Privacy statement & cookies

Why do we have a privacy statement?

You share your data with holapedro regarding financing issues. This requires you to provide us with personal data of a financial nature and we consider your privacy important. We are therefore continuously working to find ways to protect your privacy as much as possible. We will process your data in accordance with the General Data Protection Regulation and hereby act as "data controller".

We may need to change our privacy statement if prompted by, for example, new privacy legislation. You will always find the most up-to-date version on our website. This version is dated 12 April 2024. We recommend that you consult it regularly.

In this statement, we are talking about holapedro, a label operating under the trade name NoMoreTalk. The official address of holapedro is Boschstraat 43, 4811 GC, Breda.

What data do we process?

Through holapedro, you can purchase various services which we divide into two categories, namely:

A financing check

Visit our website and use it for mortgage calculation;

Automated advice based on your entered data;

A mortgage consultation

Applying for a mortgage or mortgage consultation with one of our affiliated advisers or lenders;

Depending on which services you want to purchase, we request specific data.

Financing check

In case you only visit the website and use it for a calculation, we process the following data that you enter yourself:

• Personal data, such as your name, e-mail address, telephone number, address details, nationality and dates of birth.
• Financial data; such as income, ongoing charges, type of income collection and equity.
• Purchase plans, including purchase details, area interest, financial possibilities and success rate.

The data we use is entered by the applicant himself; without the use of data-sensitive documentation.

Mortgage consultation

When entering into agreement financing check, you agree to share your data with relevant third parties. It is possible to opt out of this. In this follow-up to the purchase of the product (mortgage advice), in addition to data from the financing check we may also process the following data and documents from you and any partner:

• IB returns;
• Documentation regarding income, position, letters of intent and employer details (in case of employment);
• In case of entrepreneurs: profit of business, financial key figures, Chamber of Commerce number, VAT number and relevant documents;
• In case of personal holding company: financial and income details from holding company;
• Amount of pension/benefit (in case of pension/benefit);
• Bank account number and bank statements;
• Capital position (for demonstration of own funds);
• Details of your current mortgage and home in the Netherlands;
• BKR data;

Your financial details are sensitive data. To apply for a mortgage offer, you need to fill in several (income) details.

However, we only request demonstrable details about your income, such as a payslip, income tax return, if you yourself decide to share these details with a mortgage adviser. Without these documents, thorough mortgage advice and the conclusion of a mortgage are not possible. Naturally, we protect your details as much as possible so that no one other than the mortgage advisor involved has access to them.

Why do we process this data?

Financing check

If you only use a no-obligation calculation on our website, we collect your data for the following purposes:

• To create personal environment to store your data;
• For record keeping, so that even several years later we can look at what your advice or application was based on;
• To process your payment to us;
• To perform proper financial calculation;
• For sending an invoice;
• To carry out statistical research, in order to further tailor our services to our target audience.

Mortgage advice

Do you request a personalised quote or take out a product with us? Then we additionally collect your data for the following purposes:

• For the performance of the agreement;
• For sharing your data with approved and recorded 3rd parties;
• For fulfilling the duty of care, for example by sending an email when important changes occur;
• For training and improving our staff;

Will your data be provided to third parties?

We provide your data to third parties necessary to process your data properly. In case of mortgage advice, only the relevant data are shared for entering into the agreement you enter into via our website. For example, if you want to receive mortgage advice from a recognised mortgage adviser or if you want to take out a mortgage with a lender and want to share documents through us and have actively indicated this in writing, we will forward your data to the relevant third party.

In addition, we may be required by law to share your data. This could include tax authorities, investigative bodies such as the police and judiciary, or regulators such as De Nederlandse Bank, Autoriteit Financiële Markten and Autoriteit Persoonsgegevens.

We have entered into processing agreements with all parties to whom we provide data, where possible. Through these agreements, we have a commitment that your data will be processed properly and securely.

Which parties have access to your data:

• ActiveCampaign: storage of personal data and limited financial data and purchase plans.
• Stripe: processing restricted personal data for payment processing.
• Airtable: storage of personal data, financial data and purchase plans.

Which parties may have access to your data (depending on the case)?

• Mortgage advisers on mortgage advice in Spain (including Spanish Mortgage SL, VOEP / Van Os en Partners Hypotheken & Verzekeringen B.V., IFAR).

How long and where do we keep your data?

We store your data on our own servers; these are based in Europe and comply with GDPR data protection legislation.

We also use external tools that store data in their chosen data storage location:

• ActiveCampaign: servers in Europe.
• Stripe: servers in Europe.
• Airtable: servers in the USA.

We keep all data for 7 years, for the sake of the obligation to keep tax records for verification purposes.

How do we secure your data?

holapedro handles your data with care. holapedro has taken adequate technical and organisational measures to secure your personal data against loss or unlawful processing. These include information security policies, training of our employees, secure servers where data is stored.

We also advise you to treat your data carefully and confidentially and not to share your login details or your personal data publicly.

We assume that, as an applicant, you yourself make an informed choice to share your personal data (including financial) with us. We do not oblige this provision of data, but we do need it to provide our services. The choice to make use of this always remains with the applicant.

When using social media, we recommend that you only exchange your data with us via a DM (Direct Message). We delete publicly shared personal data on holapedro's social media pages to the extent possible due to your privacy and security.

Cookies

holapedro uses cookies that remember your preferences to make navigating our website easier, for example. Cookies allow us to analyse visitor behaviour and improve our website. This website is also used by third parties to place cookies, such as Google Analytics.

What are cookies?

Cookies are small files that remember your preferences while browsing and store them on your own computer via the browser you are using. The information collected by cookies by holapedro and/or third parties may be used for the following purposes:

• For analytical purposes: to analyse the use of the holapedro website. Example: a record can be kept of how many visitors visit a particular webpage, so that holapedro knows which parts of its website are popular.
• For personal preference purposes: to facilitate visitor navigation, such as saving cookie preferences, webshop orders and any login.
• For advertising or marketing purposes: to show website visitors relevant and personalised ads, limit the number of times each ad is shown and measure the effectiveness of advertising campaigns.

What cookies does holapedro use?

Our website uses necessary cookies (for basic website functions such as page navigation) and cookies are set by third parties to analyse website visit behaviour (such as Google Analytics). In addition, marketing cookies are set that track behaviour at a personal level or use personal data for marketing purposes. These are placed only if you have given specific consent via the cookie notification.

If you consent to the setting of cookies, additional data can be used to improve the website. If you disable cookies, the experience of our website may be disappointing or reduce user convenience.

Refusing and deleting cookies

If you browse holapedro's website, you will be notified that we use cookies and that you agree when using the website. If you still want to unsubscribe from (certain) cookies, please read below how to do so:

• Desktop: move the mouse to the bottom left of the screen
• Click on the small pop-up in the bottom left corner labelled "Cookie Policy"
• The cookie notice appears at the bottom of the screen.
• Click "functional only" at the far right of the cookie notification.
• Your cookie preferences have been changed/saved.

Optionally, you can delete cookies from the browser. If you want to delete them via the browser you are using; you can do so in the following way:
Through the browser settings on your computer, you can delete cookies already placed and refuse the placing of new cookies. The way you do this varies from one browser to another. Consult the help function of your browser if necessary. Disabling cookies only affects the computer and browser on which you perform this action. If you use several computers and/or browsers, you must repeat this operation as often as necessary.
More information on steps to take can be found at: www.browserchecker.nl

Questions and requests for inspection, correction and deletion

If you have not yet taken out a product through holapedro, you can request us to delete your data at any time. You can do this by sending an e-mail to support@holapedro.nl.

If you have taken out a mortgage through us, we will keep your mortgage documents for the duration of the mortgage. The reason for this is that we have a legal duty of care for the concluded product during the term of the mortgage. In that case, we unfortunately cannot delete your file upon request.

If you want to know whether all the data holapedro has on you is correct, you can inquire. Within 4 weeks we will provide an overview of your data as known to us. You can send us a request for this purpose to support@holapedro.nl, enclosing a copy of your proof of identity. Holapedro may charge a fee for the request for inspection in accordance with the Decree on fees for parties involved in the WBP.

Filing a complaint

If you feel we are not handling your privacy properly, you have the right to lodge a complaint with the regulator. You can contact the Personal Data Authority for this purpose:

Version & disclaimer

holapedro reserves the right to make changes to this privacy policy. Changes will be published on this website. We recommend that you consult the privacy policy regularly so that you are always aware of the content of the applicable privacy policy.

This privacy policy is version 2.0 and was last modified on 12-04-2024