Mars Pension Fund is responsible for processing your personal data.

Mars Pension Fund processes data of the following persons: 

• Members, deferred members, pensioners, and other beneficiaries of Mars Pension Fund.
• Members of the Board of Trustees and members and/or officers of other bodies of Mars Pension Fund.
• Employees of suppliers and outsourcing parties of Mars Pension Fund.
• Everyone who visits our website.
• Everyone we are in contact with.

If you are a member in Mars Pension Fund, we may process the following categories of personal data: 

• Personal details and contact information (such as name, residential and/or correspondence address, town/city of residence, date of birth and/or age, marital status, gender, phone number, email address, and signature).
• Financial and pension data (such as bank account number, pension rights or claims, and policy number).
• Employment data (such as type of employment (both current and deferred), salary details, irregular hours allowance and part-time factors, employee number).
• Citizen service number (BSN).
• Proof of identity (such as a copy of your passport to establish your identity).
• Special personal data (such as personal data relating to your degree of occupational disability and/or benefit percentage if you are incapacitated for work). We also process biometric data if you provide your “Proof of Life” digitally through the “ReadID Ready” app (we use your ID and facial image to verify the authenticity of your proof of life).
• Data relating to criminality (for example, if your data appears on international and national risk and sanctions lists).
• Relationship data (data on your partner, ex-partner and any children entitled to orphans’ pension).

Other communication data

• Personal data you provide in correspondence or phone calls with the Fund, and data we obtain from you during an advisory process.
• Data from video calls (such as metadata, image, and voice).
• We process your IP address for statistical analysis if you visit our general website or MyMarsPension. We try to pseudonymize or anonymize these data as much as possible (see our cookie statement for more information).
• If you log in to MyMarsPension, we temporarily keep log files. These files contain login data, your IP address, and technical details about the software and hardware of the device you use to log in to MyMarsPension. We use the information in these log files for authentication (if you log in to MyMarsPension) and to detect and resolve errors and security or other incidents on our website.
• When you visit MyMarsPension, we process data if you provide us with information or a change (such as a change in your email address or account number, your communication preferences if you choose to receive pension information by mail or digitally, or if you sign up for or unsubscribe from the newsletter).
• We also record open and click behavior in email newsletters, personal documents, emails and email notifications, as well as clicks on links in emails to one of our web pages. This lets us see if you open a newsletter, email or email notification, document, or link, and the date and time you did so. We analyze these data to gain insight into the effectiveness of our communication. We use this insight to optimize our services and communication. We do not analyze data at an individual level. We may also use these data to detect and resolve incidents. 

Mars Pension Fund obtains data directly from you, but also from the Key Register of Persons (BRP), your employer, government agencies (such as the Dutch Tax and Customs Administration and the Employee Insurance Agency (UWV)), pension funds and/or pension administrators where you previously accrued pension, and from other individuals and organizations you have authorized to share data with us.

If you are a member in Mars Pension Fund, we process your personal data to administer the pension plan or the administration agreement between the Fund and your employer. We process personal data for the following purposes, among others:

• to administer pensions (for example, to calculate your pension rights or claims and to inform you about them accurately and on time, or to pay your pension);
• to comply with contractual and statutory liabilities (for example, to send you legally required pension information, such as your annual Uniform Pension Statement; to provide personal data to the Pensions Register; and to comply with sanctions regulations);
• to deal with your questions about the administration of the pension plan and the services provided by Mars Pension Fund;
• to optimize and personalize our services (for example, by asking for your feedback about our services after you have contacted Mars Pension Fund by phone or email, or because you have communicated a pension choice to us);
• to manage our records and deal with complaints and disputes;
• to provide personalized and general information such as letters, digital newsletters and pension communications;
• to invite you to pension-related meetings that we organize;
• to safeguard the integrity and security of our MyMarsPension’s operations;
• to conduct statistical or other analyses and research. 

We believe it is important that our services and policy choices are aligned with our members’ needs as closely as possible. To achieve this, we regularly conduct research among our members. This includes customer satisfaction surveys, surveys about the pension plan, and studies of customer experience and the effectiveness and appropriateness of Mars Pension Fund communications. We conduct this research ourselves or through specialized research agencies. In the latter case, we only use the data needed to invite you and to perform analyses. This may include your contact details (such as your name, email address, or home address), gender, and in some cases, type of pension plan, age cohort, member group (active member, deferred member, pensioner), pension accrual start date, and risk profile. We process the results of these studies and surveys anonymously. There is no link between your personal data and the outcomes.    

The processing of personal data for these purposes must have a legal basis under the GDPR. The legal basis for processing in this context includes compliance with statutory liabilities that apply to Mars Pension Fund (for example, under pension legislation). Sending legally required pension communications (such as your annual Uniform Pension Statement), providing personal data to the Pensions Register, and complying with sanctions regulations are examples where we process your data on the basis of law.

Your personal data may also be processed on one of the following legal grounds:

• For the performance of a contract to which you or another data subject is a party (for example, to comply with the liabilities under the pension agreement, such as performing the pension administration, calculating pension rights or claims, informing you about them correctly and on time, or paying your pension).
• To look after a legitimate interest of Mars Pension Fund, as long as your interest or that of another data subject does not outweigh it (for example, to process relationship data, to measure the effectiveness of our communications, and to optimize and personalize our services. We may also invite you to take part in member research in that regard.
• Because you have given consent for the processing of your data for one or more specific purposes (for example, to send a newsletter). You may withdraw your consent at any time. The way to do so will be indicated when you give that specific consent. We will then no longer process your personal data unless another purpose and legal basis exist for processing your data.

Mars Pension Fund shares your personal data with various parties for the purpose of providing its services. We share your data with other parties only if there is a legal basis for doing so.

Mars Pension Fund has outsourced the administration of pensions to Blue Sky Group. Blue Sky Group therefore has access to your personal data. Other examples of parties with whom we may share your personal data include your employer, debt collection and recovery agencies, payment processors (who make the gross-to-net calculations), mailing processors and printers, IT providers (for the management, maintenance, and hosting of administration systems), research agencies, accounting and actuarial firms, and pension providers.

Mars Pension Fund enters into processing agreements with parties that process your data on our instructions. In these agreements, we state that these parties may only use the data to perform specific tasks, and for no other purpose, and that they must implement appropriate security measures. In this way, the Fund ensures an appropriate level of security and confidentiality of your data. Mars Pension Fund remains responsible for these processing operations. 

In addition, Mars Pension Fund may be required by government institutions, regulators, or other parties to share your data. The Fund will do this only if it is strictly necessary to comply with a court order or statutory obligation. The Fund will never sell your data to other parties.

Mars Pension Fund processes your data as much as possible in countries within the European Economic Area (EEA). If it is nevertheless necessary to transfer your personal data outside the EEA for the purposes set out in this Privacy Statement, we do so with appropriate safeguards in accordance with the GDPR. In that case, your personal data remains protected through contracts we have entered into with organizations outside the EEA, which, for example, contain the European Commission’s approved standard contractual clauses for data protection. If you have a specific question about transfers outside the EEA, you can contact our Privacy Officer. 

Mars Pension Fund has implemented appropriate security measures to protect your personal data. Examples include measures against misuse, destruction, loss, and other unlawful processing. We have also implemented measures to ensure and safeguard careful handling of your data and to maintain awareness of this within our organization. We have also implemented measures to restrict access to your personal data to those who need to have knowledge of it. The persons to whom we give access to these data are bound by confidentiality. The security measures implemented by the Fund comply with the applicable statutory requirements and guidelines. These measures are evaluated regularly and updated when necessary. 

Despite our precautions to protect personal data as well as possible, security incidents involving personal data may still occur. Such incidents are called data breaches. Mars Pension Fund has a procedure to resolve a data breach as quickly as possible and implements measures, where necessary, to prevent recurrence as much as possible. If necessary, we report a data breach to the Dutch Data Protection Authority and to the data subject(s) involved.  

You will find the main personal data that Mars Pension Fund processes about you in your personal secure environment MyMarsPension. Logging in to MyMarsPension is possible only through a secure login method (for example, with your DigiD). Your data on MyMarsPension are secured in accordance with GDPR requirements. 

We do not retain your personal data longer than necessary for the purpose for which we have collected or process your data. In some cases, the law determines how long we may or must retain data. We retain certain data for determining your pension claims for at least seven years after your death, or until after the death of your surviving dependents or other beneficiaries who are entitled to pension or other benefits from Mars Pension Fund. Your surviving dependents or other beneficiaries (for example, an ex-partner) may still be entitled to pension or other benefits from Mars Pension Fund after your death.

Mars Pension Fund may record phone calls for the purpose of providing our services. We will inform you in advance (at the start of the phone call) if we will record the conversation. Blue Sky Group, which administers the pensions on our behalf, may use these recordings for training its employees. The recordings of phone calls are stored securely so they are not accessible to unauthorized persons. The recorded calls are not retained longer than necessary for the purposes stated above.

Mars Pension Fund uses cookies. A cookie is a small text file that is placed on your computer, tablet or cell phone when you visit our website. Cookies make using the Fund’s website easier and faster. Read more about cookies in our cookie statement.

Under the Pensions Act, communication in relation to personal information must align as much as possible with the information needs and characteristics of the member, deferred member, partner, ex-partner or pensioner. Mars Pension Fund uses profiling for this purpose. We then use segmentation to inform you as personally as possible about your pension. On the basis of your data, we determine which target group you belong to. Examples include type of pension plan, age cohort, group (member, deferred member, pensioner), pension accrual start date, and risk profile. These target groups then determine how and for what purpose we communicate with you. 

Mars Pension Fund does not use automated decision-making in addition to profiling.

If we process your personal data, you have certain rights. We explain these rights in more detail below.

Right of access

You have the right to access the personal data we process about you. If you want to know that the data we process about you are correct, you can check this on MyMarsPension. If you have further questions regarding the personal data we process about you, please contact us.

Right to rectification and completion

We want to keep your data up to date. If you find that your personal data are no longer correct, you can provide us with the correct data. The same applies if you find that the data we process about you are incomplete. 

Right to erasure of data (right to be forgotten)

You have the right to have your personal data at Mars Pension Fund erased. The Fund will erase your personal data if:

• the personal data are no longer required for the purposes for which they were collected or processed;
• you have withdrawn your consent to the processing, or you object to the processing on legitimate grounds (and there is no other legal ground for the processing);
• the personal data have been processed unlawfully; or
• the personal data must be erased on the basis of European or national legislation.

Right to restriction of processing

You have the right to restrict the processing of your personal data by Mars Pension Fund. Restriction means that we may not process the data, either temporarily or permanently. The processing of your personal data can be restricted if:

• you contest the accuracy of the data. In that case we may not use the data until we have verified their accuracy;
• processing your personal data is unlawful and you oppose erasure;
• the Fund no longer needs your personal data, but you do, for example for legal proceedings against Mars Pension Fund or third parties; or
• you have objected to the processing and the Fund has not immediately decided on the objection.

Once the processing of personal data has been restricted, those personal data may only still be processed if:

• they are only stored;
• you have given consent; or
• the processing is in connection with a legal action, the protection of the rights of other persons or important reasons of public interest.

Right to data portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit them unhindered to another controller (for example, another pension fund). 

This right applies only if the personal data is processed through automated systems and the personal data are processed solely on the basis of your consent. The right to data portability will not normally apply if you participate in Mars Pension Fund and are required to purchase a pension with the Fund. If you wish to request a transfer of pension claims to another pension provider, we refer you to the Mars Pension Fund pension plan. 

Right to object

You may object to the processing of your personal data if the processing is based on a legitimate interest. If you believe that a different weighing up of interests is required in your situation, you may inform Mars Pension Fund of this digitally or in writing (by mail).

After receiving your objection, Mars Pension Fund assesses whether it is justified. The Fund will cease processing if you object, unless we have compelling legitimate grounds for the processing that outweigh your interests, rights, and freedoms, or if the processing relates to a legal action.

You may submit a request to exercise your rights in writing (by mail) or digitally via MyMarsPension. If you submit your request in writing, send it to: Stichting Mars Pensioenfonds, P.O. Box 123, 1180 AC Amstelveen, Attn: Pension Service Department. 

Before Mars Pension Fund can process your request, we have to verify your identity. We may therefore ask you for a copy of your identity document (for example, your driver’s license or passport). The Fund requests this to avoid providing data to unauthorized persons. Please make your passport photo, Citizen Service Number (BSN), and the MRZ code (the strip with numbers at the bottom of the passport) illegible on the copy of your identity document. For example, you can use the Dutch central government’s KopieID app for this purpose. If you submit a request via MyMarsPension, no copy of your identity document is required. Mars Pension Fund will deal with your request within one month of receipt. If this is not possible, the Fund will inform you within one month of receipt of your request why we are unable to deal with it and specify a new deadline (a maximum of two months after that notification). 

If you have a question regarding how Mars Pension Fund handles your personal data, send your question to: Stichting Mars Pensioenfonds, P.O. Box 123, 1180 AC Amstelveen, Attn: Privacy Officer: pensioenservice@marspensioen.nl. 

If you have a complaint regarding how Mars Pension Fund handles your personal data, please submit your complaint or question digitally via pensioenservice@marspensioen.nl or in writing (by mail). If you submit your request in writing, send the letter to: Stichting Mars Pensioenfonds, P.O. Box 123, 1180 AC Amstelveen, Attn: Pension Service Department. 

You may also submit your complaint to the Dutch Personal Data Authority: https://autoriteitpersoonsgegevens.nl/en/contact