Privacy Policy

1. Introduction 📄

At bunq, your privacy matters. We’ll never sell or rent your personal data to anyone without your permission - because your trust is everything. In this Privacy Statement (“Statement”) you’ll find everything you need to know about what personal data we collect and how we use it.

bunq B.V. is the data controller responsible for processing your personal data.We’re officially registered with the Dutch Chamber of Commerce under registration number 54992060. Our headquarters are at Basisweg 32 1043 AP Amsterdam, the Netherlands.

To make sure we always handle your data in line with the law, we have a dedicated Data Protection Officer (DPO). If you still have any questions about the processing of personal data after reading this Privacy Statement,  feel free to reach out at privacy@bunq.com. Need to cancel your bunq account or have other account-related questions? Our support team is happy to help via the bunq app or support@bunq.com.

2. What data does bunq collect? 📊

Personal data means any information that can be linked to a natural person. We collect your personal data in a number of ways. The types of data processing we perform can be found below:

When you use bunq, you share some personal data with us. This happens when you open an account, use our products and services, reach out to us through any of our channels, or visit our website.

We also receive data from public registers and third parties like other financial institutions or public authorities. Plus, if you're making payments, we may collect personal data from non-bunq users to process those transactions.

If you're using tricount, some of your data is processed too. You can check out the details in their privacy policy: tricount.com/en/privacy-policy

Opening a bunq account

To open bunq accounts, we can collect and process the following personal data:

• Identity information: First and last name; date, country and place of birth; nationality; gender; 

• Contact and address details: Residential address; telephone number; email address;

• Social security numbers and/or other tax identification numbers including the type of identification document, the issuing date and the issuing institution;

• Counter IBAN;

• Device data (such as type of device, operating system, IP-addresses and advertising ID’s);

• Cookies and usage data on how you use our products and services;

• Correspondence with bunq and support data (telephone, chat conversations and email);

• Additional documentation related to opening an account;

• ID Verification: a picture of an identification document made in the bunq app;

• Video identification data.

Use of the bunq app, websites and other services

While using our app, websites and other services, we can collect and use the following personal data:

• Contact details: First and last names, phone numbers and email addresses of the contacts in your phone’s address book; 

• Location data via GPS;

• Uploaded images/content;

• Device data of added devices and API-keys;

• Added aliases: bunq.me pages, telephone numbers and email addresses;

• Financial and banking data: product subscriptions and transaction history;

• Cookies & usage data:how you use and interact with our products and services;

• Marketing data: statistics related to our marketing campaigns and data to measure this;

• Correspondence with bunq and support data: telephone calls such as SOS calls, chat conversations, email, voice and screen recordings - the correspondence is recorded for purposes of follow up by bunq and quality assurance;

• Activity on bunq Together;

• Background location data: only if you choose to use our Card Protection feature or Travel Assistant;

• If you enable Finn for activities: we will provide recommendations for your future activities based on your and your friends’ past activities;

• If you enable Finn for budgeting: it will process your transactional and activity data and provide you with personalized insights about your spending habits

• Transactions: If you are a student and you receive a DUO ('studiefinanciering') on your bunq account, we will apply a discount to your Elite account. As a student outside the NL, you may also submit your student ID. See Terms & Conditions for more information. 

• Background location data: collected only with your active consent, for the purpose of enabling the Card Protection feature (feature that determines whether your card is within a 100km radius of you, allowing you to determine if your card has been stolen) or for enabling a Travel assistant (localized tips, assisting you in your travel destination).

• Biometric authentication: methods such as fingerprint scans, are not stored, used or shared in a format that allows us to reproduce the biometrical data.

Minors

We collect and process personal data from minors in accordance with this privacy policy only with parental consent when they become a bunq user and use our services. Parents are able to access their child’s account and hide certain features of the bunq app from them. The child will gain full access to the account when they turn 18 years old,

Finn

We use artificial intelligence (AI) throughout your experience with the various bunq interfaces. All information on the bunq platforms is provided in English. For your convenience we use AI to translate into your language of choice, where available. In case of conflict, the English version will always prevail.

We have an artificial intelligence (AI) assistant called Finn that you can use in the app for any general questions you may have and to help you organize and pay your invoices in bulk. The context in which Finn operates is your data and your use of bunq's services. 

Finn is also present throughout the app, where he may offer proactive advice, tips, and suggestions based on your activity and usage patterns. We will not, without your explicit consent, use Finn to make automated decisions which produce legal effects concerning you or similarly significantly affect you. 

Finn is involved in processing customer support tickets: it can respond directly to questions submitted by users, as well as provide suggestions that bunq support can review and use as a basis for response to the user.  Finn will also answer the bunq user’s questions on their spending, accounts, group expenses, and app activity.

Finn is here to make your onboarding smooth and hassle-free as well. Once you submit your documents, Finn will review them and let you know if everything is good to go or if anything needs to be adjusted. That way, you’ll always have clarity on your next steps and can move forward with setting up your account without delays.

Finn also assists with customer support by answering your questions directly or suggesting responses that our support team can review and refine before getting back to you.

Finn also helps with your spending insights, group expenses, and app activity. If you enable Finn in your Activities or Budgeting tabs, it processes the data in those tabs, along with other relevant bunq account data, to provide personalized insights.

Finn also makes onboarding easier! Once you submit your documents, Finn reviews them and lets you know if everything looks good or if anything needs to be adjusted—so you always know your next steps without any unnecessary delays.

Open Banking

You can connect your accounts from other banks or payment institutions to your bunq app to see all your transaction data and balances in one place. To do this, you’ll need to give us explicit consent, specifying which accounts you want to link. Since this is a security-sensitive feature, you’ll need to renew your consent periodically.

Once you’ve given consent, we’ll collect and update your account data at regular intervals throughout the day, making it available in your bunq app.

If you ever change your mind, you can withdraw your consent at any time using our online tool. When you do, we’ll immediately stop collecting data from those accounts and delete any data we’ve already retrieved as soon as possible.

Employee cards

When you utilize Employee Cards as part of your bunq Business account, we process your personal data. We may collect and process employee names and transaction details to ensure seamless management and accurate reporting of financial activities. This data handling is conducted in compliance with applicable privacy standards, safeguarding the integrity and confidentiality of your team’s financial information.

By managing these aspects, you can efficiently track and oversee the financial activities conducted under your business account.

eSim

bunq offers an eSIM service that enables users to access mobile data services on compatible devices without the need for a physical SIM card. Use of this service leads to processing of your generated phone number.

3. What is the lawful basis for the processing of my personal data? ⚖️

bunq processes your personal data in line with the law and only when there’s a solid legal reason for it. Here’s what that means:

Legal obligations

We’re required to process certain personal data to comply with the law. This includes verifying your identity and sharing necessary data with governmental institutions when needed.

Contract performance

To provide you with our services smoothly and securely, we process your personal data.For example, we use your contact information to keep you informed about relevant developments, and we store correspondence data to improve our customer service.

Consent

Your privacy, your choice. For certain features, we’ll always ask for your explicit consent.For example, while using the app you can choose to provide access to your contact list, to upload images/content or to create a public bunq.me link. If you have given consent for a specific feature, you can withdraw it anytime directly in the app.

Legitimate interests

Sometimes, we process data because it’s necessary for a legitimate reason, like:

• Preventing and fighting fraud, misuse, or crime.

• Analyzing how our products and services are used to make them even better.

• Ensuring information and system security.

• Enhancing your overall user experience.

4. For what purposes does bunq use my personal data? 🎯

We use your personal data to:

• Follow the law – We comply with all relevant regulations and any requirements from supervisory authorities or judicial institutions.

• Provide you with our services – This includes processing payments, producing your bunq cards, securing your account, verifying your identity, and offering customer support.

• Improve our products and services – We analyze how you and other users interact with bunq to make things even better.

• Make our marketing more relevant to you – We personalize (targeted) marketing activities through different channels and measure how effective they are, based on your personal circumstances and how you use bunq.

• Prevent and fight fraud, misuse, and crimes – Your security is our priority.

• Let you create a Stocks account – If you open one, we process your data to enable it.

• Let you open a Credit line – If you’re eligible and choose to open one, we process your data accordingly.

• Keep bunq and the financial sector safe – Protecting the integrity of bunq and its users is key.

• Train and coach our team – We use data to improve how we help you.

• Build the best banking experience for you – We’re always working on making bunq even better, now and in the future.

5. Does bunq make automatic decisions based on my personal data? 🤖

Yes, when you use bunq, some decisions about you may be made automatically—this includes profiling.

You always  have the right to request a manual review of automatic decisions. For more information, please take a look at the ‘What are my rights?’ section of this statement.

Automated decisions are made in the following processes:

Opening an account

Our 5-minute rule is made possible by an automated system that reviews your application and approves or rejects it.

Fraud detection

We monitor how our services are used to detect fraud, money laundering, and other crimes, making sure our platform stays safe. If misuse is detected, we take action to prevent further harm.

Determining your eligibility to open a a credit line

If you apply for a credit line, we check your credit score using relevant credit bureaus. If you're not eligible based on this automated decision, you'll be notified via the bunq app.You can find more information in our Terms & Conditions.

6. Does bunq share my personal data with third parties? 🔗

To provide you with the best banking experience, we sometimes need to share certain personal data with third parties. But don’t worry—we keep this to a minimum and make sure they handle your data with the same level of care as we do.

These third parties are required to take strict security measures to protect your data. This includes signing Data Processing Agreements and following the standard contract clauses set by the European Commission for personal data protection.

Business Partners

We may share your personal data with our business partners who act on our behalf, or which jointly offer products and services with us. You can find an overview of the third parties or categories of third parties with whom we share data,  below. In some cases, their own privacy policies may also apply alongside this statement.

• Onfido Limited

To verify your identification document and identity, we use the services of third-party supplier Onfido Limited (Finsbury Avenue 3, EC2M 2PA London, United Kingdom).

• Wise

Wise makes it possible for you to perform one time FX-transactions without having to open a local currency account. If you wish to use the services of Wise in the bunq app, we share your personal data with Wise (56 Shoreditch High St, E1 6JJ London, United Kingdom). 

• TeleSign

In order to verify your identity, we use the services of third-party supplier TeleSign (13274 Fiji Way Suite 600, Marina del Rey, CA 90292, United States). 

• adjust GmbH

To analyze the use of our websites, products and services, and to measure the effectiveness of our (personalized) marketing campaigns, we use technology from adjust GmbH (Saarbrücker Strasse, 10405 Berlin, Germany).

• Mixpanel Inc. and Looker Data Sciences Inc.

For bringing together and analyzing the personal usage data from various sources, including your use of our websites, products and services and to carry out and measure the effectiveness of our (personalized) marketing campaigns, we use technology from Mixpanel Inc. (405 Howard Street, San Francisco, CA 94105, USA)) and Looker Data Sciences Inc. (1600 Amphitheatre Parkway, CA 94043, Mountain View, USA).

• Bird

The third party is used as a direct communications platform for emails / push notifications / in-app messages of bunq and Tricount users. The Bird privacy statement can be found here: https://bird.com/legal/privacy.

• AskNicely

In order to receive your feedback and to analyze and improve the usage of our services, we use the technology and services of AskNicely (63 Ponsonby Road, Ponsonby 1011, Auckland, New Zealand). For these purposes, personal data is shared to provide AskNicely’s services.

• Google LLC

To offer you smooth translations (on your request) and OCR related features (such as invoice and attachment scanning), we use the Cloud Translation and Cloud Vision API's from Google LLC (600 Amphitheatre Parkway, CA 94043, Mountain View, USA). We also use Google’s G Suite services, in order to improve the services we offer to you, by enhancing our information security and efficiency. Content will only be stored by Google temporarily (before being deleted) to provide the services, and Google does not claim any ownership of the content nor do they use it for any other purposes except for providing the requested services.

To verify your address, assure your bunq cards arrive at the correct address and for fraud prevention, we also use the services of Google Places API from Google LLC (600 Amphitheatre Parkway, CA 94043, Mountain View, USA). For these purposes, location and usage data is shared to provide and help improve the services. Further information regarding Google’s data privacy policy can be found at policies.google.com/privacy.

• Google Gemini

To make certain processes more efficient, bunq uses the services of Google Gemini, a generative artificial intelligence chatbot developed by Google. The vendor’s API is used for: document review, transaction monitoring, onboarding, customer support, and allows Finn to be accessible to our users. For more information, see here.

• Mobile payments

To offer you Apple Pay and Google Pay services, we use the technology from Apple Inc (One Apple Park Way, Cupertino, CA 95014, USA) and Google LLC (600 Amphitheatre Parkway, CA 94043, Mountain View, USA). When you decide to use these services, please take notice of the separate terms and conditions with regard to data sharing.

• MaxMind

To verify your location, assure your bunq cards arrive at the correct address and for fraud prevention, we use the technology of MaxMind (14 Spring Street, MA 02451, Waltham, USA). For these purposes, location, usage data and your e-mail address is shared to provide and help improve the services.

• Cash Payment Solutions

To offer you the services of Cash Payment Solutions to be able to deposit and withdraw cash at various locations where available, we use the services of Cash Payment Solutions GmbH (Wallstr. 14a 10179 Berlin, Germany). For these purposes, data is shared such as location data in order to show you their nearest locations.

• Currence

For the use of the online identification tool 'iDIN' we use the services of Currence (Gustav Mahlerplein 33-35, 1082 MS Amsterdam, The Netherlands). Certain personal information is shared for the purpose of verifying your identity.

• TapiX

In order to offer you the bunq features Insights and Subscriptions, we make use of the services of Tapix (Dateio s.r.o., Impact Hub Praha, Drtinova 10, Praha 5 – Smichov, Czech Republic). For these purposes, anonymized payment information is shared, for TapiX to enrich your transactions with details about your payment and to offer you with an overview of all your subscriptions.

• Vonage

In order to offer you the ‘SOS’ feature, which can be found on bunq.com/contact,  we need to record and transcribe your conversation with us. To help us with this, we use the services of Vonage (Nexmo Inc., 23 Main Street, Holmdel, NJ 07733 USA). Your personal data is only processed if you make use of this service.

• Externe Verwijzingsregister (EVR)

When you want to open a bunq account, we check your details against the EVR. We may also include your details in this register in case we have a reasonable ground to believe that your bunq account is being used for fraudulent activities. More information about the EVR can be found here: together.bunq.com/d/55920 

• Incode

To verify your identification document and identity, we use the services of third-party supplier Incode (221 Main St Ste 520 San Francisco, CA, 94105-1983 United States). The party processes biometric information, allowing bunq to meet its customer identification obligations under Anti-Money Laundering law. 

Furthermore, bunq has engaged Incode agents for purposes of user review at onboarding. Their privacy policy can be found here: incode.com/privacy-policy/. 

• CHEQ

To ensure that bots and other forms of fake traffic do not affect your experience of using our website, we use the services of CHEQ AI Technologies Ltd (23 Yehuda HaLevi Street, Tel Aviv 65136) to block such traffic. The Privacy Policy of CHEQ can be found here: cheq.ai/privacy-policy/. 

• Sardine

To counter fraud and money laundering, as well as to conduct risk checks, we use the services provider Sardine (382 North East 191st Street, Miami, sardine.ai/). By sharing your behavioral data with Sardine, we strengthen our efforts to counter money laundering and fraud. 

For fraud prevention purposes only,  Sardine will:

(1) collect your Battery Usage, Device Identifier, Device Storage, MAC Address, and SIM information; 

(2) collect enough information to determine if you are trying to fake your current location by using a VPN, VPN apps with location spoofing, or other related tools.

• Microsoft Azure

To make certain processes more efficient, bunq uses the services of Microsoft Azure OpenAI (Redmond, One Microsoft Way, United States, azure.microsoft.com). The vendor’s API is used for: document review, transaction monitoring, onboarding, customer support, and allows Finn to be accessible to our users.

• AWS Anthropic

To make certain processes more efficient, bunq uses the AI models of AWS Anthropic. The vendor’s API is used for: document review, transaction monitoring, onboarding, customer support, and allows Finn to be accessible to our users.

• Checkout.com

To allow you to top up your bunq account using debit and credit cards, bunq has partnered with Checkout.com (London, N1, 1 Shepherdess Walk, United Kingdom). You can access the privacy policy of Checkout.com here: enterprise.craft.co/privacy. 

• Barzahlen

Users residing in Austria or Germany have an option in the bunq app called “Withdraw & Deposit” provided through bunq’s partnership with Barzahlen. You can find Barzahlen’s privacy policy here: barzahlen.de/privacy-notice

• Adyen

Adyen (Simon Carmiggeltstraat 6-50, Amsterdam, Noord-Holland, 1011DJ) is a Payment Service Provider that processes payment transactions of bunq users. Adyen’s privacy policy can be accessed here: adyen.com/policies-and-disclaimer/privacy-policy.

• Stocks services

To provide bunq users with the ability to invest in stocks and exchange-traded funds (ETFs), we use the services of Ginmon (broker) and Upvest (custodian). When you choose to use the Stocks product, you will accept the privacy statements of these parties and be subject to both processing and controllership of these parties. bunq will share your data with Ginmon and Upvest to facilitate the creation of your account, transactions to purchase stocks, and other functionalities.

If you share your contacts with bunq and have the toggle for sharing your stock purchases with friends on (“What’s happening” in the Stocks settings), your contacts will see the stocks purchases you make. You can always turn this off in your Stocks settings.

• Algoan

To check your eligibility for opening a credit line, we share your data with Algoan (Morning, Laffitte, 34 Rue Laffitte, 75009 Paris, France), a credit decision-making platform. They perform automatic decision-making using your data, if you apply for a credit line, to determine your eligibility for the credit limit you are applying for.

• Taktile

To determine your eligibility for opening a credit line, we share your data with Taktile (Schönhauser Allee 9, 10119 Berlin, Germany), a credit decision-making platform. The platform allows bunq to determine if you are eligible to receive credit and to pull data from credit bureaus.

• Experian

The German credit bureau collects German user’s personal data and shares it with bunq upon their onboarding, to determine the user's debt and bankruptcy status. The API connection is performed through Taktile, described above.

• DuckDuckGoose

The purpose of using DuckDuckGoose is to have access to explainable AI solutions to uncover deep fakes. It will be used as an additional digital identity verification to distinguish between deep fakes and real selfies/facial biometrics provided at onboarding. It is used for authentication purposes, to detect fraudulent onboarding. The processing does not involve automated decision-making; all output by AI is validated and implemented by a bunq agent.

DuckDuckGoose is headquartered in the Netherlands. Their privacy policy can be found here.

• Kraken

The third party, Kraken, offers crypto services via the bunq app. It is headquartered at San Francisco, 237 Kearny Street Suite 102, United States (processing is subject to Standard Contractual Clauses). They are controllers of the data they process to maintain your wallet. bunq is a controller for purposes of your identification. You will be asked to identify yourself at opening of a crypto account with bunq, if you have not done so or if your identification document is expired. This processing is subject to Anti-Money Laundering/Counter-Terrorist Financing regulations. 

If you would like to exercise your rights with regards to processing of your personal data, please reach out to us via support chat or privacy@bunq.com. See Kraken’s privacy statement here: https://www.kraken.com/en-nl/legal/privacy. 

If you share your contacts with bunq and have the toggle for sharing your crypto purchases with friends on (“What’s happening” in the Crypto settings), your contacts will see the crypto purchases you make. You can always turn this off in your Crypto settings.

• Other parties

  • Parties for producing and delivering bunq cards;

  • Email, marketing and ad services and social media platforms for managing and executing service emails, direct marketing emails, setting up marketing campaigns and helping us track usage of our website;

  • If you grant bunq access to your phonebook, the existing bunq users in your phonebook will receive a notification that you became a bunq user;

  • SMS providers for sending SMS messages;

  • (Outsourced) customer support services;

  • Financial institutions for processing transactions and safeguarding the safety and integrity of the financial sector;

  • Notaries for helping you set up your company;

  • Legal consultants or auditors for complying with our own legal obligations and for any legal claims;

  • Internal communications tools used by bunq may store communications that contain personal data;

  • We may share your personal data with other bunq entities and branches. We may do so to provide and improve our services to you and to enable us to comply more efficiently with the applicable laws.

A Data Processing Agreement or equivalent agreements have been signed with each of the ‘Other parties’ listed above. If any of them are located outside the EU, we ensure that standard contractual clauses provided by the European Commission are signed to protect your data.

Governmental, supervisory and judicial institutions and authorities 

To comply with laws and regulations—or when there’s a legitimate reason—we may share personal data with public authorities, regulators, tax authorities, and judicial or investigative bodies.

For example, we may need to:

• Submit anti-money laundering reports to the FIU.

• Provide financial data to tax authorities upon request.

• Share data with the Dutch Central Bank as part of the Deposit Guarantee Scheme.

• Comply with legal obligations to assist investigative authorities in preventing and fighting fraud, misuse, and crime.

To help protect the banking system and make filing tax returns easier for you, we also share your Tax Identification Number and the description of your sub-accounts with the tax authorities.

What is scraping and how can I protect myself?

We go above and beyond to keep your personal data safe, but no internet transmission is 100% secure. While we do everything we can to protect your information, we can’t guarantee absolute security once data is sent or stored. That’s why it’s important to stay mindful of what you share online.

Once we receive your data, we apply strict security measures to prevent unauthorized access. However, depending on your account settings, certain personal information—like your username, profile photo, or contact details—may be visible to other users or third parties to enable specific services.

To stay in control, regularly review and update your settings in the bunq app to decide what information you want to share.

7. How long does bunq store my data? ⏳

We process and store your data for as long as you remain a bunq user. ​​We only keep your data for the time necessary to fulfill the purpose of collection. You can request us to close your account at any time and delete your data after account closure. However, some data may need to be retained due to legal or regulatory requirements.

In some cases, we may store personal data for longer—if we have a valid legal reason or if the data has been pseudonymized or anonymized in a way that protects your privacy. 

8. What are my rights? 🛡️

Below we have outlined the rights the GDPR (General Data Protection Regulation) grants you and what they mean for you as a bunq user.If you would like to exercise any of these rights, just send a request to privacy@bunq.com.

9. Revoking consent & limiting access 🚫 

Direct marketing

If you prefer not to have your data used for direct marketing activities, you can let us know anytime via the bunq app. Additionally, every marketing email we send includes an option to unsubscribe.

GPS and access to your contact list

While using the bunq app, you may grant permission to access your contact list and to process location data (e.g., for the card protection function). If you no longer want us to use location data, or if you no longer want to provide access to your contact list in the bunq app, you can easily revoke these permissions by going to Settings in your bunq app. You can withdraw consent at any time. 

Uploaded images/content

Any images and content you upload to personalize your bunq account or improve your app experience are processed by bunq. You can update or remove these at any time within the app. 

Public bunq.me profile

When you create a public bunq.me profile, your nickname and IBAN are visible for anyone that visits your public bunq.me profile for making payments. You can deactivate your bunq.me page with the accompanying data at any given time via the bunq app.

Phone number, email aliases and bunq Elite Plan

At signup, we link your phone number and email address to your bunq account as aliases. This allows other bunq users to easily and safely transfer money to your bank account(s), as your bunq account (and IBAN) will show up in their contact list if they have added you to their phone contact list with your phone number and/or email address. The processing of your aliases for these purposes is based upon bunq’s legitimate interest in ensuring seamless transactions and fraud prevention. Furthermore, it gives bunq users certainty that money is transferred into the correct account. If you wish to opt out, you can disconnect your aliases via the account settings. 

We will also show other bunq users on Together and in the app that you are on bunq Elite plan. You can disable this feature in your account settings.

Cookies

For more information on how to manage or block cookies, please see our Cookie Statement.

Recommendations and Activities

To offer you bunq Recommendations, we share certain information with other bunq users who have you in their contact list.Users who have your alias (see above) in their contact list will be able to see your recommended places, public nicknames and public avatars.

Sharing these data under Places occurs only with your explicit consent, which you can revoke anytime via the bunq app.

Stocks

When it comes to sharing the details of your stock purchases in the bunq app, the choice is entirely yours.

For anyone to view your stock trades, the following conditions must be met:

1. Contacts List : You must have the individual in question saved in your contacts within the bunq app. Only those who you have deliberately added can be considered to view your trades.

2. Sharing Preferences : You must actively choose to enable the "Share trades with friends" feature. This ensures that you have explicitly agreed to share your trading activities with your selected contacts.

In summary, you are in full control over who sees your stock trades. You decide with whom you share this information by managing both your contacts and your sharing settings. This empowers you to share your trades only with trusted individuals.

10. Changes to the Privacy Statement 🔄

We are always improving and expanding our products and services, which may lead to changes in how we process data. Whenever we change something, we adjust our Privacy Statement accordingly. You can always find the latest version on our website and in the app.

11. Complaints 🗣️

If you have concerns about how bunq processes your data , you can contact our Data Protection Officer via privacy@bunq.com. 

If you are not satisfied with how we handle your complaint, you can escalate it to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).