Privacy Policy

2. Introduction

As part of our efforts to make data sharing in the digital world more secure, NewBanking ApS, CRN (CVR) 38 99 49 99 (“NewBanking”, “we” and “our”) support the ability to share personal information securely and easily. This policy contains a description of the information we collect, how it is used, how it is shared and what rights apply.

This policy applies to all NewBanking brands, products and services for which there is no separate privacy policy, and covers the processing of personal data where we are the data controllers. NewBanking is the data controller when data is handled on the basis of the individual data owners’ (i.e. natural persons such as management members as well as companies) use of our platform “NewBanking Identity”.

In cases where we only process data based on instructions from our customers, NewBanking is considered to be a data processor, and enters into specific data processor agreements with our customers.

This policy also applies to data related to marketing activities.

3. Basis for processing

We only process personal information about our customers, users, counterparties, suppliers, employees and partners to the extent that there is a legal basis for this.

The processing of personal data includes activities such as collection, registration, storage, modification and searching, as well as the use of our services, including when initiating the sharing or transfer of data.

To use NewBanking Identity to share personal information, it is crucial that personal information is uploaded to the NewBanking Identity platform securely.

In situations where data is only shared with NewBanking Identity, the processing will be based on consent, cf. GDPR art. 6(1), letter a, as well as section 11(2), no. 2 of the Data Protection Act. If a data owner explicitly initiates data sharing with a third party, the legal basis for processing can change from consent to a requirement for fulfilment of a contract/agreement, cf. GDPR art. 6(1), letter b, or compliance with a legal obligation to the third party in question, cf. GDPR art. 6(1), letter c, e.g. in connection with AML, KYC or PEP obligations. Furthermore, depending on the circumstances, we may rely on our legitimate interest, cf. GDPR art. 6(1), letter f, e.g. to strengthen security and reliability, in the placement of functional and statistical cookies, for delivery, in the improvement and development of services, for responding to your requests, etc. Our legal basis for the use of marketing cookies is your consent, cf. GDPR art. 6(1), letter a.

The data owner’s profile on NewBanking.com will always state what data sharing applies to the individual data, including which third parties have access to the data.

In the following situations, we collect and process personal information:

When our platform is used
In case of company collaboration
When you sign up for our newsletter or participate in an event organised by us or a partner

4. What data is collected?

Personal information that NewBanking collects in connection with the use of the NewBanking Identity platform:

Name, address, phone number, email, date of birth
Job history, academic records, leisure activities
Civil registration no., copy of passport or driver’s licence or other information that makes it possible to identify you as a person
Other personal data, information, etc., contained in the documents and files that you choose to upload or share via our platform
Data can be retrieved from other data providers, including public data and data provided by private companies
We collect content and other information provided by you when you use our services, including the information you provide when you create an account, create or share things and write messages or communicate with others (e.g. companies). This may include personal and sensitive information in the data you provide, for example in the form of a passport and the information therein.

The data owner’s profile on NewBanking.com will always show what data has been collected.

5. Other data collected

We also collect information about how you use our services, e.g. the type of content you see or interact with, or the frequency or duration of your activities.

Device information

We collect information from or about the computers, telephones or other devices on which you install or access our services, depending on the permissions you have given. We may combine the information we collect from your various devices to provide you with consistent services across all of your devices.

Here are some examples of the device information we collect:

Properties such as operating systems, hardware versions, device settings, types and names of files and software.
Connection information such as browser type, language and time zone, mobile phone number and IP address.
We also place cookies on our website. You can always read the updated cookie information on our website https://www.newbanking.com/cookie-policy/.

6. How do we use the information?

Personal information uploaded or collected via the NewBanking Identity platform is used to facilitate data sharing between the data owner and a third party with an explicit basis for processing – see the list of legal bases above (for example when creating a bank account). In connection with explicit data sharing, data can be used for the validation of identity data and accuracy/existence, as well as possible registrations in external databases.

NewBanking only shares your personal information with external parties where this is necessary and there is a legal basis for this. Recipients can include law firms, accountants, banks, asset managers, the private equity fund, public authorities, etc.

NewBanking thus does not share information without explicit permission. It is always possible for a data owner to share personal information through NewBanking’s platform. All matters can be managed by logging in via https://www.newbanking.com/login/#/.

Use of other data collected

We use other data as a prerequisite for providing and supporting our services.

What we do

Delivery, improvement and development of services: We conduct surveys and research, test features under development and analyse the information we have in order to evaluate and improve products and services, develop new products or features, and perform revisions and troubleshooting activities.

Communication with you: We use your information to communicate with you about our services, and to inform you about our policies and terms. We also use your information to respond to you when you contact us.

Improving security and reliability: We use the information we have to verify accounts and activities, and to increase security and reliability in and outside of our services, e.g. by investigating suspicious activities or violations of our terms or policies. We work hard to protect your account with help from our teams of technicians, automated systems and advanced technology, e.g. encryption. We also offer easy-to-use security tools that add an extra layer of security to your account. We use cookies and similar technologies to provide and support our services and the various uses of these, which are listed and described in this section of our policy. Read our cookie policy for more information.

Data to third countries: NewBanking uses third-party service providers who store your personal information on behalf of NewBanking. All data is stored in an encrypted format, and cannot be accessed or processed by the third-party provider. In some cases, and in connection with the use of NewBanking Identity, a third party may request that personal data is processed outside the EU/EEA in connection with mapping the risks of international money laundering or terrorism financing. In such cases, this will be done in accordance with the provisions of the EU Commission’s standard contracts.

7. How data is shared

As previously mentioned, NewBanking does not share information without the permission of the data owner. NewBanking gives the user control over which third parties have access to what data – easily and securely through our platform.

Basis for sharing

NewBanking may facilitate that a specific third party is given the opportunity to use and process your information, subject to your explicit permission (consent or other basis for processing). This third party will have access as long as:

you do not explicitly withdraw your permission, or until the basis for processing lapses.
any time-limited sharing has not expired, or until the third party’s need for access lapses.

NewBanking will also give the specific third party access to the documentation that validates your identity.

8. Storage and deletion of data

Deletion of account

You should be aware that deleting your NewBanking account may have serious implications for your relationship with third parties, including possible termination of agreements.

You can request to have your account with NewBanking deleted at any time. If you wish to delete your account with NewBanking, please be aware that there may be parties with whom you have shared data who have a legal obligation to retain this data.

You can manage the content and information you share when you use NewBanking by logging in to our platform. You can also download information associated with your NewBanking account through www.newbanking.com/login/#/.

Storage and deletion

We store data for as long as is necessary to provide products and services to you and others, including the information described above. Information associated with your account will be protected until the account is deleted, unless we no longer need the data to provide products and services. Depending on applicable law (e.g. anti-money laundering legislation), we may be required to store your information even after you request that we delete it. In such cases, we will not store your personal information beyond what is required by law.

9. Rights

According to the provisions of data protection law, there are a number of rights in relation to our processing of personal data, with certain statutory exceptions. A large number of these rights are integrated directly into the NewBanking Identity platform, and can be accessed via NewBanking.com:

It is possible to see the information that has been processed, as well as a series of additional information (right of access)
It is possible to correct inaccurate information (rectification)
Depending on the legal basis for processing, you may delete or request to have information deleted (erasure)
You also have the right to object to the collection and further processing of your personal information (objection).
In addition, you also have the right to have inaccurate personal information corrected (correction).
It is possible to download personal information (data portability)
If the processing is based on consent, you can demand that your consent be withdrawn at any time (withdraw consent).

If you wish to exercise your rights or withdraw your consent as described above, you are welcome to contact us at [email protected] at any time. You can always contact NewBanking via [email protected], if you have questions about the privacy policy.

You can also read more about your rights on the Danish Data Protection Agency’s website, and find guidance on data subjects’ rights at www.datatilsynet.dk. You can also lodge a complaint with the Danish Data Protection Agency at:

Danish Data Protection Agency

35 Carl Jacobsens Vej

DK-2500 Valby

Tel.: +45 33 19 32 00

Email: [email protected]

1. Applicable legislation