Data Privacy Notice
We take data protection and confidentiality very seriously and adhere to the provisions of the EU General Data Protection Regulation (EU-GDPR) as well as current national data privacy regulations. Please read this data privacy information carefully before submitting a report.
Purpose of the whistleblowing system and legal basis
The whistleblowing system (BKMS® System) serves the purpose of securely and confidentially receiving, processing and managing reports regarding violations of the compliance rules of N26 AG or any entities directly or indirectly controlled by N26 AG from time to time, currently being N26 Bank AG (including all branches), N26 Operations GmbH, N26 Growth GmbH and N26 Product & Tech GmbH ("N26"). The processing of personal data in the BKMS® System is pursued in accordance with the applicable whistleblowing legislation (namely Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019) and any national laws issued in the jurisdictions where N26 has employees as per Article 6 (1) (c) GDPR and where no such law has been yet approved and in force on the legitimate interests of N26 to detect and prevent misconduct and thus avoid damage to N26, its employees and customers as per Article 6 (1) (f) GDPR.
Controller
The controller for the processing of personal data of this whistleblowing system is the N26 entity with which you had the contractual relationship.
N26 AG provides services to all N26 entities regarding the processing of employee personal data. For employees that do not sign a contract with N26 AG, N26 AG acts as a processor of the N26 entity that signed the contract, i.e. processes personal data on behalf of other N26 entities.
Additionally, the reporting system is operated by a specialised company, EQS Group AG, Bayreuther Str. 35, 10789 Berlin in Germany, on behalf of N26.
Personal data and information entered into the reporting system are stored in a database operated by EQS Group in a high-security data centre. Only N26 has access to the data. EQS Group and other third parties do not have access to the data. This is ensured in the certified procedure through extensive technical and organisational measures.
All data are stored encrypted with multiple levels of password protection so that access is restricted to a very small selection of expressly authorised persons at N26.
N26 has appointed a data protection officer. Questions on data protection and privacy can be sent to dpo@n26.com.
Type of the collected personal data
Reports can be submitted anonymously without the need to collect any personal data. However, if you which to provide personal data by submitting a report via the whistleblowing system, the following personal data and information may be collected:
- your name, again, only if you choose to reveal your identity,
- whether you are employed at N26 and
- the names of persons and other personal data of persons that you name in your report.
Confidential handling of reports
Incoming reports are received by a small selection of expressly authorised and specially trained employees of the Compliance or, alternatively, People department of N26 and are always handled confidentially. Once a report is received the responsible teams will evaluate the matter and perform any further investigation required by the specific case.
During the processing of a report or the conduction of a special investigation, it might become necessary, always under the proper law application, to share reports (whenever possible anonymized) with additional employees and Works Councils of N26. Furthermore, it might become necessary to share reports (whenever possible anonymized), according to the proper legal mandate, with authorities (e.g. German Federal Financial Supervisory Authority (BaFin), German Federal Bank (BuBa), other National Competent Authorities, tax authorities, public prosecutors or involved legal and accounting firms.
All persons who receive access to the data are obligated to maintain confidentiality.
Information of the accused person
As a basic principle we are bound by law to inform the accused persons that we have received a report concerning them, unless this threatens further investigations into the report. In doing so, your identity as whistleblower is not revealed as far as is legally possible.
Rights of the data subjects
According to European data protection law, you and the persons named in the report have the rights as mentioned in the Privacy Policy for N26 Group Employees (https://we26--simpplr.vf.force.com/apex/simpplr__app?u=/site/a112o00000G0RUyAAN/page/a0z7T000000g06KQAQ) and in the Privacy Policy of N26 for the rest.
Retention period of personal data
Personal data is retained for as long as necessary to clarify the situation and perform an evaluation of the report or a legitimate interest of the company exists, or it is required by law, and for a maximum of 5 years. After the report processing is concluded, this data is deleted in accordance with the statutory requirements.
Use of the reporting portal
Communication between your computer and the reporting system takes place over an encrypted connection (SSL). Your IP address will not be stored during your use of the reporting system. In order to maintain the connection between your computer and the BKMS® System, a cookie is stored on your computer that merely contains the session ID (a so-called session cookie). This cookie is only valid until the end of your session and expires when you close your browser.
It is possible to set up a postbox within the reporting system that is secured with an individually chosen pseudonym/ user name and password. This allows you to send reports either by name or in an anonymous, safe way. This system only stores data inside the reporting system, which makes it particularly secure. It is not a form of regular e-mail communication.
Note on sending attachments
When submitting a report or an addition, you can simultaneously send attachments. If you wish to submit an anonymous report, please take note of the following security advice: Files can contain hidden personal data that could compromise your anonymity. Remove this data before sending.
Version: June 2023