Your privacy

Your privacy

In the context of our activities, we, the partnership (maatschap) Wieringa Advocaten, may process personal data relating to you. Through this privacy statement, we inform you about what personal data we may process, the grounds for doing so and your rights in this regard. Any processing for which we are the controller is carried out in accordance with this privacy statement and the applicable legislation. This statement relates to the processing of personal data of clients, job applicants, website visitors, bankrupts and persons subject to bankruptcy proceedings, and other parties, such as clients' counterparties and suppliers.

A. What personal data do we process about you, and for what purposes?

    The categories of personal data we may process about you depend on your relationship with us: for example, we process different personal data about clients than about job applicants. Below, we explain for each category of data subjects which personal data we may process and for what purposes. For each processing purpose, we indicate the legal basis for the processing concerned by means of a letter. The letters correspond to the classification in Article 6, first paragraph, of the General Data Protection Regulation. All our processing is based on one of the following legal bases.

    a)         The processing takes place with your consent.

    b)         The processing is necessary for the performance of a contract with you or in the phase prior to entering into a contract.

    c)         The processing is necessary in order to comply with a legal obligation to which we are subject.

    f)         The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms.

    Clients

    We may process the following categories of personal data about our clients, including their employees and other contacts:

    • name, title, job title
    • home and work address, e-mail address
    • telephone number, fax number
    • date and place of birth, gender
    • copy and number of identification document, nationality
    • details about your company, such as Chamber of Commerce and VAT numbers
    • correspondence, such as letters and emails
    • information relevant to the matters we are handling for you, such as information about your employer or client, legal proceedings, claims and assets
    • financial information, such as account details and our invoices to you

    We process this personal data for the following purposes, on the following grounds:

    • providing our services (b)
    • invoicing our services (b)
    • collecting receivables (b)
    • managing and auditing our bookkeeping (c, f)
    • complying with our legal obligations (c, f)

    Job applicants

    We may process the following categories of personal data about individuals who apply for a job with us:

    • name, title, job title
    • home and work address, e-mail address
    • telephone number, fax number
    • date and place of birth, gender
    • education, current and previous positions
    • names of references
    • social media profile addresses (e.g. LinkedIn)
    • correspondence, such as letters and emails
    • other personal data provided by you, for example in your CV

    We process this personal data for the following purposes, based on the following principles:

    • assessing your suitability (b, f)
    • determining and sending a job offer (b, f)
    • fulfilling our legal obligations (c, f)

    Website visitors

    We may process the following categories of personal data about visitors to our website and subscribers to our newsletter:

    • e-mail address of newsletter subscribers
    • data about visitor behaviour, such as IP addresses, pages visited on our website, time spent on our website and the page you visited before arriving at our website, by means of a Google Analytics cookie. We have set up Google Analytics data collection in a privacy-friendly manner in accordance with the advice of the Data Protection Authority. This means, among other things, that Google only processes part of your IP address and does not use your data for its own purposes.

    We process this personal data for the following purposes, on the following grounds:

    • to provide information about our activities (b, f)
    • ensuring our website functions as well as possible and adapting it to the behaviour of our visitors (f)
    • to comply with our legal obligations (c, f)

    Bankrupt and insolvent persons

    We may process the following categories of personal data about bankrupts (gefailleerden) and persons subject to administration (gesurseëerden), in respect of whom one of our solicitors (advocaten) has been appointed as liquidator (curator) or administrator (bewindvoerder), including contact persons associated with bankrupt companies and persons subject to administration:

    • name, title, job title
    • home and work address, e-mail address
    • telephone number, fax number
    • date and place of birth, gender
    • copy and number of identification document, nationality, citizen service number
    • details about your company, such as Chamber of Commerce and VAT numbers
    • correspondence, such as letters and emails
    • information relevant to the handling of your or your company’s bankruptcy or suspension of payments, such as legal proceedings and claims, as well as financial and public information

    We process this personal data for the following purposes, on the following grounds:

    • carrying out our assignment (c, f)
    • invoicing our services (f)
    • collecting receivables (f)
    • managing and auditing our bookkeeping (c, f)
    • complying with our legal obligations (c, f)

    Other relationships

    With regard to our other relationships, such as (contact persons of) counterparties of our clients, suppliers, references, potential clients and referrers, we may process the following categories of personal data:

    • name, title, job title
    • home and work address, e-mail address
    • telephone number, fax number
    • date and place of birth, gender
    • copy and number of identification document, nationality
    • details about your company, such as Chamber of Commerce and VAT numbers
    • correspondence, such as letters and emails
    • information relevant to cases we are handling or may handle in the future, such as information about your employer or client, legal proceedings, claims and assets
    • financial information, such as account details and invoices
    • other personal data that we have obtained from you or that we have collected from public sources and that is relevant to our relationship with you

    We process this personal data for the following purposes, on the following grounds:

    • providing our services (f)
    • fulfilling our obligations towards you (b)
    • informing you about our activities, acquisition (a, b, f)
    • purchasing products and services (b, f)
    • managing and auditing our administration (c, f)
    • complying with our legal obligations (c, f)
    • Obtaining personal data

    B. Obtaining personal data

    We obtain the personal data we process about you in various ways. In many cases, we will ask you to provide us with certain personal data, for example when you become a client or apply for a job with us. We also receive personal data from our clients, for example about their counterparties. We also collect personal data from public sources, such as the commercial register, company websites and social media.

    If you do not wish to provide certain personal data that we request, we may not be able to fulfil our contractual obligations towards you. This may result in us having to decide to terminate the services we provide to you, or us not being able to use your services. We will, of course, inform you of the consequences if you do not wish to provide certain personal data.

    C. Provision to third parties

    We will provide your personal data to third parties as little as possible. In some cases, however, we are obliged to do so, for example because the handling of our matters requires it or because we are required to do so by law. In such cases, we will not provide more personal data than is necessary.

    In the context of handling matters, we may provide personal data to other parties and advisers involved in the matter, judicial authorities, bailiffs, experts, notaries and other professional service providers. If you are a client of ours, we will usually do so in consultation with you. If you are not a client, this transfer will take place in order to protect our legitimate interests or those of our client. We will, of course, take your rights and interests into account in doing so.

    In all other cases, we will only provide your personal data to third parties if you have given your consent or if we are legally obliged to do so. This includes the provision of certain personal data to the tax authorities or investigative authorities. We will never disclose clients’ personal data to third parties without consent, unless we are obliged to report to the Financial Intelligence Unit Netherlands under the Wwft. If we wish to disclose your personal data to third parties for other reasons, for example in the context of an event that we are organising together with another company, we will inform you of this in person in advance.

    We use the services of a number of processors for the purposes of our business operations. These include ICT service providers, who, among other things, provide our digital working environment. We also use processors for the hosting of our website and for the system for sending our newsletter, as well as for keeping statistics on visits to our website. Furthermore, we have outsourced part of our paper archive to an external party, which also takes care of its destruction.

    Some of the third parties to whom we provide personal data are located in countries outside the European Union. The safeguards offered by these countries with regard to the protection of personal data may be more limited than those offered by the European Union. By means of contractual agreements, among other things, we ensure that your personal data is nevertheless protected as well as possible, in accordance with the requirements of the General Data Protection Regulation.

    D. Retention period

    In principle, we do not retain your personal data for longer than is necessary for the purposes mentioned above. We are required by law to retain certain personal data for a long period of time. For example, we must retain personal data that is subject to the fiscal retention obligation for at least seven years after acquisition.

    E. Your rights

    During the period that we process personal data about you, you have the right to request an overview of the personal data we process about you. If you find that personal data we process about you is incorrect, incomplete or no longer relevant, you can request us to correct or delete that personal data. In addition, you have the right to data portability, the right to object to our processing of your personal data and the right to request us to restrict the processing thereof. Insofar as our processing is based on your consent, you always have the right to withdraw that consent for future processing. Our contact details are at the bottom of this privacy statement. If you have any complaints about our processing of your personal data, you can also contact the Data Protection Authority.

    F. Changes to this privacy statement

    This privacy statement was last amended on 31 July 2019. We reserve the right to make changes. In the event of significant changes that are relevant to you, we will do our best to inform you.

    E. Questions or complaints?

    Do you have any questions or complaints? Please contact Victor Bouman by email at bouman@wieringa.nl or by post at PO Box 10100, 1001 EC Amsterdam. You can also reach us by telephone on +31 20 624 68 11.