Information about our processing of your personal data

In some cases, AP Pension collects and processes personal data about you when we offer a pension and insurance scheme to the company where you are employed. In this way, we can calculate the price of the scheme and prepare a correct offer.

Categories of personal data

AP Pension processes various personal data about you. This personal data will be:

General information

AP Pension typically process information about your name, employment, including who your employer is and information about salary. In addition, it concerns e.g. birthday, gender, type of employment and how much is paid into your pension savings.

Where do we get information about you from?

AP Pension receives your information from your employer or from the insurance intermediary used by your employer.

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

The collection, use and disclosure of general personal data about you is necessary for AP Pension to pursue a legitimate interest in being able to provide your company with an offer for a pension and insurance scheme with AP Pension (Article 6(1)(f) of the General Data Protection Regulation).

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

1. Data processors and business partners acting on behalf of AP Pension. These parties may only process information on the basis of instructions from AP Pension and may not use the information for their own purposes.
2. AP Pension reinsurance company.

Your employer and/or the insurance intermediary used by your employer.

Your insurance and/or pension scheme will be established in AP Pension, either as part of an agreement on compulsory or voluntary contributions with your employer or based on a privately established scheme.

In the case of a mandatory scheme based on an agreement with, for example, your employer, you will be registered in AP Pension on the basis of either the first payment to AP Pension or by your employer registering with AP Pension. If your scheme is set up in AP Pension because your employer changes pension provider, we will typically receive data on a list of covered employees from the previous pension provider.

In the case of a privately created scheme, the creation is based on the information necessary for us to accept the scheme. This information will often come from you yourself in connection with your insurance claim or through the financial institution that has brokered the pension scheme.

Categories of personal data

AP Pension processes various personal data about you. This personal data will be:

General and confidential information

AP Pension typically collects and processes the following information:

1. Name, information about CPR number and in some cases passport or other documentation for identification purposes.
2. Information about your general practitioner and any other practitioners and treatment facilities you have used.
3. Information about your employment relationship, such as employer, position, and salary information.
4. Financial information such as payments, income and assets, information on public benefits and grants, and account information for disbursement. If you are self-employed, we will also collect accounts for the company.

Sensitive information

When setting up private schemes in AP Pension, we will collect health information based on consent.

When establishing mandatory or voluntary company schemes, AP Pension will, as a rule, not collect health information. However, there may be a need to obtain health information in connection with a change of supplier in the form of, for example, clauses.

In connection with changes to existing schemes, e.g., in connection with requests for increases that result in an increased risk of AP Pension, it may be relevant to obtain information about health.

Where do we get information about you from?

We receive your personal data in connection with the creation and changes to your scheme from:

1.  
2. Your employer or the insurance intermediary that you or your employer use.
3. The CPR-register.
4. Any former pension and insurance companies.
5. Knowledge Centre for Health and Insurance.
6. Your general practitioner, hospitals, specialists, and other therapists, such as psychologists, physiotherapists, and chiropractors.
7. Insurance intermediaries, including financial institutions.
8. Publicly available sources.

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

1. The collection and use of general personal data about you is necessary in order for us to fulfil the insurance and/or pension agreement we have with you and, if applicable, your employer (Article 6(1)(b) of the General Data Protection Regulation).
2. Your ordinary personal data, sensitive personal data and your CPR number are collected, used and disclosed on the basis of explicit consent from you (Article 6(1)(a) of the General Data Protection Regulation and Article 9(2)(a) of the General Data Protection Regulation, cf. Article 6(a) and section 117(1) of the Financial Business Act, cf. Article 6(1) of the Regulation, cf. subsection 2, subsection 3 and section 11(2)(2) of the Danish Data Protection Act.
3. The collection, use, and disclosure of CPR numbers is a natural part of the company's operations. Processing and disclosure are also necessary for unique identification in relation to existing customer relationships when performing administrative tasks and advice. and to comply with requirements from public authorities, as well as for legal claims to be established, exercised, or defended (Data Protection Act § 11(2), no. 1, cf. the Financial Business Act § 43 b and the Data Protection Act § 7 (1) and the General Data Protection Regulation Art. 9 (2) (f)).
4. The processing of sensitive personal data is necessary for the establishment, exercise or defense of legal claims (Article 9(2)(f) of the General Data Protection Regulation, cf. Art. 6(1)(b) and (f), and the Danish Financial Business Act, Section 117(1), cf. Article 6(1) of the Regulation, cf. subsection (2), cf. subsection (3)).

• The collection, use, and disclosure of CPR numbers and general personal data, including financial information, is necessary, as AP Pension is legally obliged under the Money Laundering Act to legitimize and risk assess customers (including assessing whether you are politically exposed or close relatives to a politically exposed person) and to inform the Money Laundering Secretariat (the State Prosecutor for Serious Economic and International Crime) of suspicions with a view to preventing and combating money laundering and terrorist financing (the Data Protection Act § 11(2), no. 1 and the General Data Protection Regulation, Art. 6(1)(c). In addition, the Act on Measures to Prevent Money Laundering and Financing of Terrorism (the Money Laundering Act).

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

1. Data processors and business partners acting on behalf of AP Pension. These parties may only process information based on instructions from AP Pension and may not use the information for their own purposes.
2. AP Pension reinsurance Company.
3. Your employer and/or the insurance intermediary that you or your employer use.
4. Knowledge Centre for Health and Insurance in relation to health assessment.

Public authorities, including the Tax Administration, the Danish Financial Supervisory Authority, and the like.

When we administer your pension and insurance scheme, we process the data we hold about you.  This applies both in relation to receiving payments on an ongoing basis, tax reporting, ongoing handling of your policy, upon termination of your scheme and in the situation where you contact for advice.

AP Pension also processes your information if, based on the data we have, we assess that advice may be relevant to you from a needs point of view. For example, when you reach retirement age, change marital status, or if we receive information that your salary changes significantly.

Categories of personal data

AP Pension processes various personal data about you. This personal data may be, for example:

General and confidential information

1. Name, contact information, social security data and credentials.
2. Policy data, including policy number or customer number, information on employer, pensionable salary, payments, payouts, products and insurance covers, risk profile and investment choice, beneficiary selection.
3. Financial information on assets, other insurance, public benefits.
4. Information about spouse, cohabiting partner, children, special beneficiaries, or other persons relevant to your commitment to AP Pension.

Sensitive information

Health data, e.g., in connection with termination of the scheme (e.g., if you switch to a new pension provider).

Health obtained with consent at the time of registration or in connection with increases is stored and treated as needed.

Where do we get information about you from?

We receive your personal data in connection with the administration of your scheme as well as advice from:

1.  
2. Your employer or the insurance intermediary that you or your employer use.
3. The CPR-register.
4. Other pension and insurance companies.
5. Public authorities.
6.  

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

1. The collection, use and disclosure of general personal data about you is necessary for us to fulfil the agreement/pension and insurance scheme we have with you (Article 6(1)(b) of the General Data Protection Regulation and the Financial Business Act § 117(1), cf. Article 6(1) of the General Data Protection Regulation, cf. subsection (2), cf. subsection 3).
2. The collection, use and disclosure of CPR numbers is a natural part of the company's operations. Processing and disclosure are also necessary for unique identification in relation to existing customer relationships when performing administrative tasks and advice.  And compliance with requirements from public authorities, as well as for legal claims to be established, exercised, or defended (Data Protection Act § 11(2), no. 1, cf. the Financial Business Act § 43 b and the Data Protection Act § 7 (1) and the General Data Protection Regulation, Art. 9 (2) (f)).
3. The collection, use and disclosure of sensitive personal data is necessary for the establishment, exercise, or defense of legal claims (Article 9(2)(f) of the General Data Protection Regulation, cf. Art. 6(1)(b) and (f), and the Danish Financial Business Act § 117(1), cf. Article 6(1) of the General Data Protection Regulation, cf. subsection (2), cf. subsection 3).
4. The collection, use and disclosure of CPR numbers, the sensitive personal data and the general personal data is necessary, as AP Pension is legally obliged under the Money Laundering Act to legitimize, and risk assess customers and to inform the Money Laundering Secretariat (the State Prosecutor for Serious Economic and International Crime) of suspicions with a view to preventing and combating money laundering and terrorist financing. AP Pension collects personal data about you in connection with customer due diligence procedures and as a result of investigation, listing and monitoring of the pension scheme (the Data Protection Act § 11 (2), no. 1, cf. § 43 b as well as the General Data Protection Regulation art. 9 (2) (g) and the General Data Protection Regulation art. 6 (1) (c). In addition, the Act on Measures to Prevent Money Laundering and Financing of Terrorism (the Money Laundering Act).
5. Collection, use and disclosure of your CPR number as well as general personal data is necessary as AP Pension is legally obliged to report to the Tax Administration in accordance with tax legislation. In addition, AP Pension is obliged to withhold tax and duty when paying out pension savings and insurance benefits to you. In this connection, AP Pension discloses your personal data in accordance with the Pension Taxation Act. Similarly, AP Pension settles tax or levy in accordance with the Pension Return Taxation Act (PBL). CPR numbers are disclosed for the purpose of identifying the customer when reporting financial information and settling taxes or duties (the Data Protection Act § 11, subsection 2, no. 1, cf. the Financial Business Act § 43 b and the Tax Law Act (PBL) as well as the General Data Protection Regulation, Art. 6, subsection 1, letter c).
6. Disclosure of your ordinary personal data, including your CPR number, to banks and other financial institutions is necessary in order for us to fulfil the agreement/pension and insurance scheme we have with you (Financial Business Act § 117(1), cf. Article 6(1) of the General Data Protection Regulation, cf. subsection 2, cf. subsection 3, and Article 6(1)(b) of the General Data Protection Regulation and the Data Protection Act § 11, paragraph 2(3).

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

1. Data processors and business partners acting on behalf of AP Pension. These parties may only process information on the basis of instructions from AP Pension and may not use the information for their own purposes.
2. Your employer and/or the insurance intermediary that you or your employer use.
3.  
4. Public authorities, such as the tax administration.
5. Financial institutions and other pension and insurance companies.

When you report a claim to AP Pension or apply for payment of insurance benefits, e.g., certain critical illnesses, loss of earning capacity, health insurance benefits, etc., we register the information you submit to us. In connection with claims handling and follow-up in claims cases, we will ask for your consent to collect information so that we can investigate whether you are entitled to payment. The same applies when you participate in a guidance course in AP Care.

AP Pension processes your data when we need to assess whether we can offer you treatment or pay insurance in connection with an injury, follow-up or as a preventive measure. We also process your information when you participate in a guidance course in AP Care. We also process them for the purpose of calculating risk and insurance accounting.

Categories of personal data

AP Pension collects and processes various personal data about you. This personal data will be:

General and confidential information

AP Pension typically collects and processes the following information:

1. Name, contact information, information about social security number.
2. Information about your general practitioner and any other practitioners and treatment facilities you have used.
3. Information about your employment relationship, such as employer, position, and salary information.
4. Financial information on payments, income and assets, information on public benefits and grants, and account information for disbursement. If you are self-employed, we will also collect accounts for the company.

Personal data relating to criminal offences.

In individual cases, it may be necessary to obtain information from the police or information that otherwise documents an incident that may involve criminal offences or document the circumstances surrounding e.g., an accident.

Sensitive information

AP Pension processes health information in connection with, among other things, claims handling, follow-up in claims, payment of insurance benefits and in connection with registration and termination of the scheme.

In AP Care, health information is processed in connection with a guidance process.

If you contact your trade union as a representative, AP Pension will, on your initiative, process information about trade unions.

Where do we get information about you from?

AP Pension receives most of the information from you on the form you fill out when you apply for a benefit or for treatment and in connection with ongoing follow-up on payments. AP Pension may also receive information from you in connection with telephone contact regarding health, injury, follow-up, and payment.

In connection with our processing, we collect information from the following third parties in order to assess the case:

•  
• Other pension and insurance companies (where you are or have been a customer).
• Hospitals, general practitioners, other doctors, and treatment facilities, such as specialists, chiropractors, physiotherapists, psychologists, etc.
• Public authorities.
• Public and private registers.
• Publicly available information.
• Social media.
• Collaborators, including joint data controllers.

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

• The collection, use and disclosure of general personal data about you is necessary to fulfil the pension and/or insurance agreement we have with you (Article 6(1)(b) of the General Data Protection Regulation and the Financial Business Act § 117(1), cf. Article 6(1) of the General Data Protection Regulation, cf. subsection 2, cf. subsection 3).
• The collection and use of general personal data about you is necessary in order for us to pursue a legitimate interest in connection with the prevention of abuse of insurance (Article 6(1)(f) of the General Data Protection Regulation).
• The collection and use of health data, and in rare cases and on your initiative, information about trade unions is necessary for the establishment, exercise, or defense of legal claims (Article 9(2)(f) of the General Data Protection Regulation, cf. Article 6(1)(b) and (f) and the Financial Business Act § 117(1), cf. Article 6 of the General Data Protection Regulation, paragraph 1, cf. paragraph 2, cf. paragraph 3).
• The collection, use and disclosure of CPR numbers is a natural part of the company's operations. Processing and disclosure are also necessary for unique identification in relation to existing customer relationships when performing administrative tasks and advice and for meeting requirements from public authorities, as well as for legal claims to be established, exercised or defended (the Data Protection Act § 11(2), no. 1, cf. the Financial Business Act § 43b and the Data Protection Act § 7(1) and Article 9 of the General Data Protection Regulation, paragraph 2(f). It is also necessary for us to comply with legal obligations in e.g., the Danish Money Laundering Act and tax legislation (Article 6(1)(c) of the General Data Protection Regulation).
• The collection, use and disclosure of your CPR number and general personal data is necessary, as AP Pension is legally obliged to report to the Tax Administration in accordance with tax legislation. In addition, AP Pension is obliged to withhold tax and duty when paying out pension savings and insurance benefits to you. In this connection, AP Pension discloses your personal data in accordance with the Pension Taxation Act. Similarly, AP Pension settles tax or levy in accordance with the Pension Return Taxation Act (PBL). CPR numbers are disclosed for the purpose of identifying the customer when reporting financial information and settling taxes or duties (the Data Protection Act § 11, subsection 2, no. 1, cf. the Financial Business Act § 43 b and the Tax Law Act (PBL) as well as the General Data Protection Regulation, Art. 6, subsection 1, letter c).
  
  
• We process the collection, use and disclosure of personal data relating to criminal convictions or offences when it is relevant for the performance of the pension and/or insurance agreement we have with you and if the processing is necessary to pursue a legitimate interest (Article 6(1)(b) and (f) of the General Data Protection Regulation).
• In other cases, disclosure of ordinary personal data and sensitive personal data takes place with your explicit consent (Article 6(1)(a) of the General Data Protection Regulation and Article 9(2)(a) of the General Data Protection Regulation, cf. Art. 6(1)(a) and the Danish Financial Business Act § 117(1), cf. Article 6(1) of the General Data Protection Regulation, cf. subsection (2), cf. subsection (3)) or on the basis of special legislation, including tax legislation, Financial Business Act, etc.

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

• For example, we inform the employer if the payment from an insurance policy is made to the employer while you are receiving a salary. We do not disclose information about the nature and extent of the damage to the employer.
• Insurance intermediaries, including brokers and tied agents. If your scheme is operated by an insurance intermediary and this is relevant, AP Pension informs the insurance intermediary that you have been awarded payment in the event of loss of earning capacity. We do not disclose information about the nature, extent, and amount of the damage to the insurance intermediary.
• Other pension and insurance companies (where you are or have been a customer),
  including health insurance providers.
  
  
• Hospitals, general practitioners, other doctors, and treatment facilities, such as specialists, chiropractors, physiotherapists, psychologists, etc. in our treatment network.
  
  
• In certain cases, information may be disclosed to AP Pension's reinsurance company, e.g., in connection with audits.
• Our business partners who help us with, for example, technical support, supplier services and mediation of healthcare.

• Knowledge Centre for Health and Insurance. In special cases, we disclose information in order to obtain an opinion for the purpose of a decision.
• Sygeforsikring "danmark". If you are a member of Sygeforsikring "danmark", we disclose personal data to this in connection with possible reimbursement.
• Public authorities, e.g., the Danish Tax Administration, Labour Market Insurance (AES), the Danish Health Data Authority or Patienterstatningen.
• That is, someone who represents you, such as a lawyer, a close relative, or your trade union. In certain cases, it will be a prerequisite that you have given the representative power of attorney to represent you.
• Data processors and business partners acting on behalf of AP Pension. These parties may only process information based on instructions from AP Pension, and they may not use the information for their own purposes.

AP Pension processes general information about persons related to an insurance relationship, e.g., beneficiaries of a payment under an insurance or pension scheme with AP Pension.

In certain insurance schemes, such as spousal pensions, it may be necessary in special situations to obtain and process the health data of an eligible person. In this case, health data will be obtained from the person entitled and processing will be based on consent. Similarly, cross-life insurance policies will process information about both policyholder and insured.

AP Pension will also process general information about third parties who are not customers and who have more general questions.

When advising a customer in AP Pension, it may be relevant to include matters such as household finances, spouse, children, and the like.

Similarly, in order to calculate the benefit in payout situations, information about a spouse's finances may be needed.

Categories of personal data

AP Pension processes various personal data about persons related to a customer relationship, including beneficiaries and, in some cases, spouse or children. This personal data will be:

General and confidential information

This will typically be name, relation to the insured, CPR number or birthday, possibly contact data and account number and, in some cases, financial information.

Sensitive information

Health information.

Where do we get information about you from?

AP Pension generally receives information about beneficiaries of an insurance scheme from the policyholder if a special advantage has been inserted. In other cases, AP Pension will, in connection with death, obtain information about the beneficiary/beneficiary from:

• The beneficiary himself/herself/themselves.
• Public authorities, e.g. The Bankruptcy Court or the Tax Administration.
• The estate of the deceased.
• Nets Danmark A/S (information about Nem-account for payout).

If the scheme is pledged, we obtain information from the mortgagee, e.g., a financial institution.

In the special cases where AP Pension obtains health information from a beneficiary or insured person on a scheme (e.g., the eligible spouse on a spousal pension), we will typically obtain this information from the beneficiary himself and possibly from doctors, hospitals, or other therapists.

In cases where, for example, a spouse's information is necessary for us to advise the customer or calculate the customer's payout, we will typically receive the information either from the customer or directly from the data subject himself.

In case of general enquiries from third parties who are not customers, AP Pension will normally process the information that the person concerned provides in connection with the inquiry.

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

• The collection, use and disclosure of general personal data about a beneficiary/beneficiary of a pension or insurance scheme is necessary to fulfil a legal obligation incumbent on AP Pension in accordance with the insurance contract with the policyholder (Article 6(1)(c) of the General Data Protection Regulation and Section 11(2)(1) of the Danish Data Protection Act, cf. the Financial Business Act § 43b et al.). Similarly, processing will take place on the basis of a legitimate interest. For example, the consideration that a beneficiary may be noted exceeds the fact that the data subject has no interest in being listed as a beneficiary/beneficiary of a pension or insurance scheme. Similarly, a balance of interests is carried out when it is necessary to process information about a spouse in order to advise or calculate payment to the policyholder. (Article 6(f) of the General Data Protection Regulation).
• The collection, use and disclosure of CPR numbers is a natural part of the company's operations. Processing and disclosure are also necessary for unique identification in relation to existing customer relationships when performing administrative tasks and advice and for meeting requirements from public authorities, as well as for legal claims to be established, exercised or defended (Data Protection Act § 11, subsection 2, no. 1, cf. the Danish Financial Protection Act, cf. the Danish Financial Protection Act). Company § 43 b and the Data Protection Act § 7 (1) and Article 9 (2) (f) of the General Data Protection Regulation. It is also necessary in order for AP Pension to comply with legal obligations in e.g. the Danish Money Laundering Act and tax legislation (Article 6(1)(c) of the General Data Protection Regulation).
• The collection and disclosure of health data takes place with the consent of the data subject (Article 6(1)(a) of the General Data Protection Regulation and Article 9(2)(a) of the General Data Protection Regulation, cf. Art. 6(1)(a) and the Financial Business Act Section 117(1), cf. Article 6(1) of the General Data Protection Regulation, cf. subsection (2), cf. subsection (3)).
• The collection and use of health data is necessary under certain circumstances in order for legal claims to be established, exercised or defended (Article 9(2)(f) of the General Data Protection Regulation, cf. Article 6(1)(b) and (f) and the Danish Financial Business Act § 117(1), cf. Article 6(1) of the General Data Protection Regulation, cf. subsection (2), cf. subsection (3)).
• The collection, use and disclosure of general personal data in connection with a general inquiry from a third party takes place on the basis of AP Pension's legitimate interest in being able to process an inquiry sent to AP Pension (Article 6(1)(f) of the General Data Protection Regulation).

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

• Data processors and business partners acting on behalf of AP Pension. These parties may only process information on the basis of instructions from AP Pension and may not use the information for their own purposes.
• In some cases, AP Pension reinsurance company.
• Public authorities (for example, the tax administration in connection with disbursement).
• That is, someone who represents you, such as a lawyer or a close relative. In certain cases, it will be a prerequisite that you have given the representative power of attorney to represent you.

The focal point of AP Pension is customer ownership because AP Pension has only one owner, and that is the customers.

At AP Pension, there is therefore no dilemma about whether a decision should benefit the customers or the owners – because they are the same people. You can read more about customer ownership and AP Pension's strengths here (in Danish).

Customer ownership gives AP Pension a special responsibility, namely the responsibility to ensure that all AP Pension's customers are treated fairly and that each customer receives what he or she is entitled to, but no more than that, as it will then be the other customers in the customer community who pay. This is a balance that AP Pension continuously works with in connection with case management, and which in some cases gives rise to complaints.

AP Pension use your information to process any complaint from you about a decision made by AP Pension. This also applies if you choose to have your complaint reviewed by, for example, the Danish Court of Justice. The Insurance Appeals Board or the courts if you are not satisfied with AP Pension's decision in the complaint handling.

Categories of personal data

AP Pension processes various personal data about you. This personal data will be:

General and confidential information

AP Pension treats, among other things, depending on the specific case:

• Name, contact information, CPR number, customer number and the like.
• Policy information (i.e., policy information, deposit, risk profile, insurance, beneficiary, custody, etc.).
• Information about employment, including employer, pensionable salary, and professional situation.
• Financial information, including assets.
• Social conditions, family relationships, leisure activities and the like.

Personal data on criminal offences

In individual cases, it may be necessary to process information from the police or information that otherwise documents an incident that may involve criminal offences or document the circumstances surrounding e.g., an accident.

Sensitive information

AP Pension health information in complaint cases, if necessary due to the content and nature of the complaint.

If you contact your trade union as a representative, AP Pension will, on your initiative, process information about trade unions.

Where do we get information about you from?

When AP Pension does not receive the personal data from you, we may obtain it from:

• Employer, insurance broker or insurance intermediary.
• Representatives, such as a lawyer or trade union, or someone you have mandated to represent you.
• Other pension and insurance companies (where you are or have been a customer).
• Hospitals, general practitioners, other doctors, and treatment facilities, such as specialists, chiropractors, physiotherapists, psychologists, etc.
• Insurance intermediaries, including financial institutions.
• Public authorities (e.g., municipality, AES, the Danish Data Protection Agency and the Danish Financial Supervisory Authority)
• Publicly available information.
• Collaborators, including joint data controllers.

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

• The general personal data is collected, used and disclosed on the basis of a balance of interests in relation to the fact that legal claims must be established, exercised and defended by AP Pension if a customer complains about a decision made by AP Pension (Article 6(1)(f) of the General Data Protection Regulation and section 117(1) of the Danish Financial Business Act, cf. Article 6 of the General Data Protection Regulation, paragraph 1, cf. paragraph 2, cf. paragraph 3).
• The collection and use of general and sensitive personal data is necessary to comply with a legal obligation (GDPR Art. 6(1)(c) and Art. 9(2)(g) cf. Art. 6(1)(c)). AP Pension has a legal obligation under the Executive Order on the handling of complaints by the complaints officer and financial institutions.
• The sensitive personal data is collected, used, and disclosed if it is necessary for legal claims to be established, exercised or defended by AP Pension (General Data Protection Regulation Art. 9(2)(f), cf. Art. 6(1)(b) and the Financial Business Act § 117(1), cf. Art. 6(1) of the General Data Protection Regulation, cf. subsection 2, cf. subsection 3).
• The collection, use and disclosure of CPR numbers is a natural part of the company's operations. Processing and disclosure are also necessary for unique identification in relation to existing customer relationships when performing administrative tasks and advice and for meeting requirements from public authorities, as well as for legal claims to be established, exercised or defended (the Data Protection Act § 11(2), no. 1, cf. the Financial Business Act § 43b and the Data Protection Act § 7(1) and Article 9 of the General Data Protection Regulation, paragraph 2(f).
• The collection, use and disclosure of information about criminal offences is necessary for legal claims to be established, exercised, or defended (the Data Protection Act § 8 (5) and the Data Protection Act § 7 (1) and the General Data Protection Regulation § 9 (2) (f)).

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

• That is, someone who represents you, such as a lawyer, a close relative, or your trade union. In certain cases, it will be a prerequisite that you have given the representative power of attorney to represent you.
• Data processors and business partners acting on behalf of AP Pension. These parties may only process information based on instructions from AP Pension and may not use the information for their own purposes.
• Courts and appeals boards.
• Insurance intermediaries, including financial institutions.
• Public authorities in connection with public authority cases, e.g. The Danish Data Protection Agency or the Danish Financial Supervisory Authority as well as the Tax Administration in connection with payment.

AP Pension processes your personal data when we market our products and solutions. You can read more about this in our consent to marketing.

AP Pension has various marketing initiatives to ensure that you can get exactly the knowledge from AP Pension that is relevant to you when it comes to your pension. We provide you with news and knowledge about your benefits, and they are targeted at you, your situation, and your needs in the different phases of your life.

AP Pension automatically uses, analyzes and compiles the information we collect in order to provide you with targeted and relevant information. In this way, we make sure that you get the information that AP Pension assesses is of the greatest value to you.

You can also consent to AP Pension sending marketing to you via the channels stated in the consent.

In connection with campaigns or other marketing initiatives, we may, in agreement with you, ask for your consent to process your personal data, e.g., statements, images, videos for marketing or business purposes.

Categories of personal data

We process various personal data about you. This personal data will be:

General and confidential personal data

The following data may be processed in connection with marketing:

• Name, contact information, date of birth.
• Financial information, including assets, salary information.
• Information about your involvement in AP Pension (e.g., your deposit, risk profile, insurance and any other products).
• Marital status, family relationships (spouse/partner/children) and demographics.
• Your behaviour on AP Pension's digital channels (e.g., which emails you open, which articles you read and what you are interested in at My Pension).
• Your communication with AP Pension (e.g., if you have questions about your pension plan, wish to book a consultation or want further knowledge about one of our products).
• Publicly available or purchased data from, among others, BBR, the CVR register and Statistics Denmark (e.g., value of housing, ownership in companies and demographics).
• Information you have provided to us in connection with questionnaires, evaluations and the like (e.g., what you think of our customer service or products).
• Information about your workplace and position, if any.

Sensitive information

Health information and any other sensitive information that you may disclose or comment on in connection with, for example, an interview.

Where do we get information about you from?

We receive most of the information we process from you. AP Pension usually does not collect any personal data other than those already collected as part of the customer relationship with you. If we receive new personal data about you, it will be:

• Information about which articles, etc. you open in AP Update, as well as which emails you open.
• Information from publicly available registers (e.g., Statistics Denmark, BBR and CVR register).

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

AP Pension processes data for marketing purposes on the basis of your consent pursuant to Article 6(1)(a) of the General Data Protection Regulation and section 121 of the Danish Financial Business Act, cf. Article 6(1) of the General Data Protection Regulation, cf. subsection (2), cf. subsection 3, including when disclosing personal data for marketing purposes.

Processing of sensitive data, such as health data, is processed after your consent, cf. Article 9(2)(a) of the General Data Protection Regulation.

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

• Data processors and business partners acting on behalf of AP Pension. These parties may only process information on the basis of instructions from AP Pension and may not use the information for their own purposes.
• The public on AP Pension's website (only on the basis of specific consent)

AP Pension processes your personal data when we prepare statistics and analyses. For example:

• Internal surveys, analysis and profitability assessments.
• Solvency statements and statutory solvency reports.
• The calculation of technical provisions, including the setting of relevant parameters.
• Statistical studies of major social importance on the causes of disease, disease patterns and correlation to mortality.

Categories of personal data

AP Pension processes various personal data about you. This personal data will be:

General and confidential personal data

AP Pension treats, among other things:

• Name, contact information, social security number, gender, customer, or policy number.
• Policy information and information about your commitment to AP Pension (e.g., your deposit, risk profile, custody size, hazard class, insurance and any other products and benefits).
• Information about your employment relationship (e.g., employer and pensionable salary).
• Financial information, including pension contributions, tax information, assets, information on income from social schemes, such as sickness benefits, early retirement, flexi-job benefits, etc.
• Family relations (spouse/partner/children).
• Information about deaths and information about disappearances.

Sensitive personal data

Health information

Where do we get information about you from?

The information that AP Pension does not receive directly from you is obtained from the following sources in connection with your customer relationship:

• Other pension and insurance companies (where you are or have been a customer).
• Hospitals, general practitioners, other doctors, and treatment facilities, such as specialists, chiropractors, physiotherapists, psychologists, etc., if you have had an injury.
• Public authorities.
• Public and private registers.
• Social media.
• Publicly available information.
• Collaborators, including joint data controllers.
• Representatives such as lawyers.
• Insurance intermediaries or financial institutions.

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

• The processing of general personal data is necessary to comply with a legal obligation incumbent on AP Pension under the Solvency II Regulation, the POG(IDD) Regulation on product supervision and governance requirements for insurance companies and insurance distributors and the Financial Business Act (Article 6(1)(c) and fsva of the General Data Protection Regulation. CPR number, Data Protection Act § 11, subsection 2, no. 1 and no. 3). The legal obligation is contained in the Act on Danmarks Nationalbank ('statistical information within its area of competence') and in the Financial Business Act ('the information necessary for the activities of the Danish Financial Supervisory Authority').
• AP Pension prepares statistics, analyses and statutory reports in a number of areas, including solvency statements, provisions, risk reporting, stock reports, drainage analyses, simulation of expected and current claims history/hedging in relation to the individual insurance products, including product profitability, tariff classification and claims development as well as in relation to the insurance portfolio as a whole. AP Pension processes sensitive personal data if the processing is necessary for reasons of substantial public interest pursuant to the Solvency II Regulation, the Financial Business Act and the Executive Order on Management (Article 9(2)(g) of the General Data Protection Regulation, cf. Article 6(1)(c)). It follows, among other things, from the above that AP Pension is obliged to carry out the calculations and analyses.
• AP Pension prepares analyses of combined information on injuries, disease, disease patterns and correlation to mortality. The analyses are carried out with the aim of reducing the risk of illness and death and to obtain general knowledge about the effect of preventive measures for the benefit of society. These analyses are carried out on the basis of the POG(IDD) Regulation on product oversight and governance requirements for insurance companies and insurance distributors (GDPR Art. 9(2)(g) cf. Art. 6(1)(c)).

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

• Data processors and business partners acting on behalf of AP Pension. These parties may only process information on the basis of instructions from AP Pension and may not use the information for their own purposes.
• In some cases, AP Pension reinsurance company.
• Statistics Denmark.
• Public authorities, e.g. the Danish Financial Supervisory Authority.

AP Pension processes your personal data in connection with statutory reports and when we need to ensure that we comply with applicable legislation, e.g., on money laundering, personal data, and financial activities.

AP Pension collects, uses, and discloses your information in connection with compliance with legislation, and processing inquiries related to legislation, including anti-money laundering legislation, the General Data Protection Regulation, and the Financial Business Act, etc. For example:

1. Statutory reports to the authorities.
2. Compliance with the principles for processing personal data and the legal basis for the processing.
3. Protection of personal data when implementing and maintaining technical and organisational security measures, e.g., to prevent unauthorised access to AP Pension's IT systems.
4. Investigation of suspicion or knowledge of security breaches and then reporting to customers or others affected and to the Danish Data Protection Agency.
5. Handling inquiries and complaints from customers and others.
6. Handling inspections and inquiries from the Danish Data Protection Agency and the Danish Financial Supervisory Authority.
7. Handling disputes, e.g., appeals board cases and court cases.
8. Obtaining documentation for compliance with anti-money laundering legislation.

Categories of personal data

AP Pension processes various personal data about you. This personal data will be:

General and confidential information

AP Pension treats, among other things, depending on the specific case:

• Name, contact information, CPR number, customer number and the like.
• Policy information (i.e., policy information, deposit, risk profile, insurance, beneficiary, etc.).
• Information about employment, including employer, pensionable salary, and professional situation.
• Financial information, including assets and annual statement.
• Social conditions, family relationships, leisure activities and the like.

Personal data on criminal offences

In individual cases, it may be necessary to process information from the police or information that otherwise documents an incident that may involve criminal offences.

Sensitive information

Health information

Where do we get information about you from?

When AP Pension does not receive the personal data from you, we may obtain it from:

• Employer, insurance broker or insurance intermediary.
• Representatives, such as a lawyer or trade union, or someone you have mandated to represent you.
• Insurance intermediaries, including financial institutions.
• Other pension and insurance companies (where you are or have been a customer).
• Hospitals, general practitioners, other doctors, and treatment facilities, such as specialists, chiropractors, physiotherapists, psychologists, etc.
• Public authorities (e.g., municipality, AES, the Danish Data Protection Agency, and the Danish Financial Supervisory Authority)
• Publicly available information.
• Collaborators, including joint data controllers.

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

• Processing takes place in accordance with the regulation in force at any given time and Article 6(1)(c) and (e) of the General Data Protection Regulation as well as Article 9(2)(g) of the General Data Protection Regulation, the Financial Business Act, the Act on Measures to Prevent Money Laundering and Financing of Terrorism (the Money Laundering Act), etc.
• The general personal data is collected, used and disclosed on the basis of a balance of interests in relation to the fact that legal claims must be established, exercised and defended by AP Pension if a customer complains about a decision made by AP Pension (Article 6(1)(f) of the General Data Protection Regulation and section 117(1) of the Danish Financial Business Act, cf. Article 6 of the General Data Protection Regulation, paragraph 1, cf. paragraph 2, cf. paragraph 3).
• The collection and use of general and sensitive personal data is necessary to comply with a legal obligation (Article 6(1)(c) and Article 9(2)(g) of the General Data Protection Regulation, cf. GDPR). art. 6, stk.1, litra c). AP Pension has a legal obligation under the Executive Order on the handling of complaints by the complaints officer and financial institutions.
• The sensitive personal data is collected, used, and disclosed if it is necessary for legal claims to be established, exercised, or defended by AP Pension (General Data Protection Regulation Art. 9(2)(f), cf. Art. 6(1)(b) and the Financial Business Act § 117(1), cf. Art. 6(1) of the General Data Protection Regulation, cf. subsection 2, cf. subsection 3).
• The collection, use and disclosure of CPR numbers is a natural part of the company's operations. Processing and disclosure are also necessary for unambiguous identification and for compliance with requirements from public authorities, including rules on money laundering, legislation on complaints officers, and for legal claims to be established, exercised or defended (Data Protection Act § 11 (2), cf. the Financial Business Act § 43 b and the Data Protection Act § 7 (1) and Article 9 (2) of the General Data Protection Regulation, point (f).
• The collection, use and disclosure of information about criminal offences is necessary for legal claims to be established, exercised, or defended, including processing in accordance with the legislation on complaints responsible (the Data Protection Act § 8 (5) and the Data Protection Act § 7 (1) and the General Data Protection Regulation § 9 (2) (f)).

 
Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

• Public authorities in connection with authority cases or requirements arising from legislation, e.g. The Danish Data Protection Agency, SØIK or the Danish Financial Supervisory Authority.
• That is, someone who represents you, such as lawyers. In certain cases, it will be a prerequisite that you have given the representative power of attorney to represent you.
• Data processors and business partners acting on behalf of AP Pension. These parties may only process information on the basis of instructions from AP Pension and may not use the information for their own purposes.
• Courts and appeals boards.
• Forsikringsformidlere, herunder pengeinstitutter.

At AP Pension we use video surveillance in our reception, along the facades and at the entrances to our domicile address Østbanegade 135, 2100 Copenhagen Ø. The purpose of the video recordings is to create security for AP Pension's staff and to prevent and solve crime.

At AP Pension's addresses in Aarhus and Amerika Plads, there is no independent video surveillance, but the buildings may be video monitored by the buildings' owners, who will then be data controllers.

Categories of personal data

AP Pension processes various personal data about you. This personal data will be:

General personal data

AP Pension processes video recordings from the reception area in AP Pension as well as the private parking area belonging to the domicile. Video footage down the facades of the building and the doors to the parking area.

Personal data relating to criminal offences.

Video recordings may contain recordings of criminal offences committed at AP Pension's reception, along the facades of the domicile and in the private parking area belonging to the domicile. In addition, the recordings can document accidents that are suitable for police investigation.

Where do we get information about you from?

AP Pension collects your personal data in the form of video recording when you are at AP Pension's reception, at the entrances, in the parking area and along the facades of the domicile.

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

• We process and disclose the personal data collected by AP Pension via video surveillance considering legitimate interests in creating security, preventing and solving crime (Article 6(1)(f) of the General Data Protection Regulation).

Storage

AP Pension stores the video recordings for 30 days. After that, the recordings will be deleted automatically.

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

1. Partners who help AP Pension with e.g., technical support and supplier services.
2. The police, if necessary, based on the purpose, based on the content of the recordings or at the request of the police.

We process your personal data when you use our websites and app. This may, for example, be information about your behavior that we collect using cookies to optimize the user experience on our websites and our app.

Categories of personal data

AP Pension processes various personal data about you. This personal data will be:

General and confidential personal data

When you use one of AP Pension's websites or portals, including Appension.dk, you will meet a cookie consent where you must consider which cookies you can accept.

It is not possible to avoid cookies that are necessary for the website to function.

With cookies, AP Pension collects and processes information about

• IP address
• which pages you have opened,
• what choice you have made in the cookie consent
• the user's platform (PC, tablet or mobile)
• Preferences
• Selections in various settings and forms (e.g., language)

In cookie settings on the website, you can see exactly what the purpose of each cookie is and what it stores. As far as appension.dk is concerned, you can see the cookie declaration here. (in Danish)

Where do we get information about you from?

When you use our websites and apps, AP Pension collects personal data about your behavior from, among other things, these sources:

1. AP Pension uses Google Analytics on AP Pension's websites and apps to investigate how the pages are visited and how users navigate the pages. Read more about Google Analytics by clicking here.
2. AP Pension uses cookies for the purpose of, among other things, making the website work, for statistics and for marketing. You can read more about what cookies are, what cookies we use, what we use them for, how to access cookie settings or, for example, block and delete cookies here.

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

1. We collect your personal data using cookies when you visit our websites and app based on your cookie consent (Article 6(1)(a) of the General Data Protection Regulation). We process and disclose the personal data that we have collected via cookies considering the legitimate interests in making the website or app work (Article 6(1)(f) of the General Data Protection Regulation) and for statistics as well as for marketing purposes in accordance with your consent.
2. The collection and use of general personal data about you is necessary for the website to function. When you then use the website, you accept necessary cookies in the form of an implicit consent (Article 6(1)(a) of the General Data Protection Regulation).
3. Cookies that are not necessary and used for e.g., statistics or marketing require explicit consent. Processing takes place solely based on consent (Article 6(1)(a) of the General Data Protection Regulation)

You can read more about the use of cookies  in AP Pension's cookie policy (in Danish) and revoke or change your consent in the cookie overview. You can also completely block cookies in your browser.

On http://minecookies.org/cookiehandtering (in Danish) you can read more about cookies and find instructions on how to delete your cookies on different browsers.

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

1. Partners who help AP Pension with e.g., technical support and supplier services. The partners act solely on behalf of AP Pension. This means that they may not use the information for their own purposes.

Some of the marketing cookies that are activated on your device when you visit our website and consents to marketing cookies are owned by third parties. These third parties help us convey relevant marketing messages when you visit their websites. These third parties may use the information their cookies collect about you for purposes other than those decided by us, and if you accept such marketing cookies or services, you agree that the third party's cookie guidelines and privacy policies apply. Our joint data responsibility means, among other things, that we remain responsible for the third party's use of your information, which is processed on our behalf. You can read more about third-party cookies here.

AP Pension processes your personal data when you use our digital platforms. This can be, for example, if you use an online form or if you contact us via our contact form on the website, which you can find here. (in Danish)
You can use the contact form to communicate securely with AP Pension.

In relation to the handling of complaints, we refer you to 'Complaint handling' under section 2.6.

Categories of personal data

AP Pension processes various personal data about you. This personal data will be:

General and confidential personal data

When you contact us via one of our contact forms, AP Pension registers the information you provide yourself in order to identify you and process your inquiry. For example, name, contact information, date of birth and your CPR number. It may also be information of a more confidential nature that you provide in the form on your own initiative.

The contact form is used for secure communication as an alternative to e.g., emails.

If you fill out an online form, we will process the information you provide herein, as well as any documentation of digital signature. For example, there may be an advantage.

Sensitive personal data

In the contact form, it is possible to contact about the specific topic that you want. It is also possible to upload documents and documentation. Therefore, e.g., health data are processed in the contact form on the data subject's own initiative.

The use of online forms may involve the processing of health data. For example, by using critical illness notification forms or other insurance benefits. It may also be a question of providing health information to AP Pension via external channels – for example, mediated by a financial institution.

Where do we get information about you from?

When you use our websites and apps, AP Pension collects personal data about your behavior from, among other things, these sources:

1. AP Pension uses Google Analytics on AP Pension's websites and apps to investigate how the pages are visited and how users navigate the pages. Read more about Google Analytics by clicking here.
2. AP Pension uses cookies for the purpose of, among other things, making the website work, for statistics and for marketing. You can read more about what cookies are, what cookies we use, what we use them for, how to access cookie settings or, for example, block and delete cookies here.

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

1. The collection and use of general personal data about you is necessary for us to fulfil the agreement/pension and insurance scheme we have with you (Article 6(1)(b) of the General Data Protection Regulation).
2. The general personal data is collected, used and disclosed on the basis of a balance of interests in relation to the fact that legal claims must be established, exercised and defended by AP Pension if you complain about a decision made by AP Pension or in order to be able to answer other inquiries from you (General Data Protection Regulation Art. 6(1)(f) and the Financial Business Act § 117, paragraph 1, in conjunction with Article 6(1) of the Regulation, in conjunction with paragraph 2, in conjunction with paragraph 3).
3. The collection, use and disclosure of CPR numbers is a natural part of the company's operations. Processing and disclosure are also necessary for unique identification in relation to existing customer relationships when performing administrative tasks and advice and for meeting requirements from public authorities, as well as for legal claims to be established, exercised or defended (the Data Protection Act § 11(2), no. 1, cf. the Financial Business Act § 43 b and the Data Protection Act § 7 (1) and the General Data Protection Regulation Art. 9, paragraph 2(f).

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

Partners who help AP Pension with e.g., technical support and supplier services. The partners act solely on behalf of AP Pension. This means that they may not use the information for their own purposes.

AP Pension is customer-owned in that we only have one owner, and that is our customers.

AP Pension livsforsikringaktieselskab is 100 percent owned by Foreningen AP Pension f.m.b.a. AP Pension livsforsikringaktieselskab has a number of subsidiaries, including nærpension forsikringsformidling A/S, AP Ejendomme P/S and AP Pensionsservice A/S. Group diagram can be seen on AP Pension's website – here. (In Danish)

The members of the association AP Pension f.m.b.a. are the customers of AP Pension life insurance limited company in accordance with the association's articles of association.

It is the customers of AP Pension who, through elected delegates, elect the board of directors of Foreningen AP Pension f.m.b.a.

The board of directors of Foreningen AP Pension f.m.b.a. consists for the most part of delegates. The members of the Board of Directors of AP Pension Life Insurance Limited Company are elected from among the members of the Board of Directors of Foreningen AP Pension f.m.b.a., with the possibility of electing two specially qualified members. AP Pension has four employee representatives represented on both boards.   It is the boards of directors that determine the AP Pension Group's mission, vision and strategy.

AP Pension processes customer data in connection with delegate elections and general meetings. This is done for all customers to have the opportunity to participate in AP Pension's customer democracy. The processing of data will be adapted to the individual's position in the process. Thus, an increased processing of data for elected board members and delegates is to be expected than for other customers.

For elected board members, there will be a requirement for processing information for the purpose of fit and proper assessment to the Danish Financial Supervisory Authority as well as ongoing competence assessment.

Categories of personal data

AP Pension processes various personal data about you. This personal data will be:

General and confidential personal data

Name, your contact information (e.g., address and e-mail), that you have a customer relationship with AP Pension, possibly election group, employer, professional position, demanding organizational tasks and possibly CPR number.

Personal data relating to criminal offences.

Criminal record for use in fit and proper assessment to the Danish Financial Supervisory Authority for members of the Executive Board and the Board of Directors.

Where do we get information about you from?

The information we process will typically have been received as part of your customer relationship with AP Pension. In many cases, this is information that you have provided to us yourself, but it may also be information that we have received from your employer in connection with your customer relationship.

With regard to board members and members of management in general, there are a number of requirements in legislation and from the authorities as to what competencies a director must have. Therefore, AP Pension collects information for use in competency assessment and fit and proper.

The information processed by the AP Pension Group will most often be provided by the individual management member but may also originate from authorities and public sources.

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

• We collect, use, and disclose your personal data for the purpose of fulfilling the contract we have with Foreningen AP Pension f.m.b.a.'s members, who have the right to exercise their rights in relation to customer democracy in the AP Pension Group (Article 6(1)(b) of the General Data Protection Regulation).
• We process information regarding Foreningen AP Pension f.m.b.a.'s members. The reason for this is a legitimate interest in being able to maintain customer democracy in the AP Pension Group and ensure the data subjects' opportunity to participate actively in customer democracy (Article 6(1)(f) of the General Data Protection Regulation).
• The collection, use and disclosure of CPR numbers is a natural part of the company's operations. Processing and disclosure are also necessary for unique identification in relation to existing customer relationships when performing administrative tasks and advice and for meeting requirements from public authorities, as well as for legal claims to be established, exercised or defended (Data Protection Act § 11(2), no. 1, cf. the Danish Financial Protection Act, Company § 43 b and the Data Protection Act § 7 (1) and Article 9 (2) (f) of the General Data Protection Regulation.
• We process data about members of the management of the AP Pension Group in order to maintain a wide range of legal obligations in accordance with, among others, the Danish Companies Act, the Financial Business Act and related regulation, the Danish Financial Statements Act, etc. (Article 6(1)(c) and Article 10 of the General Data Protection Regulation and the Financial Business Act with regard to requirements for submission of criminal records). It should also be noted that the processing of both general data and criminal records is necessary for the performance of a task that falls under the supervision and exercise of authority by the Danish Financial Supervisory Authority (Article 6(1)(e) and Article 10 of the General Data Protection Regulation and the Financial Business Act).

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

• Partners who help AP Pension with e.g., technical support and supplier services. The partners act solely on behalf of AP Pension. This means that they may not use the information for their own purposes.
• Authorities, including the Danish Financial Supervisory Authority and the Danish Business Authority.
• If you stand as a delegate, your information will be passed on to your electoral group.
• Candidates for the Board of Directors must expect that information about candidacy will be communicated in general meeting material. For example, publication of candidate profile on the AP Pension Group's website.
• The public, as there is a legal requirement that the remuneration of the Board of Directors and the Executive Management appear in the annual accounts.
• The names and positions of board members will appear on the company's website and possibly also in print media.

In some cases, we collect personal data about you if you are employed by one of our suppliers or partners (hereinafter referred to as a contracting party). We collect this personal data when you act on behalf of the contracting party as a contact person for the contracting party, e.g., when entering contracts with AP Pension or when providing services to AP Pension or other business contact.

Categories of personal data

AP Pension processes various personal data about you. This personal data will be:

General personal data

Name, your contact details of our contracting party where you are employed (e.g., your work email and phone number), employer and position.

Where do we get information about you from?

The information that we do not receive directly from you, we will typically receive from our contracting party.

Why are we allowed to process your personal data?

AP Pension collects, uses, and discloses your personal data based on the following legal grounds:

• We collect, use, and disclose your personal data for the purpose of entering and fulfilling the contract we have with the contracting party (Article 6(1)(b) of the General Data Protection Regulation).
• We process your data when you contact AP Pension on the basis of a legitimate interest in being able to handle and answer inquiries and contact business contacts (Article 6(1)(f) of the General Data Protection Regulation).

Disclosure of your personal data

AP Pension may disclose your personal data to the following category of recipients:

• Data processors and business partners acting on behalf of AP Pension. These parties may only process information on the basis of instructions from AP Pension and may not use the information for their own purposes.