VrijVermogen · Happynessplanner

Privacy Policy

We take the privacy of your financial data extremely seriously. This page explains, in plain language, what we collect, why, who processes it and how we keep it safe.

Zuletzt aktualisiert: October 7, 2026

Dieses Dokument ist derzeit nur auf Englisch und Niederländisch verfügbar. Die englische Fassung ist verbindlich.

VrijVermogen is operated by CEON Business Systems B.V., a company registered in the Netherlands; VrijVermogen is one of its trade names. This Privacy Policy describes how CEON Business Systems B.V. ("we", "us", "our") collects, uses, shares and protects information about you when you use our website, mobile applications and services (collectively, the "Service"). We are the controller of that data under the General Data Protection Regulation (GDPR).

1. Information we collect

We only collect what we need to make the product work for you. There is no connection to your bank or broker: everything the Service knows about your finances is there because you entered it or uploaded it.

  • Account information — your e-mail address and the identifiers of our sign-in provider (Hanko). You sign in with a one-time code sent to that address or with a passkey; we never store a password.
  • Profile and plan data — what you enter so that the projections work: country, birth month, planned retirement date, income and expense periods, goals, reporting currency and language.
  • Financial data you enter — accounts and balances, holdings and transactions, property and mortgage figures, pension entitlements and your watchlist.
  • Documents you upload — CSV and PDF exports such as bank statements, broker exports, Dutch pension overviews, tax returns and WOZ assessments. A tax return can contain your citizen service number (BSN), and a bank statement shows whom you pay and are paid by. We store the document and the figures read from it with your account; only you can open it.
  • Usage and device data — the IP address, browser and operating system in our server logs, and aggregate, cookieless page statistics. We use them for security, abuse prevention and to see which pages are used — never to build a profile of you.
  • Payment data — if you subscribe, our payment provider Mollie handles the payment. We never see your card or bank details; we receive only the payment status and a customer id.
  • Mobile apps — the iOS and Android apps register a device token with us so that we can deliver the push notifications you have turned on.

2. Why we process it, and on what legal basis

The GDPR requires a legal basis for every use of your data (Article 6). Ours are:

  • Performance of our contract with you — storing your data, computing your net worth, projections and reports, sending the notifications you asked for, and handling your subscription and support requests.
  • Your consent — the AI features, which send your figures and the text of your documents to the AI providers named below, and marketing e-mail. The weekly digest is sent only if you turned it on in your notification settings, where you can turn it off again. You can withdraw your consent to the AI features at any time by e-mailing privacy@vrijvermogen.nl; we then stop them for your account.
  • Our legitimate interests — keeping the Service secure and preventing abuse (server logs, reCAPTCHA on our public forms), and understanding how the Service is used through aggregate statistics. We keep this processing to the minimum and have weighed it against your interests.
  • A legal obligation — keeping invoices and payment records for as long as Dutch tax law requires, and answering lawful requests from authorities.

We never sell your personal or financial data. We never use your financial data to train third-party models.

3. AI features

The AI features — the prompt bar, what-if scenarios, the Wellness Report, the crisis resilience analysis, stock reports, the weekly signals, the monthly investment ideas and the analysis of uploaded statements and tax returns — send the relevant figures and the text of the documents you uploaded to Google Gemini (Google LLC / Google Ireland Limited). Uploaded PDFs are first sent to Mistral AI (France) to read their text (OCR). Both providers process the data only to answer our request.

Google may process this data outside the EU. That transfer takes place under Google's API terms and the European Commission's standard contractual clauses. Everything else — your account, your figures, your documents and the database — stays on our server in the EU.

4. Security

  • All traffic between your device and our servers is encrypted in transit (TLS).
  • The server disks that hold the application, the database and your documents are encrypted at rest.
  • Passwordless sign-in — a one-time code to your e-mail address or a passkey — so there is no password of yours to leak.
  • Access to the servers and the database is limited to the operator.

5. Hosting and the providers we work with

The application and its database run on a server in the EU (Hetzner, Germany). We share data with the following service providers, each only for the purpose named:

  • Hetzner Online GmbH (Germany) — hosting of the application, the database and your documents.
  • Hanko — passwordless sign-in: your e-mail address and the one-time codes. We never store a password.
  • Google Gemini (Google LLC / Google Ireland Limited) — the AI features: the relevant figures and the text of uploaded documents. Processing may take place outside the EU under Google's API terms and standard contractual clauses.
  • Mistral AI (France) — reading the text of uploaded PDFs (OCR).
  • Mollie — subscription payments. We receive only the payment status and a customer id, never your card or bank details.
  • EODHD — stock prices, exchange rates and company data. It receives no personal data.
  • Soverin — delivery of the e-mail we send you.
  • Google reCAPTCHA — protects the contact and advisor forms against bots. Google receives your IP address and browser data when one of those forms is shown.
  • Simple Analytics — cookieless, aggregate page statistics. It receives no personal data.
  • Google Fonts — the font files load from Google's servers, which transmits your IP address to Google when a page loads.
  • Apple Push Notification service and Google Firebase Cloud Messaging — delivery of push notifications to the mobile apps; they receive your device token and the notification being delivered.

We also disclose data to authorities when the law requires it, and only to the minimum extent necessary.

6. How long we keep your data

  • Your account, your figures and your documents: for as long as your account exists.
  • After a deletion request: we delete the account and everything stored with it within 30 days.
  • Invoices and payment records: 7 years, as Dutch tax law requires — also after your account is deleted.
  • Server logs (IP address, requested page, time): 30 days.

7. Your rights (GDPR)

Under the GDPR you have the right to:

  • access the personal data we hold about you;
  • have it rectified when it is wrong;
  • have it erased;
  • restrict how we process it;
  • receive it in a portable format (data portability);
  • object to processing based on our legitimate interests;
  • withdraw consent at any time, without affecting what was done before.

Most of this is self-service. In Settings → Personal → "Your data" you can download everything we store about you as a JSON file ("Download my data") and ask us to delete your account ("Delete my account" → "Request deletion"): we delete the account and all its data within 30 days and confirm by e-mail, and until then you can withdraw the request on the same page. For anything else — or if you prefer — e-mail privacy@vrijvermogen.nl.

If you believe we handle your data unlawfully, you can lodge a complaint with the Dutch supervisory authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). We would appreciate the chance to put things right first.

8. Storage on your device

The Service uses your browser's localStorage and session storage to remember your preferences — language, currency, theme, dismissed hints — and your sign-in session. We set no advertising or tracking cookies, and our page statistics work without cookies. Google reCAPTCHA sets its own cookies on the contact and advisor forms, where it loads.

9. Changes to this policy

We may update this policy from time to time. Material changes will be announced via e-mail or in-app notification at least 14 days before they take effect.

10. Contact us

Questions about this policy or about your data? E-mail privacy@vrijvermogen.nl or visit our contact page.

Company details

  • Legal name: CEON Business Systems B.V.
  • Trade name: VrijVermogen