Privacy Statement

Introduction

The FINN - Banking of Things (BoT) product suite consists of a secure Software Development Kit (‘SDK’) for Internet of Things devices, a FINN application (‘App’) and a community website (‘Community’) provided to you by ING Bank N.V.


With FINN you can enable your own IoT devices to start doing trigger based financial transactions. FINN facilitates you to download and use the App to make your IoT projects more safe and enable autonomous financial transactions.


If you visit our website or in any other way contact FINN, we process your personal data. By “processing” we mean everything we can do with this data such as collecting, recording, storing, adjusting, organising, using, disclosing, transferring or deleting that data.


This Privacy Statement aims to explain in a simple and transparent way what personal data we gather about you and how we process it. We process your personal data to enable us to perform our services as effectively as possible. Needless to say, we treat your personal data with the utmost care and in full compliance with privacy laws and regulations.


Below, we explain what personal data are and which personal data we use for which purposes.


As FINN is a part of ING Bank N.V., please also refer to the ING Privacy Statement located at ing.com for further information about how ING processes data and your privacy rights and obligations.


Personal data

The type of personal data we collect

Personal data refers to any information that tells us something about you and that we can link to you.


  • If you contact us, we process personal data such as your full name and email address
  • If you download and use our SDK, we process your Github account name, full name, email address and usage data of your IoT devices
  • If you download and use our App, we process your full name, e-mail address and usage data.
  • When adding payment to your projects, we also process the payment related data (like IBAN)

What we do with your personal data

We only use your personal data for legitimate business reasons. This includes:


  • validating interest in FINN goods and services;
  • contacting you about the FINN App; and
  • if necessary, to comply with our legal obligations.

Who we share your personal data with and why

We may disclose personal data to third parties like regulators if required to do so by law. When we use other service providers we only share personal data that is required for a particular assignment. Service providers support us with activities like:


  • performing certain services and operations
  • designing and maintenance of internet-based tools and applications; and
  • preparing reports and statistics, printing materials and designing products.

Cookies

We use cookies on our website for making the website function properly and analysing use of the website. With this information we can improve and further develop the website. We don’t use tracking cookies or similar technologies.


A cookie is a small text file that is stored by your browser on your computer. On each subsequent visit to the website, the browser searches for cookies. If the browser finds cookies, it sends the information stored by the cookie to the website. The website downloads cookies on your computer, tablet or mobile phone which are strictly necessary for the functioning of the website, such as cookies that ensure that you can retrieve information on the website quickly, and cookies that are strictly necessary to provide a service which has explicitly been requested by you, such as a cookie that remembers your cookie settings. To download cookies that are not strictly necessary, such as cookies for gathering statistical information, FINN needs your prior consent.


If you have adjusted your cookie settings so that websites are not permitted to place cookies on your computer, the FINN website may not be able to download the cookie which remembers whether or not you consented to the placing of cookies. If so, you will be asked to indicate your cookie preferences each time you visit the website. If you do not wish to be asked about your cookie preferences each time you visit the website, you need to adjust your browser’s cookie settings.


Marketing

We will not use your personal data for marketing or promotional purposes.


Data retention

We are only allowed to keep your personal data for as long as it’s still necessary for the purpose we initially required it. After this we look for feasible solutions, like anonymize, archiving and deleting it.


Your rights

We respect your rights to determine how your personal information is used. These rights include:


  1. Right to access personal data: You have the right to ask us for an overview of your personal data that we process by sending an email to FINN@ing.nl.
  2. Right to rectify personal data: if your personal data is not correct, you can ask us to rectify your personal data by sending an email to FINN@ing.nl.
  3. Right to complain: Should you not be satisfied with the way we have responded to your concerns you have the right to submit a complaint to us. If you are still unhappy with our reaction to your complaint, you can escalate it to the ING Bank Data Protection Officer. You can also contact the data protection authority in your country.

Please refer to the ING Privacy Statement for a full overview of your rights and how to exercise them.


Changes

This Privacy and Cookie Statement may be modified from time to time to comply with applicable laws or to reflect our updated business practices, so please check this Privacy Statement periodically for any changes. https://www.makethingsFINN.com. The most recent version was created on 7 December 2018.


Supervisory information

FINN is a trademark of ING Bank N.V. (‘ING’). ING has its statutory seat in Amsterdam at Bijlmerplein 888, 1102 MG, The Netherlands, Trade Register number 33031431. ING is regulated and licensed by the De Nederlandsche Bank (‘DNB’) and the European Central Bank (‘ECB’) for payment services. ING is also regulated and licensed by the Autoriteit Financiële Markten (‘AFM’) and regulated by the Autoriteit Consument & Markt (‘ACM’). Information regarding supervision of ING can be obtained from DNB (www.dnb.nl), AFM (www.afm.nl) or ACM (www.acm.nl).