.

Questions or complaints?
If you are not satisfied with the processing of your personal data or have other questions in relation to this privacy policy or how we process data, please contact us via info@mijnpensioen.nnip.com and we will work with you to find a suitable solution. You can also contact our data protection officer via gs-privacy@gs.com. You are also entitled to file a complaint with the Dutch Data Protection Authority.

Our privacy policy may be changed from time to time. We will inform you promptly of any major changes. We recommend referring to this privacy policy regularly to stay informed about the latest changes. This privacy statement was last modified on 1 March 2023.