PAYDAY PRIVACY AND COOKIE STATEMENT

This Privacy and Cookie Statement was published on 25-07-2022.

Payday Privacy and Cookie Statement

This is the privacy and cookie statement of ABN AMRO Payday (“Payday”). Payday is offered by ABN AMRO Bank N.V. (“ABN AMRO”), which has its registered office at Gustav Mahlerlaan 10, 1082 PP Amsterdam, the Netherlands. ABN AMRO is the controller as referred to in the General Data Protection Regulation (“GDPR”).

What is Payday?

Payday is a payment service that (digital) labour platforms or temp agencies can use to provide their contractors or temp workers with immediate access to their earnings within the Payday mobile application.

Who is Payday for?

Payday is intended for digital labour platforms and their workers and temp agencies and their temp workers. The mobile application is intended to give (temp) worker insight into their earnings and the possibility of having their available earnings paid directly to their bank account, as known to the digital labour platform or temp agency.

Personal data

This Privacy and Cookie Statement explains how we handle your personal data if you use Payday. Please read the Privacy and Cookie Statement carefully before you make certain decisions.

What is personal data?

Personal data is information that says something about you. The best-known forms of personal data are your name, address, email address, age and date of birth. Personal data also includes your bank account number, telephone number, and IP address.

When do we process your personal data?

Obviously, we may not request or use your personal data without good reason. By law, we are permitted to do this only if 'the processing has a basis'. This means that we may only use your personal data for one or more of the following reasons:

Agreement

You have downloaded Payday and accepted the terms and conditions. We use your personal data to make your earnings visible and available in the mobile application, and to pay your earnings to your IBAN on demand.

Legal obligation

The law lays down many rules that we have to comply with as a bank. For example, we must store personal data and in some cases provide it to third parties, such as the Netherlands Public Prosecution Service in the event of financial fraud.

Consent

Sometimes we are required to ask you for your consent. You can read more about this in the section headed 'Using personal data with or without your consent'.

Legitimate interest

We have the right to use your personal data if we have a legitimate interest in doing so. In that case, we must be able to demonstrate that our interest in using your personal data outweighs your right to privacy. We therefore balance all the interests. We explain the situations in which this happens using a few examples:

1. We protect property and personal data belonging to you, to us and to others.
2. You will be sent relevant tips and offers relating to Payday's products and services.
3. We aim to keep efficient records and improve our data quality in order to provide you with the best possible service.
4. We conduct research to find out how we can improve our existing processes, develop products and services, and fulfil our legal obligations more effectively. We may use new technologies for this. We will consider which data we can use for developing, training and testing new technologies on a case-by-case basis.
5. We constantly search for appropriate ways to ensure the highest possible level of protection for your data and for ours.

What personal data does Payday use and for what purpose?

We use the following personal data relating to you for the following purposes:

1. Contact details

   First name and last name | Mobile phone number | Email address We use this information to identify you when you register and to contact you when necessary.

2. Job details

   Payday uses information such as the number of hours worked, the hourly wage, and taxes payable in order to provide a complete and accurate overview of your earnings through the platform or temp agency. This information is necessary for calculating your earnings (or provisional earnings) correctly, visualising your earnings and paying your earnings to you on demand

3. Payment and transaction details

   Details of payments made to your bank account or details of the platform from which a payment was received. This information is necessary for providing insight into incoming and outgoing transactions and calculating your wallet balance correctly.

4. Information relating to use of app

   Information, such as your IP address and the device you are using, is necessary for enabling access to the application, preventing fraud and improving the app.

5. Payslip or invoices

   Payday may consult your payslip or invoices whenever you, as a user of the app, wish to view your payslip.

Cookies and similar technologies

What are cookies?

A cookie is a small text file that stores certain information. Cookies are automatically offered to your web browser when you visit a website. The cookies are then stored on your computer, laptop, tablet or mobile phone (depending on which device you use to visit the website).

Payday uses analytical tools to measure the use of the app. This allows us to identify the most popular and user-friendly elements. We then use this information to optimise the app.

How can I disable cookies?

You can do this by changing your browser settings so that all cookies are rejected. Important! This may mean that the website does not function optimally. You can also specify in the web browser settings that you want to allow only certain types of cookies or want to be notified whenever a website wants to store a cookie.

The way you change the cookie management settings depends on the web browser you use. You can find information about this in your web browser's help function, or you can visit www.aboutcookies.org for a step-by-step explanation of how to manage cookies in most web browsers.

How can I delete cookies?

You can delete all the cookies that have already been stored on your computer, laptop, tablet or mobile phone by a web browser. The way you do this depends on the web browser you use. You can find information about this in your web browser's help function, or you can visit www.aboutcookies.org for a step-by-step explanation of how to delete cookies in most web browsers.

Who do we share your personal data with?

There are situations in which we need to provide your personal data to other people and organisations involved in the provision of our services. You can read more about them below.

Our service providers

We work with other companies that help us provide services to you, such as ICT service providers. We are not permitted to disclose your personal data to these parties without good reason. There are legal rules that banks must comply with in such situations. We carefully select these companies and enter into clear agreements with them on how they may use your personal data. We remain responsible for your personal data.

Sometimes we engage other parties that also provide services, such as lawyers, auditors and bailiffs. These parties bear their own responsibility for their use of your personal data.

Competent public authorities

Our supervisory authorities, the Dutch Tax and Customs Administration, the Netherlands Public Prosecution Service and other public authorities may ask us to provide personal data relating to you. The law specifies when we are required to provide this data.

What messages do we send you?

If you are a client of ours, we will send you product messages and service messages. You will always be sent these messages. We are also keen to share relevant tips and offers with you. If you are not interested, you can easily indicate that you do not wish to receive any tips or offers.

Product messages and service messages

If you are a client of ours, you will receive messages about Payday. We will then send you information to keep you informed about new product conditions, for example.

We will also send you service messages concerning us outages, for example. You always receive product messages and service messages from Payday and are not able to opt out of this.

How do we ensure your personal data is secure?

We go to great lengths to ensure the highest possible level of protection for your personal data:

• We invest in our systems, procedures and people.
• We make sure that our working methods are in keeping with the sensitive nature of your personal data.
• We train our people how to keep your personal data safe and secure.

Security is our shared priority. If, for example, you encounter breaches in our security, you can report them to us confidentially by writing to Payday at payday.support@nl.abnamro.com.

Warning system used by banks

Financial institutions in the Netherlands have developed a warning system to protect the safety and security of ABN AMRO and the financial sector. This system allows the banks to check whether a person:

• has ever committed fraud,
• has tried to commit fraud, or
• somehow forms a threat to the safety and security of the banking sector.

For more information about this warning system and its workings, please visit the website of the Dutch Banking Association.

How do we determine the period for which your personal data is stored?

We keep personal data in any event for as long as is necessary to achieve the purposes for which they have been collected.

The GDPR does not stipulate specific retention periods for personal data. Other legislation may specify minimum retention periods, however, which we must comply with. Such legislation includes the general requirement for businesses to keep records, as set out in the Dutch Civil Code, tax laws or laws governing financial enterprises in particular (such as the Dutch Financial Supervision Act).

Personal data is deleted or anonymised once the storage periods have ended. Certain personal data may be kept for long for various reasons, for instance as part of our risk management, for security reasons, or in connection with claims, investigations or lawsuits

When personal data is kept for longer than the retention periods, we take measures to ensure this personal data is only used for purposes that require a longer retention period.

What rights do you have, and what can you do?

What rights do you have when it comes to your personal data? And what do these rights mean?

Right to object

If we use your personal data based on a legitimate interest, you have the right to object. It may be the case that you do not want us to use your personal data for profiling. In certain situations, however, we are permitted to do this even if you object, for instance to prevent fraud, manage risks or investigate unusual transactions. In such situations, we will of course comply with the law.

Right of access, right to rectification, right to be forgotten, right to restriction

1. You have the right to demand an overview of all personal data relating to you that we use for Payday.
2. If your personal data is incorrect, you can ask your platform to change your personal data.
3. You can ask us to delete your personal data at any time. We are not always able to do this, however, and do not always have to comply with your request, for example if we are required by law to keep your personal data for a longer period of time.
4. You can also ask us to restrict the use of your personal data on a temporary basis. This is possible in the following situations:
   1. You think that your personal data is incorrect;
   2. We use your personal data wrongfully.
   3. We no longer require your personal data, but you still need your personal data (for example following the storage period) in order to bring, exercise or substantiate a claim;

Right to data portability

Do you want to receive the personal data that you have provided to us and that we store by automated means for the purpose of performing a contract? We can arrange this, but only if we process your personal data on the basis of your consent or on the basis of the contract we concluded with you. This is referred to as data portability.

Please keep your personal data secure

• If you want to provide your personal data to any party, please check the purpose for which that party wants to use your personal data. For example, you can read the privacy statement on that party's website.
• If you want to receive your personal data, please make sure that your own equipment is adequately secure and has not been, or cannot be, hacked. Your financial information is very valuable for criminals.

If you want to receive the personal data we hold on you or arrange for it to be passed on to another party, you can submit a request to us through the ‘Clients’ rights’ page on our website.

Do you have a complaint or question, or is anything unclear?

If you have any questions, ideas or complaints about Payday, please send an email to payday.support@nl.abnamro.com.

If you have specific questions about this Privacy and Cookie Statement, you can contact the Data Protection Officer: privacy.office@nl.abnamro.com.

If you do not agree with the way in which we use your personal data, you have the right to lodge a complaint through the ‘Clients’ rights’ page. You also have the right to submit a complaint to the Dutch Data Protection Authority.

Do you want to read this Privacy and Cookie Statement at another time?

You can save our Privacy and Cookie Statement on your smartphone, tablet or computer. Alternatively, you can send it to your email address in PDF format.

Changes to the Privacy and Cookie Statement

Changes to the law or our services and products may affect the way in which we use your personal data. If this happens, we will make changes to our Privacy and Cookie Statement and notify you of these changes. We will post any changes on our website or in the Payday app.