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  • Question about bunq using Vanad Group services

A valid question. However, (before this thread may derail or people make incorrect assumptions), let’s wait for a response from bunq. As you can imagine they may be a bit busier than usual seeing the support situation.

    @Fabian-Green-Llama#103512 Ik begrijp je vraag volkomen. Maar helaas kan je zulk soort dingen niet kiezen. Ik bedoel: als bunq de privacy policy aanpast dan is dat zo. Je kan dan niet zeggen dat je wel support wil, maar niet van dat specifieke bedrijf dat bunq heeft ingehuurd. Het enige wat je dan kan doen is nooit meer support vragen of een andere bank zoeken.

      @JeroenE#103561 Well, I’m not a lawyer, but according to GDPR I think that it is mandatory for bunq to inform us when data is exchanged with third parties. Of course they can (and should) change this when needed, but then again inform us about the changed privacy policy.

      In the German privacy policy it says that bunq will never share my personal information with third parties without my consent. As far as I’m concerned, I did not consent to transfer my data to the company in question. So even if this kind of information isn’t mandatory for bunq, they should meet their own standards.

        @Fabian-Green-Llama#103581 Ja, dat is ook zo en daarom begrijp ik je vraag volkomen. Ze zetten er zelfs in dat ze informatie aan de belastingdienst geven en wie verwacht er nu dat ze dat niet doen?

        Maar wat ik bedoel is dat jij geen toestemming kan geven. Anders dan je bankrekening op te zeggen en weg te gaan. Helaas past bunq hun privacy policy sowieso pas aan als ze iets veranderen en geven ze dit niet bijvoorbeeld een maand van te voren aan.

          @JeroenE#103561 perhaps because of Google Translate, I don't understand your point. Bunq has to inform us via an update to the Privacy Policy if they send us to Vanad Group for support. They didn't inform us, so they should not have sent our data to them. I agree that if they had informed us and we had objections then we could not ask for support or find another bank, but this is not what happened.

          The lack of an update to the privacy policy is a big deal. It shows that bunq's compliance department is not doing their job, or they have been sidelined. If they are not compliant with privacy, where else might they be messing up?

            @AbuKarol#103589 Eerlijk gezegd heb ik wel vaker het idee dat de praktijk bij bunq voorloopt op de goede documentatie. Kijk hoe lang ze er over hebben gedaan om uit te leggen hoe of wat met de Freefomof Choice investeringen die je kan kiezen. En dan nog leggen ze maar drie van de opties uit en vergeten ze de rest.

              @JeroenE#103591 I'm OK with an innovative, branch-less bank. However I need their documentation to be as good as, or better, than a traditional bank. The lack of disclosure in the privacy policy about sending our data to Vanad Group rings alarm bells to me.

                @AbuKarol#103592 Jij volgt duidelijk ook nooit topics over het up to date houden van de API documentatie of SDK's 🙊

                  No, I don't. I'm interested from consumer (not a developer) point of view.

                    So, although I see your point about bunq informing us about outsourcing support, how is it any different from hiring temp. staff in house? The employees of Vanad Group are basically "bunq employees"? (disclaimer: I'm not a legal expert). Them being "temporary" bunq employees would (to me) seem as if they fall under the same NDA and regulations etc. etc. that current and former bunq employees are bound to. 🤔

                      @Sander#103639 That is a very interesting discussion. If Vanad ‘rents’ some people to work for bunq as in an employment agency, it would be fine if bunq would let the employee some piece of paper and the employee becomes some kind of 0-hours contract employee.

                      However, if he support would be outsourced partly to Vanad and the support employee would have the data of the customer in the Vanad location (which is highly unlikeable), it would be a breach of the GDPR.

                      I guess honestly bunq didn’t give any data to Vanad. Probably they just allowed some employees from Vanad into their bunq systems as they were temporary employees. Can’t see anything wrong about that.

                        @Sander#103639 how is it any different from hiring temp. staff in house? The employees of Vanad Group are basically "bunq employees"?

                        Well "basically" they aren't. Sure, their day-to-day occupation and tasks might "look" similar to in-house support in nature. But that's not the really the point in the discussion here.

                        The crucial point is their legal relationship with regards of the processing of customer data and its implications on data protection. And, just for starters, one thing couldn't be more obvious: I never entered into a contract with Vanad Group, but with bunq.

                        That's where the EU GDPR comes into play, having specific provisions for such external "processors" of data.

                        @DennisdeWitNL#103684 if he support would be outsourced partly to Vanad and the support employee would have the data of the customer in the Vanad location (which is highly unlikeable), it would be a breach of the GDPR

                        Why should it be a breach? That's a common model of outsourcing (and I think probably exactly what bunq where doing) - as I understand it, the GDPR specifically has provisions fot that - you just have to abide by them in doing so.

                          @NiB#103686 Let’s not guess about what exactly was parf of the deal in order to protect bunq and Vanad. Such situation knows only losers, no winners.

                            @JeroenE#103561 als bunq de privacy policy aanpast dan is dat zo. Je kan dan niet zeggen dat je wel support wil, maar niet van dat specifieke bedrijf dat bunq heeft ingehuurd

                            I don't think you can or should claim in your privacy policy to "keep the sharing to a minimum" and share data only with a limited set of third parties (or categories thereof) - and then fail to mention third parties that handle customer support.

                            @AbuKarol#103589 Bunq has to inform us via an update to the Privacy Policy if they send us to Vanad Group for support.

                            I don't think they have to do this for every single supplier individually, but (as is stated in their privacy policy), they can subsume that under "categories of third parties".

                            Though in contrast to "Card suppliers", "Email, marketing and ad services for managing and executing service emails, direct marketing emails and setting up marketing campaigns", "SMS providers " and "Payment institutions for processing transactions", they fail to include "customer support". Which is, a pretty big omission and (in my eyes) a clear misrepresentation.

                              @DennisdeWitNL#103687 Let’s not guess about what exactly was parf of the deal in order to protect bunq and Vanad

                              Honestly, there isn't much room left for "guessing", if we are taking bunq's own words from yesterday at face value:

                              (Quote) "This morning, Vanad Group decided to unexpectedly stop answering support questions altogether"

                              So it (allegedly) was "Vanad Group" that stopped answering support questions. Not 0-hours, temporary „hired through“ or whatever employees directly working for bunq.

                              @DennisdeWitNL#103684 if he support would be outsourced partly to Vanad and the support employee would have the data of the customer in the Vanad location (which is highly unlikeable)

                              Well, I wasn't aware of any bunq location/offices in which to work bunq customer support duties in Rotterdam or Capelle aan den IJssel (location of Vanad‘s headquarters).

                                @NiB#103686 Exactly, very well put. The employees of Vanad Group are not employees of Bunq. And they definitely did share data, because without this data they couldn't carry out their support function. Hell, I shared sensitive data with Vanad (thinking they were Bunq) employees when I sent them my Dutch BSN number when it wasn't being accepted automatically in the app.

                                  @DennisdeWitNL#103687 Well this post has been up for a whole day now and still no response from bunq. Eventually you have to assume they are hiding something or they don't have a good response...

                                    @AbuKarol#103694 Funny that some people freak out because there seems to be a missing information but you people don’t mind using services like WhatsApp and Facebook or google which do much much worse stuff with your data.