Privacy Statement
Hamelink & Van den Tooren

About HAMELINK & VAN DEN TOOREN, personal data and processing

Hamelink & Van den Tooren N.V., hereinafter "HAMELINK & VAN DEN TOOREN, we or us", has its registered office in the Hague, the Netherlands, and is registered with the Dutch Chamber of Commerce under number 27197846. The organization of HAMELINK & VAN DEN TOOREN focuses on Dutch tax law. Ensuring the privacy of its clients, employees, visitors and other relations is of fundamental importance. 

HAMELINK & VAN DEN TOOREN processes your personal data in accordance with applicable privacy legislation, including the General Data Protection Regulation (GDPR). The term “personal data” means any piece of information directly or indirectly leading to the identification of a natural person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Examples of “processing” are: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data. 

To whom does this Privacy Statement apply?

This Privacy Statement applies to all natural persons of whom HAMELINK & VAN DEN TOOREN
processes personal data. Examples are:
● (contact persons or directors of) HAMELINK & VAN DEN TOOREN’s clients;
● (contact persons or directors of) potential clients of HAMELINK & VAN DEN TOOREN;
● applicants;
● (contact persons of) suppliers;
● (other) third parties that communicate with HAMELINK & VAN DEN TOOREN.

What types of personal data does HAMELINK & VAN DEN TOOREN process and why?

Goal / purpose

Group

Personal data

In order to contact you in connection with the services or products to be provided by your company.

HAMELINK & VAN DEN TOOREN processes personal data that you have provided to us. Generally
speaking, HAMELINK & VAN DEN TOOREN processes personal data for the following purposes:
●  maintaining contact with you;
● providing services in the field of Dutch tax law;
● compliance with our statutory (retention) obligations;
● pursuing legitimate interests of HAMELINK & VAN DEN TOOREN, for example in the context of the handling of a complaint;
● improving the quality of our services.

(contact persons
or directors of)
Suppliers

Name-Address-City, e-mail address,
telephone number.

Contact persons / directors of 
clients:


Name-Address-City, gender, date of birth,
place of birth, citizen number (BSN),
e-mail address, telephone number.

For the purpose of identification and
in order to contact you.

Individuals acting in
personal capacity


Name-Address-City, gender, date of birth,
place of birth, citizen number (BSN),
e-mail address, telephone number.

For the purpose of iidentification and
in order to contact you.

(contact persons
or directors of)
Potential clients

First name, last name, e-mail address,
telephone number.

In order to contact you with regard to planning an appointment and answering any questions.

Applicants

First name, last name, address, place of
residence, postal code, e-mail address,
telephone number, date of birth, place of
birth, nationality, work experience and the
documents you have uploaded.

To give you the opportunity to
communicate with HAMELINK &
VAN DEN TOOREN about
vacancies; and to participate in
the relevant application process.

What types of personal data does HAMELINK & VAN DEN TOOREN process and why?

Goal / purpose

Group

Personal data

In order to contact you in connection with the services or products to be provided by your company.

HAMELINK & VAN DEN TOOREN processes personal data that you have provided to us. Generally
speaking, HAMELINK & VAN DEN TOOREN processes personal data for the following purposes:
●  maintaining contact with you;
● providing services in the field of Dutch tax law;
● compliance with our statutory (retention) obligations;
● pursuing legitimate interests of HAMELINK & VAN DEN TOOREN, for example in the context of the handling of a complaint;
● improving the quality of our services.

(contact persons
or directors of)
Suppliers

Name-Address-City, e-mail address,
telephone number.

Contact persons / directors of 
clients:


Name-Address-City, gender, date of birth,
place of birth, citizen number (BSN),
e-mail address, telephone number.

For the purpose of identification and
in order to contact you.

Individuals acting in
personal capacity


Name-Address-City, gender, date of birth,
place of birth, citizen number (BSN),
e-mail address, telephone number.

For the purpose of iidentification and
in order to contact you.

(contact persons
or directors of)
Potential clients

First name, last name, e-mail address,
telephone number.

In order to contact you with regard to planning an appointment and answering any questions.

Applicants

First name, last name, address, place of
residence, postal code, e-mail address,
telephone number, date of birth, place of birth, nationality, work experience and the
documents you have uploaded.

To give you the opportunity to
communicate with HAMELINK & VAN DEN TOOREN about
vacancies; and to participate in
the relevant application process.

On what legal grounds does HAMELINK & VAN DEN TOOREN process personal data?

The processing of personal data may be necessary for concluding an agreement or in the run-up thereto. When you grant us the assignment to provide services in the field of Dutch tax law, we process personal data if and insofar this is necessary for the execution of that assignment. 

Furthermore, it is possible that personal data we process, is processed based on your consent. If you do not want HAMELINK & VAN DEN TOOREN to process the personal data (which it processes with your permission), you can withdraw your consent. HAMELINK & VAN DEN TOOREN will then stop processing the personal data, unless the law or a legitimate interest of HAMELINK & VAN DEN TOOREN or a third party opposes to this. If HAMELINK & VAN DEN TOOREN stops processing personal data at your request, this may result in you no longer being able to use (all) our services. 

We do not retain the personal data longer than necessary for the purpose for which you have provided with it, unless longer retention is required to comply with a statutory obligation or to pursue a legitimate interest of HAMELINK & VAN DEN TOOREN. For example, an administrative retention obligation of seven (7) years applies for certain data. Personal data provided to HAMELINK & VAN DEN TOOREN within the context of an application, will be retained for up to four (4) weeks after the application process has been completed, unless you have given your consent for longer retention thereof. Finally, processing takes place based on a legitimate interest of HAMELINK & VAN DEN TOOREN, such as processing within the context of internal management, for effective communication and quality improvement. 

How does HAMELINK & VAN DEN TOOREN protect the personal data? 

HAMELINK & VAN DEN TOOREN will do its utmost to take appropriate technical and organizational security measures to protect your personal data against loss or against any form of unlawful processing. The following principles apply: 

● HAMELINK & VAN DEN TOOREN does not process more personal data than is necessary in order to provide its services to you and to realize the other aforementioned goals/purposes.
● All employees of HAMELINK & VAN DEN TOOREN have a duty of confidentiality and will not share personal data with third parties, unless there is a legal ground for this. 
● Only those employees of HAMELINK & VAN DEN TOOREN who are involved in providing services to you, have access to the personal data that is necessary in order to do so. 
● Employees of HAMELINK & VAN DEN TOOREN will discuss privacy-sensitive topics with you at the right time and in the place. 
● HAMELINK & VAN DEN TOOREN only uses secure computer programs, servers and connections. Only the devices managed by HAMELINK & VAN DEN TOOREN have direct access to our systems. Devices that are not managed by HAMELINK & VAN DEN TOOREN only have access to our systems via secure connections. Our systems are checked for suspicious activities, via monitoring by a certified third party. 
● Physical files are kept to a minimum and are stored in closets equipped with locks.
● Our offices are protected by admission control (reception) during office hours. Only authorized persons have access to our offices. 
● When HAMELINK & VAN DEN TOOREN engages a third party for the performance of certain activities, HAMELINK & VAN DEN TOOREN warrants that the same levels of security and confidentiality apply to these third party as maintained by HAMELINK & VAN DEN TOOREN. 
● Transfer of personal data to parties in countries outside the European Economic Area will, if at all, only take place in accordance with the requirements set in that regard by the applicable privacy legislation. 
● Requests done by third parties to provide your personal data that are not based on a legal duty, will only be granted with your explicit consent. 

What are your rights? 

If desired, you can exercise the following rights at any time: 

Access: you can ask HAMELINK & VAN DEN TOOREN for access to and inspection of your personal data that is processed by HAMELINK & VAN DEN TOOREN; and to obtain a copy thereof; 
● Correction or supplementation: if your personal data that HAMELINK & VAN DEN TOOREN processes is not correct or incomplete, you can ask HAMELINK & VAN DEN TOOR to correct or supplement it; 
Removal: if you no longer agree to the processing of your personal data by HAMELINK & VAN DEN TOOREN or if you believe that the processing of your personal data by HAMELINK & VAN DEN TOOREN is no longer necessary for the purpose for which you provided HAMELINK & VAN DEN TOOREN with it, you can ask HAMELINK & VAN DEN TOOREN to delete the relevant personal data; 
Restriction: if you suspect that HAMELINK & VAN DEN TOOREN processes more personal data than necessary, you can request HAMELINK & VAN DEN TOOR to process less personal data;
Objection: if you are in doubt as to whether your personal data is lawfully processed by HAMELINK & VAN DEN TOOREN, you can object to the processing thereof; 
Data portability: if you have provided HAMELINK & VAN DEN TOOREN with personal data and HAMELINK & VAN DEN TOOREN have processed this personal data digitally, you can request HAMELINK & VAN DEN TOOREN to make this personal data available to you in digital form.

To exercise the rights mentioned above, you can submit a written request to Pauline de Bruin via privacy@hamelinktooren.com. HAMELINK & VAN DEN TOOREN will deal with your request as quickly as possible, and in any case within the legal term set for that purpose. HAMELINK & VAN DEN TOOREN will comply with your request if and insofar you are entitled thereto in the relevant case.