We give you the power to share your personal data as part of our mission to make the world more open and connected. This policy describes what information we collect and how it is used and shared.
The following legislation applies to our processing of personal data: The General Data Protection Regulation (Regulation No. 2016/679 of 27 April 2016) and the Data Protection Act (Act No. 502 of 23 May 2018).
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.
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.
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:
Personal information that NewBanking collects in connection with the use of the NewBanking Identity platform:
The data owner’s profile on NewBanking.com will always show what data has been 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.
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:
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.
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.
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:
NewBanking will also give the specific third party access to the documentation that validates your identity.
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.
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:
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
Tel.: +45 33 19 32 00
Email: [email protected]
Last updated 2 February 2021