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This Privacy Statement provides information on how TreasurUp in the Netherlands approaches the processing of your personal data.
Last updated 26 November 2025
Because we refer to processing personal data in this privacy statement, we believe that it is important to specify to you what is understood when we use terms such as ‘personal data’ and ‘processing’.
This entails data which is related directly or indirectly to you as a natural person.
Anything which can be done with your personal data. This includes the collecting, the sorting, the using, passing on and deleting of personal data.
We process personal data if we have, want to have, or have had a business relationship with you, or if we have had contact with you and/or your representatives. The people whose personal data we process include:
| Type of data | What this might involve | How TreasurUp uses it |
|---|---|---|
| Information that allows an individual to be identified directly or indirectly | Name, address, telephone number, e-mail address, information provided in your identity document. | To draw up an agreement or to contact you. |
| Recorded calls, conversations with TreasurUp employees, recordings of video calls, online chat sessions, recorded e-mails and social media | Conversations we have with you by telephone, online chat or video, conversations in person that we register, e-mails, and comments, video, photographs, likes and public posts on our social media pages. | To combat fraud, fulfil legal obligations, monitor quality, provide proof, improve our services and train, coach and assess our employees. Social media activity is used to answer questions and share information. |
| Data we share with other parties | Data we provide to other parties that we engage to help us provide services, and data we have to share with our regulators. | To enable our services to be used, to improve our services and website, and to meet regulatory requirements. |
| Data we require to ensure your security and ours | IP address, device details and cookies. | To combat online fraud (DDoS attacks) and botnets, and to monitor internet behaviour in our services and on our website using analytical cookies. |
If we use e-mail during a campaign, we might check if you opened it and whether you clicked a link within it. We use that data to find out if a campaign is successful, on an aggregated level only, never on a personal level.
In principle we receive your personal data because you provide it to us yourself. Examples include data you enter on our website yourself in order for us to contact you, and data arising from the services we provide. We may also receive your data from:
We use the “legitimate interest” basis to process your personal data. We make a trade-off between the interests of TreasurUp or third parties and the violation of your privacy. Our interests are, for example, the following: we combat fraud to ensure your security and ours and to prevent damage; we need to improve our business processes, take measures in the context of company management and perform audits on our internal processes; and we have an interest in direct marketing, keeping you informed of new or existing products that we believe fit you.
When you are a client of ours, we want to be of service to you. We execute the instructions we receive from you and execute the agreements we have concluded.
Legal basis: we process personal data because this is necessary in order to perform the agreement.
In order for us to be of service to you and to innovate for your benefit, we develop and improve products and services on an ongoing basis. We do this for ourselves, our bank clients or other parties.
Legal basis: we process your data because we have a legitimate interest in this.
We use data we have obtained from you, such as your activity on our website, as well as information not obtained directly from you, including public registers (such as the Chamber of Commerce), publicly available sources and other parties.
Legal basis: we process your data because we have a legitimate interest in this.
If you have contact with TreasurUp for work-related reasons, we may process your personal data, for example for determining whether you are permitted to represent your business, or whether we can give you access to our offices and/or services.
Legal basis: we process your data so that we can perform the agreement we have concluded, or because we have a legitimate interest in this.
We also use data to analyse and improve our business processes so that we can help you more effectively or make our processes more efficient and create management reports.
Legal basis: we process your data because we have a legitimate interest, or it is necessary for the performance of our agreement with you.
We may also process your personal data if this is necessary for archiving purposes, scientific or historic research purposes or statistical purposes.
Legal basis: the legitimate interest of TreasurUp, or our clients and employees, or a legal obligation.
We do not keep your data for any longer than necessary to fulfil the purposes for which we collected the data or the purposes for which data are being reused. We follow a data retention policy that specifies how long we keep data. In the Netherlands, this is usually for two years following the termination of the relevant agreement or the ending of your business relationship with TreasurUp. Data are sometimes kept for longer and in some cases we use shorter retention periods. Once we no longer require the data for the purposes described above, we may still keep the data for archiving purposes, in the event of legal proceedings, or for historic or scientific research purposes or statistical purposes.
Yes, TreasurUp may share your personal data with third parties, but only where necessary and with appropriate safeguards.
We do not sell your personal data to third parties.
Within TreasurUp, only those people that require access to your personal data based on their function can actually access your personal data. All of these people are subject to a duty of confidentiality.
Your personal data can also be passed on to other parties outside of TreasurUp if we have a legal obligation to do so, if we have to fulfil an agreement with you, or because we decide to use a different service provider. If we transfer your personal data to parties outside the European Union or European Economic Area ourselves, we will take extra measures to protect that personal data. Not all countries outside of the EU have the same rules and regulations to protect your personal data. Where a third party is located in a country that does not have a sufficient level of protection according to the European Commission, we only transfer personal data when there are sufficient guarantees, such as European Commission approved contractual obligations.
This Privacy Statement describes what TreasurUp does with your data. In certain cases we provide additional or different information, by letter, by a message in your secure inbox, or in another way to be determined by us.
You may ask us whether we process data relating to you, and if so, which data this concerns. If you believe your personal data has been processed incorrectly or incompletely, you may request that we change or supplement the data.
You may request that we erase data concerning yourself that we have recorded. We do not always have to do that, and sometimes we are not allowed to, for example if we still have to store your data due to legal obligations.
You may request that we temporarily restrict the personal data relating to you that we process. This means that we will temporarily process less personal data relating to you.
You have the right to request that we supply data you previously provided in the context of a contract or with your consent, in a structured, machine-readable format, or that we transfer such data to another party where technically feasible.
If we process your data because we have a legitimate interest, you may object. We will reassess whether your data can still be used for that purpose, and stop if your interest outweighs ours. We will inform you of our decision, stating the reason.
You have the right to request that we stop using your data for direct marketing purposes.
If you have a request, please send your message via our contact form. Where your request concerns personal data that we process, we will reply within one month of receiving it. We can ask you to specify your request for review. In highly specific circumstances we can extend the review term to a maximum of three months, and we will keep you informed of the progress.
It is possible that we cannot cater to your request, for example due to harm done to the rights of others, because we are not allowed to by law, or because the interest of TreasurUp or others to process the data outweighs your interest. If so, we will inform you. If we rectify or delete data based on your request, we will inform you of that as well, and where possible we will also inform the ultimate recipients of your data.
We would like our data subjects to be satisfied with our service provision, however we understand that this might not always be the case. Do not hesitate to reach out via our website contact form and inform us of your complaint, and together we will do our utmost to find a solution.
If you are unsatisfied with the way your request or complaint has been handled, or if you have any remaining questions regarding the processing of your personal data after reading this statement, please feel free to contact us. You are always free to direct your questions to, or submit a formal complaint at, the Autoriteit Persoonsgegevens, a Dutch government body.
Yes, our Privacy Statement can change from time to time. This can occur when new forms of data processing are included in our services, and when this processing is of importance to you. The most current version can always be found on treasurup.com.