We greatly value and respect your privacy and are committed to protecting it and ensuring that your personal data is used correctly. We process personal data of visitors to our website and within the context of our services to clients. This Privacy Statement tells you how we deal with your personal information.

 

More specifically, we explain:

  • What information we collect about you;
  • For what purposes we use your information;
  • The lawful basis for using your information;
  • Who we may share your information with;
  • How we protect your information; and
  • What rights you have with regard to your personal information.

This Privacy Statement covers all personal data collected by the following companies (hereinafter referred to as “WVDB”):

  • PaCo B.V.
  • WVDB Holding B.V.
  • Moore Stephens Witlox Van den Boomen B.V.
  • Witlox Van den Boomen Accountants N.V.
  • Witlox Van den Boomen Belastingadviseurs B.V.
  • Witlox Van den Boomen B.V.
  • Witlox Van den Boomen Bedrijfsadviseurs B.V.
  • Witlox Van den Boomen Pensioenadviseurs B.V.
  • Witlox Van den Boomen Corporate Finance B.V.
  • Witlox Van den Boomen Personeel & Organisatieadviseurs B.V.
  • Witlox Van den Boomen Salarisadviseurs B.V.
  • WVDB IT Adviseurs B.V.

 

Where this Privacy Statement refers to “we”, “our” or “us”, it refers to WVDB.

We process personal data about individuals who we have or wish to have or previously had a commercial relationship with, or who we have had direct or indirect contact with. For example, personal information about:

  • prospects, if they are a natural person;
  • clients, if they are a natural person;
  • clients’ representatives;
  • clients’ employees, directors, or ultimate beneficial owners, for example to issue a UBO declaration;
  • persons who provide services to WVDB , or contacts or other persons working for suppliers of WVDB;
  • anyone who has shown an interest in WVDB, for example by filling in a contact form on our website or attending any of WVDB's recruitment or other events;
  • recipients of newsletters or invites for events;
  • visitors to our website at www.wvdb.nl, mijn.wvdb.nl or werkenbij.wvdb.nl;
  • job applicants;
  • persons who have otherwise contacted us or whose personal information we otherwise process for the purpose of providing our services.

We may receive personal information directly from you if you provide that information on any of our websites or use any of our services.

 

We may also receive information from others such as VDB Advocaten Notarissen, a law firm that we have partnered with.

 

Additionally, we use public sources, such as public registers, newspapers, or the Internet.

We may process personal data only if there is a legal basis for doing so. We will therefore process personal data only if:

 

  1. processing is necessary to perform the agreement between us and you, for example to provide our services, render advice, etc. (“performance of an agreement");
  2. processing is necessary for WVDB to comply with a legal obligation, such as our obligation to verify your identity and to conduct background checks on clients as required by the Dutch Money Laundering and Terrorist Financing Act (“MLTFA”) (“legal obligation”);
  3. processing is necessary to protect the legitimate interests of WVDB or others.
    As regards the latter reason, we will always consider whether those interests do in fact outweigh your interests or fundamental rights. That will be the case, for example, when we use your contact details to send you unsolicited commercial messages or to maintain our business relationships (“legitimate interest”);
  4. you have given consent to the processing (“consent").

The tables below show you what type of personal information we process and the purposes and legal basis for processing.

 

If you are a client or potential client

 

Type of personal data

   

Purpose for data use by WVDB

   

Basis for processing

Identification and contact details such as:

  • Name and address
  • Phone number, email address
  • Date and place of birth
  • Citizen Service Number (BSN)
  • Gender
  • Passport photo/copy of ID
  • CCTV footage (when visiting our offices)
 
  • For identification and verification purposes and to run background checks as required by the MLTFA

  • To contact you


  • To draw up contracts

  • To create and manage client files

  • To send invoices


  • To record data as required by the MLTFA

  • For relationship management, promotion, and marketing purposes

  • To secure and manage our property and systems

     

     

 
  • Legitimate interest
  • Legal obligation
  • Performance of an agreement

  • Performance of an agreement
  • Legitimate interest

  • Performance of an agreement

  • Legitimate interest

  • Legitimate interest
  • Performance of an agreement

  • Performance of an agreement
  • Legal obligation

  • Legitimate interest
  • Consent

  • Legitimate interest

 

 

 

 

Information about our services or enabling delivery of our services:

  • Company details, such as an extract from the trade register and VAT numbers
  • Company name and job title of contact and/or representative
  • Bank and payment details
  • Reports of meetings
  • Your financial situation
  • Citizen Service Number (BSN) (so as to file tax returns, etc.)
  • File content, such as correspondence, opinions, and other documents relating to instructions to advise and/or audit your organisation;
  • Content of communications such as emails, letters, etc.
   
  • Delivery of services to clients

     

 

 

 

  • Performance of an agreement
  • Legal obligation
  • Legitimate interest

 

 

Information about your preferences in terms of our services, including surveys and information on or enabling the use of our website, such as:

  • IP address
  • login details
  • your interests and preferences
  • your browsing and viewing data
  • other cookie data
   
  • To improve our services and websites

  • To provide and improve a personalised customer environment and to personalise your customer experience

 

 

  • Legitimate interest
  • Consent

  • Performance of an agreement
  • Legitimate interest
  • Consent

 

If you are a job applicant

 

Type of personal data

   

Purpose for data use by WVDB

   

Basis for processing

Information that is relevant to the recruitment and selection procedure, including:

  • Name and address
  • Email address
  • Phone number
  • Gender
  • Date of birth
  • CV
  • Motivational letter
  • Photo
  • References
  • Availability
  • Certificate of good conduct (where necessary)
  • Assessments
 
  • To assess your suitability for a vacancy or upcoming vacancy

  • To share your personal data with manager(s) or other employees within the organisation tasked with the selection process

  • To contact you for an interview

  • To contact any references/educational establishments that you have provided (where necessary).

  • To provide you with information about other vacancies for which you may be eligible

  • Screening

  • To send you general information about WVDB.

  • If you are hired: to draw up and perform the employment contract and provide you with an induction period at WVDB

 
  • Legitimate interest
  • Consent

  • Legitimate interest




  • Legitimate interest

  • Legitimate interest
  • Consent



  • Consent



  • Legitimate interest

  • Legitimate interest


  • Performance of an agreement

 

 

 

If you are a visitor to any of WVDB's websites

 

Type of personal data

   

Purpose for data use by WVDB

   

Basis for processing

Browser history, such as pages visited, date of visit, and location from where the websites were visited

 

 
  • To maintain, improve, and monitor the performance of our websites
 
  • Legitimate interest
IP address  
  • To give you access to our websites

 

 
  • Legitimate interest

 

Contact details, such as your name and email address  
  • To contact you in response to a request from you

  • To send you a newsletter

  • To respond to an information request from you

 
  •  Consent


  • Consent

  • Consent 

 

If you do not provide us with the information necessary for these purposes, this can have implications for your relationship with us. For example, we will not be able to respond to your requests or perform our agreement with you.

 

If we require your consent for processing your personal data, we will specifically ask you for your consent. You can withdraw your consent at any time. However, until that point, the processing of your personal data will be lawful.

If we process personal information for a purpose other than for which we obtained the data, we may do so only if the two purposes are closely linked.

 

If there is no sufficient link between the original purpose for which the data was obtained and the new purpose, we will ask you for your consent prior to processing.

We will keep your personal information for no longer than is necessary for the purposes for which we collected or reused that information.

 

In most cases, the retention period is 7 years starting from the end of the agreement or relationship between WVDB and you, unless we are required by law or rules of conduct to keep your personal information for longer, or unless WVDB has other valid grounds to keep your information for longer.

 

CCTV footage will be saved for no more than 4 weeks, unless it needs to be kept for longer in connection with an incident.

 

Job application details will be deleted 4 weeks after the end of the application procedure, unless the applicant is hired by WVDB or consents to the information being kept for longer (no more than 1 year).

Your personal information may be exchanged between WVDB group companies, as listed in section 2 above.

If we share your data with VDB Advocaten Notarissen, the law firm that WVDB has partnered with, we will ask you for your consent.

 

In some cases, we may be legally required to share personal or other data with regulatory authorities such as the Dutch Financial Markets Authority (AFM), Dutch Financial Supervision Office (BFT), Dutch Data Protection Authority (AP), the Dutch Revenue Service's Intelligence and Criminal Investigation Department (FIOD), the Dutch Financial Intelligence Unit (FIU), public prosecutors, courts of law, the police, or other law enforcement agencies. We are not allowed to notify you if we do.

 

We will also sometimes instruct third parties to process personal data on our behalf. These may include IT or other service providers. In all cases, we will enter into an appropriate data processing agreement with those third parties to ensure proper and safe data processing.

If we share personal data with third parties that are not subject to EU data protection rules and are not covered by an adequacy decision made by European Commission and do not otherwise provide an appropriate level of protection, we will protect your personal data using the European Commission's model contract clauses. These ensure that the third parties who we share your personal data with observe the same protection standards as we do. In all other cases, we will ask you for your consent.

We will do our utmost to protect your personal data for which we are responsible from loss, abuse, and unauthorised alteration.

 

We have taken appropriate technical and organisational measures to protect your personal information. For example, we have put in place access controls and appropriate system and network security measures, such as firewalls, encryption and patches, our mobile devices are properly password-protected, and all WVDB employees have a duty to treat your personal information confidentially.

We use cookies on our websites (www.wvdb.nl and werkenbij.wvdb.nl). A cookie is a small, simple file that is stored on your hard drive so we can recognise you on future visits and improve and simplify access to our websites.

 

If you do not want cookies to be stored on your hard drive, most browsers offer you the option to refuse cookies. If you use that option, our websites may not function properly. If you allow our websites to store a cookie on your hard drive, you can remove it after terminating your visit to the website. In addition to functional and analytical cookies, we will also store other cookies, such as tracking and social media cookies. We will ask your consent for that.

 

For more information about cookies, see our cookie statement (in Dutch).

You have various rights under privacy legislation regarding the processing of your personal data. You can exercise those rights at any time of your choosing.

 

If you wish to use any of the rights set out below, we may ask you to identify yourself or come to our office. That's because we want to make sure that we give out the data to the right person.

 

You can exercise the rights set out below by sending us a request using the privacy request form.

 

We will get back to you within one month of receiving your request. Please note that your rights are not absolute rights. They do not apply in all circumstances. The legislation provides for a number of exceptions. If we do not allow your request, we will explain why, unless this is not permitted by law.

 

  • You have the right to request access to the information we process about you;
  • You have the right to have information rectified or erased;
  • You have the right to request that we restrict the processing of your information;
  • You have the right to object to the processing of your information;
  • You have the right to have your information transferred.
  • If the processing is based on your consent, you have the right to withdraw your consent at any time;
  • You have the right to submit a complaint to the Dutch Data Protection Authority if you feel that we have not complied with the law or have not handled your complaint or request to your satisfaction.

This Privacy Statement does not apply to third-party websites referred to on our websites.

 

WVDB’s websites include links to third-party websites. If you go to another website using one of those links, please be aware that WVDB's Privacy Statement does not extend to the other website. WVDB is not responsible for either the content of third-party websites or the activities of third parties and others. Please read the privacy statements on those websites before providing any personal or other information.

Our Privacy Statement is subject to change. Changes may be made if we undertake new data processing activities. We encourage you to check this Privacy Statement occasionally. An updated version of our Privacy Statement is always available at

https://www.wvdb.nl/nl/privacy-statement.

If you have any questions, requests or complaints, please contact us using the contact details below.

 

Contact details

WVDB
Attn. data protection officer
Postbus 120
5580 AC Waalre

 

fg@wvdb.nl
+31 (0)40 - 221 58 05