Privacy statement

Effective May 2018

Your privacy is important

We, Strik Attorneys at Law and Tax Advisors (SAB), respect the privacy rights of all our clients. This privacy statement outlines the personal information that SAB holds and processes and where necessary, discloses to third parties.

SAB is data controller who is dedicated to being a guardian of information that is provided to us and the information that we gather over the course of operating our business. We assure our clients that their personal information is dealt with, with integrity and confidentiality. SAB will process your personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR) and other Dutch national applicable privacy laws.

This privacy statement is issued by SAB (The Netherlands, 1077 XX, Strawinskylaan 1439, Amsterdam) and applies to SAB. Please read below about how SAB processes and stores your personal data.

This present privacy statement describes:
– What is personal information?
– Why is such information requested and gathered?
– Consent – Prospective clients
– Client Personal Information
– Other information about you, not received by you
– No to cookies
– Who has access to your personal data?
– Retention Period
– Location of your personal data
– Security measures
– What are your rights?
– (Outside) the Economic European Area?
– How can you exercise your rights?
– Revision of the Privacy Statement
– Questions and Comments

1. What is Personal information
Personal information is information relating to an identified or identifiable natural person, (the Data Subject). This includes any information that can be used to identify or be linked to a Data subject

2. Why is such information gathered and requested?
Where applicable, SAB will differentiate between personal information that are optional and those that are mandatory to obtain due to legal grounds. Below are a few examples of legal grounds for obtaining personal information on the Data Subject.
– Performance of a contract – In order to fulfill our legal obligations, we may need to collect and use your personal information to enter into a contract with you or to perform a contract that you have with us. In short, we gather information to be able to provide services to the clients of SAB.
– Consent – you have voluntarily provided us with such information. This will allow us to correspond with you. Maybe you could be interested in future endeavors with us or receiving newsletters from us?
– Legitimate interests – The necessity to process data on the basis of the legitimate interests pursued by SAB.

3. Consent –Prospective clients
Optional data provided by you is usually given voluntarily and by consent. You can think of information gathered for networking purposes at seminars and conferences. Such personal data will usually concern personal information such as, your name, your contact information, your job title and the organization with which you are affiliated.
Since contact information has been provided by consent, communication exchange (such as, email, telephone or in person meetings) is data that we will likely retain, unless otherwise communicated by the Data Subject.

In the case that a Data Subject is considered as prospective client, additional information may be gathered about the Data Subject and the company you are affiliated to, from public sources, such as the internet and/or screening database. This will only occur when the data subject explicitly makes clear that they would like to consider a business relationship with SAB

4. Client Personal information
Other personal information is gathered from clients. In some instance, some personal information will largely depend on the services we provide to that client in particular. This includes, but is not limited to:
– Name, address and contact details;
– Date of birth and place of birth
– Gender
– Marital Status
– Personal information of the company you are affiliated to – employment status;
– Compliance documents;
– Copy IDs of relevant persons;
– Screening results of relevant persons;
– Business information – Structure and activities of the company at hand, bookkeeping and accounting information;
– Bank accounts and transfer amounts;
– Tax information;
– Contracts between SAB and the client;
– Relevant correspondence;
Please note that if you provide us with personal data (for example by sending an email or by asking for information via mail forms), SAB will use your data to respond to your request, and for further reference purposes.

5. Other information about you, not received by you
SAB may receive information about you from other sources, examples can include google alerts on press concerning our clients and data subjects. The latter is based on the legal grounds: Legitimate interest, public interest, performance of contract and legal obligation.

This applies to existing clients as well as identifying new clients. The information we may receive is governed by the privacy settings, policies, and/or procedures of the applicable online media platform.

6. Cookies
The website of SAB uses google-analytics cookies. This means that we can see who has accessed the website, the IP, the browser type, the country etc. However, generally speaking SAB does not use this functionality.

7. Who has access to your personal data?
SAB may share the personal data of clients with the employees of SAB in order to perform the contract between SAB and the client. Access to personal data is in place with the sole intention of providing proper legal services as stated in the engagement letter or other agreements signed by the client.

In some cases, personal information will not be disclosed to third parties, unless for the following reasons, (i) with your prior consent (ii) and/or for public interest:
– To our third party service providers that perform services on our behalf. This will include banks, advisors, tax authorities, notaries, chamber of commerce, potential transactional partners and counterparties.
– This can also include third parties in connection with the consideration, negotiation, or completion of a transaction in which clients are acquired by or merged with another company. Examples will include the sale, liquidation, or transfer all or a portion of assets as required by applicable legal or regulatory requirements or court order.
Such acts are therefore made on behalf of the client, with the knowledge of the client, based on the necessity of the execution of a contract.
– We may also in limited situations share personal information with government authorities, law enforcement etc. SAB will do the latter where required to protect the interests of SAB If such circumstances are to arise, SAB will take reasonable efforts to notify you before such information is disclosed, unless proper notice is prohibited by applicable law.

If such circumstances arises, SAB will take reasonable efforts to notify you before such information is disclosed, unless proper notice is prohibited by applicable law.

8. Location of your personal data
We store your personal data in several different locations.

Locations include:
– Our server – this can and will only be accessed by employees of SAB through their own account. Each account is secured with a password and therefore no-one other than the SAB employees and the IT third party of SAB, who have all signed confidentiality agreements, have access to this data. The same applies to working emails
– Hard copies – for the sake of the compliance files that we have for each client, personal info are printed and put in the folder. These folders are stored in locked cupboards. Our employees are the only ones that can access these cupboards.
– CRM – CRM is an internal database that SAB uses for business relations and feeders and any other natural persons met and networking events. Business relations and feeders can often, for instance include law firms. In most cases, personal data collected from such individuals will include their name, telephone numbers, either home address and or address of work place of a business relations, feeders or prospect client.

9. Retention period
SAB will process and store the relevant personal data for the duration of our services or for the duration of the business relationship. SAB may also store the data for as long as it is necessary or required in order to fulfill legal, contractual or statutory obligations and, or for the establishment, exercise or defense of legal claims and in general where it has a legitimate interest for doing so.

10. Security measures
SAB has an suitable technical and security measures to protect the security of your personal information against the loss, misuse, unauthorized access, disclosure, alteration, unauthorized modification or unlawful destruction or accidental loss.

Where necessary, in the unlikely event that the latter may occur, SAB will inform respected persons with no further delay and the Dutch Data Protection Authority.

SAB complies with any data breach requirement set forth by the National Authority Persons. SAB has a Data breach protocol in place.

SAB is committed to ensuring the security of your personal data. SAB take appropriate commercially reasonable technical, physical and organizational measures to prevent unauthorized or unlawful processing of your personal data or accidental loss or destruction of your personal data.

SAB will ensure a level of security suitable to the identifies risks and pursuant to applicable Data Protection Laws and where the Processing concerns personal data of EU residents, shall take measures required pursuant to article 32 GDPR.

Employees of SAB will handle your personal data with utmost respect and they will treat your personal data strictly confidential. Staff member shall be authorized to access personal data only to the extent necessary to serve the applicable legitimate purposes for which the data are processed by SAB and to perform their job.

11. What are your rights?
You, as a data subject have the following rights as of data subjects at SAB:
– The right to be informed about processing activities (elaborated upon in general conditions)
– The right to access your personal data
– The right to rectification
– The right to object to (part of) the processing activities
– The right to erasure of your personal data (the right to be forgotten)
– The right to restriction to (part of) the processing
– The right to data portability
– The right to compensation in case of violation of your privacy rights

At the start of any business relationship between SAB and a client, SAB informs the client which documents will be needed to proceed with extending services. In this regard, clients are informed beforehand about processing activities that are to take place, and are aware that such documents are necessary to collect before performing the tasks of the contract.

If you choose to exercise any of the above mentioned rights, please reach out to us on the below email found under the “questions and comments” section. Please title your emails with “Data protection” plus your request.

12. Outside the European Economic Area (EEA)

It certain cases SAB may transfer personal data to other third parties outside the European Eco-nomic Area, (EEA), in order to service the client. The data is always transferred subject to the con-sent of the client.

If disclosure or transfer of personal data is being done in a country that does not ensure an ade-quate level of protection of your personal data, SAB will make sure additional safeguards will be put in place.

13. How can you exercise your rights
You have the right to access, delete, correct or update the personal information or making inquiries about the processing of such information by contacting us through the email stated below.

SAB will provide you with access and review your personal information under applicable data protection and privacy laws within a reasonable timeframe. This will take place within one month from the receiving date of the request.

SAB acknowledges that data subjects have a right to apply for a copy of the information we hold about you, the first time you request for this information, no charges will be made, however if it is a repetitive request, SAB will then charge an administration fee. Before processing your request, SAB may verify your identity prior to disclosing any personal information to you.

Please feel free to contact us using the contact details below if you would like any corrections made to your information.

14. Revisions to the Privacy Statement
SAB reserves the right to change this Privacy Statement from time to time. Please check the Privacy Statement frequently and particularly before you submit additional personal information through the colleagues of SAB. All revisions to this privacy statement will be reported on the website via a link from the homepage. We will also place the effective date.

By visiting the Website(s) you are accepting and consenting to the practices and provisions set out in this privacy statement.

15. Questions and Comments
For any question about our privacy statement, or if you need assistance accessing or updating information we have collected about you, please contact us at the below email or address.

Address:
Strawinskylaan 1439
1077 XX Amsterdam
The Netherlands
E-mail: info@strik-law.nl