Privacy Statement

Introduction

This is the Privacy Statement of vanOlde B.V., a tax law firm established in the Netherlands registered in the trade register of the Dutch Chamber of Commerce under number 76172066 (“vanOlde”).

We consider your privacy very important. In this Privacy Statement, we explain how and why vanOlde uses personal data when we provide tax services or in respect of other possible interactions we may have with you. 

This Privacy Statement is dated 29 November 2019 and will be updated from time to time. Any changes will be posted on our websites www.vanOlde.com and www.vanOlde.nl (“website”) and will be effective when posted. 

Contents 

1. What personal data do we collect and process?
2. Why do we collect, process and use personal data?
3. What is the legal basis for the data processing?
4. How long will we store personal data?
5. Do we share personal data with third parties?
6. How do we secure personal data?
7. Can we be obliged to disclose personal data?
8. Who is responsible for data shared through social media or other website?
9. What are your rights​?

1. What personal data do we collect and process​​​?

The term “personal data” refers to all information that can be used to identify an individual directly or indirectly. The personal data we collect and process may include the following information:

  • Contact details such as name, surname, address, email address, phone number, employer, title, position and your relationship to us;; 
  • Information provided to us as part of our client identification and acceptance procedures; 
  • Information provided to us or that is collected by us in the course of providing services to clients;
  • Financial information such as bank account details and VAT number; 
  • Information we derive from visits to our website and online platforms (including social media channels), such as IP address, pages visited and demographic information; 
  • Information provided to us or that we collected as part of a registration for newsletters, alerts, events and marketing materials, such as contact details, preferred language, interests and practice areas; 
  • Information provided by job applicants such as contact details, CV, assessments and notes of interviews; 
  • Any other information provided to us or that is collected by us from a third party source such as government, an information or service provider or from public records. 

2. Why do we collect, process and use your personal data?

We collect, process or use personal data for the following purposes:

  • to provide tax services to clients and to correspond with clients;
  • to communicate information about relevant tax developments, events or services, including via newsletters, alerts, event invitations etc.; 
  • to manage our business relationships (including services provided to clients and for invoicing, collection, payments and other support services); 
  • to answer queries if we are contacted with questions or a request;
  • to distribute surveys or marketing materials; 
  • to act in compliance with legal and regulatory obligations, including know-your-client, anti-money laundering and sanction regime checks; 
  • to manage and secure access to our offices, website and online platforms and for the functional management of our website; 
  • for purposes of vanOlde’s legitimate interest provided that such legitimate interest is not overridden by your interests or your fundamental rights and freedoms; 
  • to find suitable candidates for vacancies, to assess suitability for a job position, to determine employment terms, or (in the case of identity documents and certificates of conduct) because we have a legal obligation to do so.
  • to process and handle incoming invoices, for financial reporting purposes and to file tax returns.
  • for any purpose related to the foregoing or for any purpose for which personal data was provided or for which explicit consent was granted.

3. What is the legal basis for the data processing?

There are different grounds based on which we may use or process personal data:

  • Contract: Some personal data are required for us to deliver pursuant to an engagement with our clients. 
  • Legal requirement: We are required to include in our administration certain client acceptance data for identification purposes (whereby we do not store personal identification numbers) and invoicing details based on tax legislation. 
  • Legitimate interest: Other data processing takes place based on our legitimate interest, e.g. performance data of employees and applicant’s data for a vacancy. 
  • Consent: We require consent for sending newsletters, tax alerts, invitations via email to relations which are not clients. Consent can be withdrawn easily via the “unsubscribe” option in each newsletter or alert. Consent for placing cookies can be withdrawn via our website. 

4. How long will you store personal data?

We will store data no longer than necessary as defined by the purposes for which the data is stored. 

For the following categories of data we have defined a specific term for data storage:

  • Personal data in our own administration are kept for 7 years based on tax legislation, except if we are legally required to keep the data longer. 
  • Personal data of our clients are kept for a maximum of 2 years after termination of the engagement, except if we are required to keep the data longer. 
  • Personal data of employees are kept for 2 years after termination of an employment agreement, except if there is a requirement to keep the data longer. 
  • Personal data of applicants for vacancies are kept for six weeks after the application process. 

5. Do we share personal data with third parties?

We use processors to help us with our services. Within that context such processors receive personal data from us. Processors include external file management, CRM software, (wage) administration, cloud hosting, tax return software etc. These processors must follow our instructions strictly and we see to it that all of our processors comply with the relevant legislation. They will therefore not use the personal data for their own purposes. 

Apart from the above we will not share your personal data with others – unless we are under a legal obligation to do so or you give your explicit consent.

6. Can we be obliged to disclose personal data?

VanOlde may be required to disclose personal data by a court order or to comply with other legal or regulatory requirements. We will do everything we reasonably can to notify the persons involved before we disclose these data, unless we are legally restricted from doing so.

VanOlde is obliged to report unusual transactions to the Financial Intelligence Unit (FIU-Nederland). Furthermore, based on the mandatory disclosure rules for potentially aggressive tax structures, vanOlde may be legally required to report certain information containing personal data to the tax authorities. 

In such cases, vanOlde must provide the information it collected based on legal requirements.

7. How do we secure personal data?

VanOlde secures personal data through various technical and organizational measures. VanOlde takes office-wide security measures as part of its IT policy. Technical measures include the use of two factor authentication, access controls, virus scanner, firewall, encryption techniques, SSL certificate and password protection tools. Organizational measures include confidentiality provisions, screening of personnel, privacy and security awareness and implementing controls in contracts with suppliers. 

8. Who is responsible for data shared through social media or other websites​?

If you share the content from vanOlde’s website and online platforms via social media, your personal data will be visible to the visitors of your personal pages on these social media websites. We are not responsible or liable for any processing of your personal data via such media.

VanOlde’s website and online platforms may provide references – including hyperlinks – to websites, channels or social media from other companies/persons. VanOlde is not responsible or liable for any processing of your personal data via these websites, channels or media. This Privacy Statement does not apply to the use of such websites, channels or media.

9. What are your rights​?

You have the right to request to inspect and receive a copy of your personal data that we process, including the location where the data is stored, who receives your data, how long we store your data and for which purpose we process your data. You also have the right to request us to rectify, erase, or restrict the processing of your personal data and to withdraw your consent. You have the right to have your personal data transferred to a third party of your choice. 

Should you have any questions or complaints about this Privacy Statement or should you wish to exercise any of your rights in respect of your personal data processed by vanOlde, please send your request for to info@vanOlde.com.

If you believe that your rights as a data subject have been infringed, you have the right to lodge a complaint with the Autoriteit Persoonsgegevens

If you have any questions, comments or concerns related to the manner in which we handle your personal data, please contact us. 

vanOlde B.V.
Amstel 228
1017 AK Amsterdam
The Netherlands

Telephone: +31 (0)20 21 17 117
Email: info@vanOlde.com