Stichting Mars Pensioenfonds (hereinafter referred to as 'Mars Pension Fund', 'the Fund' or 'we') needs your personal data in order to provide its services. The personal data we process depends on the capacity in which you use our services. If, for example, you contact the fund, we will in any event process your contact details in order to be able to communicate with you. If you visit our website, we will process your IP address. If you are a member of Mars Pensioenfonds, we will process your personal data in order to execute your pension scheme. Mars Pensioenfonds considers it important that your personal details are handled with care and that we treat them confidentially. This is why the fund has made agreements on how it will process your personal data.
The processing of personal data concerns all the actions we may carry out with your personal data, from collection to destruction. The relevant agreements are set out in this Privacy Statement. In doing so, we comply with the General Data Protection Regulation (AVG).
The fund's Privacy Statement also explains which rights you have and how you can exercise them. In addition, you can read more about the protection and security of your personal data.
Who is responsible for your personal data?
Mars Pension Fund is responsible for the processing of your personal data.
Whose personal data do we process?
Mars Pension fund processes data relating to the following persons:
- all (former) participants and other beneficiaries of MPF and their family members, including partners, ex-partners and children
- all visitors to the website
- all those who contact us
- visitors to MPF
- (contact persons of) employers affiliated to MPF (these are all Dutch affiliated companies of Mars Inc.)
- (contact persons of) suppliers or business contacts of MPF
- (prospective) members for the bodies of MPF
What personal data do we process relating to you?
Any personal data we process from you will depend on what capacity you have with us. For example, if you are a member of MPF, then we process your personal data in order to administer and execute your pension and inform you as well as possible. (The latter is a legal obligation of us as a pension administrator). We can collect information about who you are, your financial situation, your employment and your family situation, but also data relating to your preferences or IT. We may also collect data relating to your preferences or IT data. For example:
- Name and (various) contact and communication details
- Your gender
- Date of birth
- Citizen's Service Number (BSN)
- Policy and employee number
- Bank account number
- Information and documents relating to your marital status (in the case of a marriage or registered partnership
In the case of a marriage or registered partnership, the details of the partner or ex-partner,
cohabitation agreement and divorce agreement)
- Details of your (former) employment(s)
- Details concerning the withholding and remittance of Dutch income taxes for
benefit recipients such as benefits and level of withholding
- Your entitlements / pension rights
- School certificate
- Indication of conscientious objector
- Details of any attachments
- Risk profile / investment choices
- Attestation de Vita (proof of life)
- Details of notification of death
- Details of your incapacity for work, such as percentage of incapacity for work
- Data on your children
- Other (personal) data that you actively provide in correspondence and by telephone
- Language and communication preference (written or electronic)
- Information about your activities on the participants' portal of our website
How do we come by your personal data?
We usually receive personal data from your employer or directly from you, but we may also receive it in other ways, such as from one of the following parties (if a source is a public source, we will always state this separately):
- Basic Registration of Persons (BRP)
- Former employer(s)
- Employee Insurance Schemes Implementing Body (UWV)
- Chamber of Commerce (this is a public source)
- Other pension providers
- Register of Non-Residents (RNI)
- Legal representative
- Judicial authorities
For what purposes do we process your personal data and is it legitimate?
Why Stichting Mars Pensioenfonds, also referred to as MPF, collects and processes your personal data
depends on what capacity you have with us. For instance, if you are a member of MPF, then we process your personal data in order to be able to administration of your pension as well as possible. But also to comply with legal obligations and contractual agreements. In order to do this as well as possible, your personal data may be used for the following purposes:
- Complying with pension and benefit legislation and regulations;
- Determining the amount and payment of pension entitlements and benefits;
- To calculate, record and collect premiums from employers;
- To carry out contractual agreements, e.g. on the basis of the pension agreement
Mars Inc. and you;
- To fulfil contractual agreements, for example under the pension agreement;
- To deal with disputes;
- To prevent fraud;
- To carry out statistical analyses and ALM studies;
- To improve the user friendliness of the member portal of the website ;
- For internal (quality) analyses and product development in order to improve the schemes and the services
- For adequate communication with you as participant;
- Archive management.
With whom do we share your personal data?
We may share your personal data with other parties if, and only if, this is necessary for the execution of the pension agreement or to comply with legal obligations. In order to guarantee the security and confidentiality of your data, we enter into a processing agreement with these parties if and insofar as the AVG prescribes this. Moreover, we remain responsible to you for these processes. The parties with whom your (personal) data may be shared can be divided into the following categories:
- Pension administration organisation
- Governmental bodies, such as the Basic Registration of Persons (BRP) and the Tax Authorities
- (Former) employer(s) and their authorised representatives
- Employee Insurance Schemes Implementing Body (UWV)
- Chamber of Commerce (KvK)
- Other pension administrators - Debt collection agencies
- Mailing processors and/or printers
- Archive storage
- Consulting and certifying actuaries
- Control parties e.g. for performing payroll checks
- ICT database/website management, security and maintenance companies
- Research parties
- Parties in the context of control purposes, reporting and disputes Lawyers and (financial, legal or strategic) advisors
- The bank for payment purposes
- Board members, members of various bodies of the pension fund
- Stichting Pensioenregister
We have outsourced the pension administration to Blue Sky Group B.V. (BSG). BSG therefore has access to your (personal) data. We have made agreements with BSG about how BSG will handle your details, with whom it may share them and how BSG must protect your details. Furthermore, we have concluded a processing agreement with BSG, which we review periodically, together with this privacy statement and other AVG-related documents, to keep them up to date. We only share your data with recipients outside the EU if this is allowed by privacy laws and regulations. This is for example the case if an adequacy decision of the European Commission is applicable or if adequate safeguards are in place, such as an agreement based on European Standard Contractual Clauses.
This is how we take care of your data
We take the protection of your data seriously and take appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised amendments. The measures taken meet at least the general requirements for information security. We make agreements about this with the processors and regularly evaluate the measures taken and, if necessary, have them adjusted. If you nevertheless feel that your details are not properly secured or if you have any other questions or complaints, you can contact BSG in the first instance, as they handle the entire administration on behalf of MPF:
BSG Pension Management B.V.
Prof. E.M. Meijerslaan 1
1183 AV Amstelveen
For questions directed to our address, please contact MPF at
Stichting Mars Pensioenfonds
5466 AE Veghel
How long do we keep your personal data?
We will not store your personal data any longer than is strictly necessary to realise the purposes for which they were collected. Because we deal with long-term pension commitments and as a pension administrator we have very long-term commitments, which means this can be a very long period. We keep your personal data necessary for administration of the pension agreement at least until the statute of limitations has expired after the end of your right to a pension or after the termination of the pension agreement.
If we no longer need your data, we will in principle delete the data.
Recording of telephone conversations
BSG may record telephone conversations if you call the BSG Pension Desk. BSG will tell you in advance (at the beginning of the phone call) if they are recording the call. These recordings will be used for training purposes of its employees. The recordings of the telephone conversations are kept secure so that they are not accessible to unauthorised persons.
If a call is recorded, you have the right, within the retention period, to a reproduction of the telephone conversation. Recorded telephone conversations are not kept longer longer than necessary for the above purposes.
Pursuant to the Pensions Act, communication regarding personal information is required to match as closely as possible with the information needs and characteristics of the (former) participant, former partner and pensioner. In this context, MPF may make use of profiling in order to better tailor our communication and services to your personal situation. Based on your details, we determine the target group to which we assign you. These target groups then determine how we communicate with you and for what purpose. Various tools can be used on the participant portals. These tools help participants to better understand their accrued pension(s) (capital) and the consequences of the various choices. Such tools are not used for automated individual decision-making, but only to provide an indication. A participant's final choice is always confirmed by a human action on the part of the pension fund. Furthermore, a participant always has the possibility to object to a decision on the basis of the complaints procedure.
How can you exercise your rights?
A request to exercise your rights can be submitted in writing (by post) or digitally. You can send your request to Stichting Mars Pensioenfonds, PO Box 123, 1180 AC Amstelveen, t.a.v. afdeling Pensioenservice. You may also send an e-mail to firstname.lastname@example.org.
We will have to establish your identity before we can deal with your request. We will therefore ask you to provide a copy of your driving licence, passport or identity card. We ask for this in order to avoid providing data to unauthorised persons. We will ask you to obscure the photograph, the citizen service number and the MRZ code on the copy of your driving licence, passport or identity card. We will deal with your request within one month of receiving it. The aforementioned rights are subject to different conditions and exceptions under the law. MPF assesses in each specific case whether these are the case.
Do you have a question?
If you have a question regarding how Mars Pension Fund handles with your personal data, send your question to Mars Pension Fund, Stichting Mars Pensioenfonds, Postbus 123, 1180 AC Amstelveen, t.a.v. de Privacy Officer: email@example.com.
Do you have a complaint?
If you have a complaint regarding how Mars Pension Fund handles with your personal data, send your complaint to the Privacy Council: firstname.lastname@example.org
You may also submit your complaint to the Dutch Personal Data Authority https://autoriteitpersoonsgegevens.nl/nl/contact-met-de-autoriteit-persoonsgegevens
Changes in this Privacy statement
We reserve the right to amend and update the privacy statement within the limits of and in accordance with the applicable privacy legislation. If necessary and possible, we will actively inform you about this. The latest version of this privacy statement is published on this page. We therefore recommend that you read this privacy statement regularly.
Amstelveen, June 2022