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Privacy Policy

Privacy Policy

(Version 2.0 – Date 31.01.2017)

In the following Privacy Policy, we shall inform you about the collection, use and processing of personal data when using our website www.n26.com (hereinafter: "Website"),our web application (hereinafter: “Web App”) and our mobile app (hereinafter: “App”; jointly called: “Services”). Insofar as information refers exclusively to our Website, Web App or App, we shall explicitly point this out to you.

In general, it is possible to use our Services without providing any personal data. Insofar as personal data are collected via our Services, this shall take place, as far as possible, on a voluntary basis.

We shall therefore only collect, process and use your personal data pursuant to the following Privacy Policy. In this context, personal data means all detailed information about personal or factual circumstances of a specific or identifiable natural person, such as e.g. your name, your telephone number or your address.

Your data will only be transmitted to third parties if this is necessary for the performance of the contract or if you have previously consented to this.

We would like to point out that there are inherent security risks in the transmission of data via the internet (e.g. in communication via email). It is thus not possible to guarantee complete protection of data from access by third parties.

I. Responsible authority

The authority responsible for the collection, processing and use of personal data within the context of the Federal Data Protection Act is:

N26 Bank GmbH,
Klosterstrasse 62,
10179 Berlin

Email

datenschutz@n26.com

You will find more detailed information regarding N26 Bank GmbH (hereinafter "N26 Bank") in the Impressum.

For the technical provision of our Services, N26 Bank is supported by N26 GmbH, Klosterstrasse 62, 10179 Berlin and is bound by its instructions. With regard to the collection, use and processing of data within the framework of our Services, there is a written agreement between N26 Bank (Client) and N26 GmbH (Contractor) concerning contract data processing pursuant to sec. 11 of the Federal Data Protection Act (BDSG).

II. Data collection in case of informational use of our Website and Web App

If you visit our Services purely for informational reasons (and do not open a current account with N26 Bank),we shall not collect any personal data, with the exception of the data which your browser or your end device transmits in order to enable your visit to our Website or Web App. Thereby, the following data will be transmitted to N26 Bank:

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/http status code
  • Volume of data transferred
  • Website (from which the request comes)
  • Browser
  • Operating system
  • Language and version of the browser software
  • Advertising Identifier (IDFA)

Additionally, through the use of our Website and Web App, Cookies will be stored on your end device. You will find further information on the Cookies used under VI.

III. Data processing within the framework of N26 products

1. Data collection and processing in case of opening and using the N26 current account.

The following data will be collected, used and processed by N26 Bank for the purpose of opening a current account with N26 Bank ("Sign-up") and using the Services of N26 Bank:

  • First name and surname
  • Date of birth
  • Place of birth
  • Email address
  • Nationality
  • Registered address
  • Mobile telephone number
  • Identification document including (for details see III.)
  • Type of identification document
  • Issue date
  • ID number
  • Issuing authority

Additionally, N26 Bank is legally obligated to document and store your payments and transfers processed within the framework of your use of the current account.

The Moneybeam service is available to you within the framework of use of our current account. You can send money to your contacts via MoneyBeam without knowing their bank details. If the recipient is also an N26 customer, the transactions will be carried out in real time. To enable this, N26 Bank will access your contacts stored on your end device. Furthermore, as a current account holder with N26 Bank, you are visible to your contacts if they are also customers of N26 Bank. N26 Bank shall only access your stored contacts if you previously consent to this. You will also only be visible for other customers of N26 Bank if you have previously expressly consented to this or enable this subsequently in the system preferences.

2. Data transmission within the framework of N26 Black

In order to facilitate your insurance cover within the framework of N26 Black, we collaborate with AWP P&C S.A. (branch for the Netherlands, which operates as Allianz Global Assistance Europe and is a member of Allianz Group). For this purpose, we will transmit your first name and surname, date of birth, email address, N26 reference number and registered address to AWP P&C S.A.

3. Data transmission within the framework of N26 TransferWise

In co-operation with TransferWise Ltd., 6th Floor, The Tea Building, 56 Shoreditch High Street, London E1 6JJ, Great Britain (hereinafter: "TransferWise"),we offer “international transfers” from N26 current accounts. For the purposes of this service, we will transmit the data collected concerning your identification document, first name and surname, date of birth, registered address, telephone number and email address to Transferwise. Additionally, upon regulatory inquiry by TransferWise, N26 Bank is obligated to transmit to TransferWise the copy of your identification document created in the course of the process of opening your current account. TransferWise will use these data exclusively for anti-money laundering purposes prescribed by law. N26 Bank will only transmit your data to TransferWise if you previously consent to this data transmission.

IV. Identification procedure

N26 Bank is legally obligated to check your identity using a valid identification document within the framework of opening an account and to store specific information from the identification document. For this purpose, we offer you a Video-Ident procedure.

The execution of video identification is performed on behalf of N26 Bank by the service provider IDnow GmbH, Auenstr. 100, 80469 Munich (hereinafter: "IDnow"). Identity is thereby established by means of a web-based video identification procedure via an encrypted transmission path.

For this purpose, N26 Bank will transmit your personal data (first name and surname, date and place of birth, nationality, email address, sex, mobile telephone number, registered address, preferred language) to IDnow. IDnow will allocate a process number to these data, which will be communicated to you by N26 Bank and with which you can carry out the video identification. A secure video connection will be established between IDnow and your end device to enable the required direct visual contact. Thereupon, an employee of IDnow will check your identifying characteristics provided by us, on the basis of the identification documents. To prove the proper execution of the Video-Ident procedure, the employee must be able to access the camera of your end device and take photographs of you and the front and rear sides of your personal identification documents or the principal page of your passport. After taking the photograph of your identification document, the information on the photograph regarding height, eye colour and access number will be irrevocably blacked out by IDnow. This redacted photograph of your identification document will then be transmitted to N26 Bank. The telephone conversation held between you and the employee of IDnow will be recorded and stored for evidentiary purposes. The video image transmission will not be recorded. At the start of the video identification, the employee of IDnow will ask for your express consent to the taking of the photographs and the recording of the conversation. The data will be transmitted by IDnow to N26 Bank and deleted from the IDnow server within 90 days. If you do not wish for the creation of photographs or recordings.

During the video identity confirmation, IDnow must ensure the authenticity of the personal identity documents or passport presented by you. Additionally, the employee of IDnow must properly visually inspect the integrity of the identification documents and the respective optical security features of the identification documents. The IDnow employee will also ask you to read out the complete serial number on your identification documents.

To conclude the Video-Ident procedure, IDnow will send you a TAN via SMS, which you shall please confirm via the input field provided, upon request by the employee of IDnow.

V. Use of Cookies on our Website

N26 Bank uses so-called "Cookies" on the Website, i.e. text files which are stored on your access device. Cookies are smaller files with text information which are stored on your hard drive during retrieval of the offer. We use Cookies to make the navigation and use of our Website as user-friendly as possible. After your successful login to the protected area, we require the Cookies to identify and authorise you for the entire duration of your visit. However, Cookies also serve to store the preferences of the visitors. In this way, we are able to adapt the contents of our Website specifically to the requirements of our customers. We are not able to draw any references to customers with the Cookies. You can deactivate the option to store these Cookies at any time in the system preferences of your browser and delete any existing Cookies. Every user can also view the offer without Cookies. However, if you do not accept any Cookies, this may lead to a functional restriction of the Website.

Some of the Cookies used by us will be automatically deleted from your hard drive at the end of your browser session (Session Cookies). We also use Cookies which remain on your hard drive for a certain period after the end of your browser session (Persistent Cookies). Then on your next visit, the country and language you selected on your last visit to our Website will immediately be recognised. These Persistent Cookies will be stored on your hard drive and deleted by the browser after the prescribed period. These Cookies may also include Cookies from third-party providers (Third-Party Cookies).

N26 Bank will notify you of its use of Cookies upon your (first) visit to our Website and Web-App. You can prevent the use of Cookies at any time, with effect for the future, by deleting the Cookies and deactivating permission for the use of Cookies via your browser settings.

VI. Social Plugins

1. Use of Facebook plugins

Plugins from the social network Facebook (Facebook Inc., 1601 Willow Road, Menlo Park, California, 94025, USA) are integrated in our Services. You can recognise the Facebook plugins from the Facebook logo or the "Like button" on our page. You can find an overview of the Facebook plugins here:
http://developers.facebook.com/docs/plugins/.

If you visit our Services and click on the Facebook plugin, a direct connection will be established between your browser and the Facebook server. Facebook thereby receives the information that you have visited our site with your IP address. If you click on the Facebook "Like button" while you are logged into your Facebook account, you can link the contents of our pages to your Facebook profile. Thereby, Facebook can associate the visit to our Services with your user account. We hereby point out that as provider of the Services, we do not receive any information on the contents of the data transmitted or their use by Facebook. You can find further information about this in Facebook’s Privacy Policy at:
http://de-de.facebook.com/policy.php

If you do not want Facebook to be able to associate the visit to our Services with your Facebook user account, please log out of your Facebook user account.

2. Use of Twitter

Functions of the Twitter service are integrated in our Services. These functions are offered by Twitter Inc., Twitter, Inc. 1355 Market St, Suite 900, San Francisco, CA 94103, USA. By using Twitter and the "re-tweet" function, the websites visited by you are linked to your Twitter account and announced to other users. Data are thereby also transmitted to Twitter.

We hereby point out that, as provider of the Services, we do not receive any information on the contents of the data transmitted or their use by Twitter. You can find further information about this in Twitter’s Privacy Policy at http://twitter.com/privacy.

You can change your Twitter privacy settings in the account settings at:
http://twitter.com/account/settings.

3. Use of LinkedIn

Our Services use functions of the LinkedIn network. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (hereinafter: "LinkedIn"). If you visit our Services and click on the LinkedIn plugin (“recommend button”),a connection to the LinkedIn servers will be established. LinkedIn will be informed that you have visited our Services with your IP address. If you click on the LinkedIn “recommend button” and are logged into your LinkedIn account, it is possible for LinkedIn to associate your visit to our Services with your user account. We hereby point out that as provider of the pages, we do not receive any information on the contents of the data transmitted and their use by LinkedIn.

You can find further information about this in LinkedIn’s Privacy Policy at:
https://www.linkedin.com/legal/privacy-policy

4. Use of Instagram

Functions of the Instagram service are integrated in our Services. These functions are offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA (hereinafter: "Instagram"). If you are logged into your Instagram account, you can link the contents of our pages with your Instagram profile by clicking on the Instagram button. Thereby, Instagram can associate the visit to our Services with your user account. We hereby point out that as provider of the Services, we do not receive any information on the contents of the data transmitted and their use by Instagram.

You can find further information about this in Instagram’s Privacy Policy:
http://instagram.com/about/legal/privacy/

VII. Use of tracking technologies

1. Use of Google Analytics and Google Tag Manager on our Website and our Web-App

Our Website and our Web-App use Google Analytics and Google Tag Manager; web analysis services of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter: "Google"). Google Analytics and Google Tag Manager use so-called “Cookies”; text files which are stored on your computer/smartphone and which enable analysis of your use of our Website and Web-App. The information generated by the Cookie about your use of our Website and Web-App is generally transmitted to a Google server in the USA and stored there. However, within member states of the European Union or in other parties to the Agreement on the European Economic Area, your IP address will be previously shortened by Google on our Website and Web-App.

Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and abbreviated there. Google will use this information on behalf of the operator of this Website/App to evaluate your use of the Website, in order to compile reports about the Website activities and to render further services to the Website operator/App operator connected with the Website use/app use and internet use. The IP address transmitted by your browser within the framework of Google Analytics and Google Tag Manager will not be merged with other data from Google.

You can prevent the storage of Cookies by configuring your browser software accordingly; however, we hereby point out that in this case you may not be able to use all functions of our Website fully. Furthermore, you can prevent the collection of the data generated by the Cookie related to your use of our Website (incl. IP address) by Google as well as the processing of these data by Google, by downloading and installing the browser plugin available via the following link:
http://tools.google.com/dlpage/gaoptout?hl=de.

You can find more detailed information about this at:
http://www.google.com/intl/de/analytics/privacyoverview.html

(general information about Google Analytics and data protection). We hereby point out that, on our Website, Google Analytics are expanded with the code "gat._anonymizeIp();" in order to guarantee an anonymised collection of IP addresses (so-called IP Masking).

2. Use of Adjust in our App

The App of N26 Bank uses the Adjust usage statistics and analysis technology of adjust GmbH, Saarbrücker Str. 36, 10405 Berlin (hereinafter: "Adjust"). When you open the App, Adjust collects installation and event data, such as for example “App opened.” We use this anonymised information to understand how users interact with our App and to analyse mobile ad campaigns. Adjust uses your anonymised IDFA or Android ID as well as your anonymised IP and MAC address for this type of analysis. It is not possible to identify you individually.

3. Use of Crashlytics in our App

Our mobile App uses the crashlytics analysis programme of Crashlytics Inc. 1 Kendall Square, Cambridge, MA 02139, USA (hereinafter: "Crashlytics"); Crashlytics collects data on App use especially with regard to system crashes and bugs. Information on the device or the App version installed and other information will be used to help fix bugs, primarily with regard to the software and hardware of the user. You can find further information about this in Crashlytics’ Privacy Policy:
https://try.crashlytics.com/terms/privacy-policy.pdf.

4. Use of TrackJS on our Website and our Web-App

N26 Bank works with TrackJS LLC. (hereinafter: "TrackJS"). The TrackJS service collects data when our customers use our Website and our Web-App. This enables the analysis of technical errors such as HTTP and JS errors. You can find further information about this in the TrackJS Privacy Policy:
https://trackjs.com/privacy/

5. Use of SnowPlow on our Services

N26 Bank works with SnowPlow Analytics Limited (hereinafter: "SnowPlow"); with this service, in order to improve our Services and detect bugs in our systems, user information about our Services is collected with regard to the user’s navigation within our Services. You can find further information about this in SnowPlow’s Privacy Policy: https://snowplowanalytics.com/privacy-policy/.

6. Use of Finance ads on our Website

N26 Bank uses the Re-Targeting Tool of financeAds GmbH & Co. KG, Karlstrasse 9, 90403 Nuremberg (hereinafter: "Finance Ads"),in order to be able to inform you about advertising on other websites that may interest you. For this purpose, alias information about the use of our Services will be stored in Cookies and on this basis advertisements will be displayed on other websites. No usage profiles will be merged with your personal data as a result of this and no identifying information about your person will be disclosed to third parties. You can prevent the storage of Cookies via browser settings.

Alternatively, you can object to this data usage by setting an opt-out Cookie via the following link, which remains on the device until you delete the Cookies:
www.financeads.net/ueberuns/cookies/

7. Use of FinanceQuality on our Website

N26 Bank uses the FinanceQuality statistics tool. FinanceQuality.net is a service provided by Netzeffekt GmbH, Theresienhöhe 28, 80339 Munich. With the FinanceQuality tool, N26 Bank can record the online mediation achieved from other pages.

Alongside other optional tracking technologies, the use of FinanceQuality is based on Cookie/tracking pixel tracking. A Cookie is a text file which is stored on the user’s computer when they click on an advertisement/tracking link. The regular Cookie runtime is 30 days. According to information from FinanceQuality, only anonymised Cookies are used. Cookies do not contain any personal data of the user.

You can find further information about this in the FinanceQuality Privacy Policy:
https://www.financequality.net/agb/

8. Use of HasOffers on our Website

We work with TUNE Inc. ("HasOffers"). This service uses cookies and pixel tags to determine when affiliates/ partner websites refer new customers to N26. Further information can be found in the HasOffers privacy policy at:
www.hasoffers.com/privacy-policy

VIII. Retargeting – Use of Google Adwords (Remarketing/Conversion Tracking) on our Website

N26 Bank uses the Google Adwords service from Google. Our Website uses the Remarketing function from Google Adwords. This function serves to present visitors to the Website with advertisements tailored to their interests, within the framework of the Google advertising network. The Website visitors’ browser stores so-called "Cookies"; text files which are stored on your end device and which enable the user to be recognised when they access websites which are part of Google’s advertising network. On these pages, the user can then be shown advertisements related to content that the visitor has previously accessed on websites which use Google’s Remarketing function.

According to information from Google, it does not collect any personal data in this process. If you should nevertheless not want Google’s Remarketing function, you can always deactivate it by choosing the corresponding settings at http://www.google.com/settings/ads. Alternatively, you can deactivate the use of Cookies for tailoring advertising to interests via the advertising network, by following the instructions at http://www.networkadvertising.org/managing/opt_out.asp. You can find further information about Google Remarketing and Google’s Privacy Policy at: http://www.google.com/privacy/ads/.

IX. Email newsletter

In our email newsletter, we inform you about our offers. If you would like to receive the email newsletter, we require an email address from you. We will only send you our newsletter if you expressly consent to this as you open an account. We will thereby check whether you are the holder of the email address given or its holder is in agreement with receiving the email newsletter. This storage solely serves as proof in case a third party misuses an email address and registers to receive the newsletter without the knowledge of the entitled party. These data will only be used for sending the email newsletter and will not be disclosed to third parties.

In our newsletter, we use the Remarketing functions of the Salesforce Marketing Cloud from the service provider salesforce.com, Inc. The Landmark @ One Market Street, Suite 300, San Francisco, CA 94105, USA (hereinafter: "Salesforce"). If you consent to receiving our newsletter and visit our site via a newsletter, Cookies will be set which will enable N26 Bank to understand the customer’s interest in the newsletter.

Furthermore, in the email newsletter, Salesforce uses so-called Web Beacons. Web Beacons (also called ClearGIFs or tracking pixels) are small graphics (approx. 1x1 size GIF files) which among other things are set on websites or in HTML emails in order to provide the website operators with a better understanding of visitors’ interactions with the website. Web Beacons fulfil similar functions as Cookies, but they are not visible to the users. Information can be obtained via Web Beacons, in particular about whether the email was opened and whether the user’s system is capable of receiving HTML emails. No personal data is collected via the Web Beacon.

You can revoke your consent to storage of the data and the email address, as well as their use for sending the email newsletter, at any time. The revocation can be made via a link in the newsletter or via a message to the contact options below.

X. Transmission of personal data abroad

Insofar as N26 Bank transmits data to states outside of the scope of application of Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 for the protection of natural persons during the processing of personal data and for the free movement of data, N26 Bank shall ensure that the recipient of the data guarantees an appropriate level of data protection. In case of transmission to the USA, N26 Bank will obligate the recipient to observe and comply with the principles of the Privacy Shield (i.e. to recognise minimum standards in handling personal data). Additionally, in order to ensure an appropriate level of protection by the recipient of the data, we use the standard contracts of the European Union for the transmission of data outside the EU, as amended.

XI. Information, correction, deletion and revocation

You are entitled at any time to receive information free of charge about your stored personal data, its origin and recipient and the purpose of the data processing. Furthermore, in the cases listed in sec. 35 BDSG, you are entitled to the correction, blocking or deletion of your personal data. N26 Bank hereby points out that corresponding documentation may be requested in order to authenticate a person before its issue, because personal data is not allowed to be issued to unauthorised persons.

If you have granted consent to use data, you may revoke this at any time with effect for the future. The revocation of consent may cause our services no longer to be unrestrictedly available to you or the user relationship to be terminated. It is hereby pointed out that in some cases, collection and storage of data regardless of consent may be required by applicable law. In such cases, we will discontinue any further processing and use of your personal data and delete or block them, insofar as we are not obligated under statutory provisions to continue to process or in particular to store them.

Please direct all requests for information, queries or revocations regarding data processing via email to datenschutz@n26.com or in writing to the address specified in the Impressum.