1. Introduction
In this Privacy and Cookie Notice, you can find information about the processing of personal data by Pels Rijcken Droogleever Fortuijn N.V. (hereinafter: “Pels Rijcken” or “we”). This Privacy and Cookie Notice applies to all personal data processed by or on behalf of Pels Rijcken when you use our services, attend our events, visit our websites (www.pelsrijcken.nl, www.werkenbijpelsrijcken.nl, www.cassatieblog.nl, www.pgwoo.nl and www.pgawb.nl, hereinafter collectively referred to as the “Websites”) or otherwise communicate or are in contact with us.
When providing our Websites, we use cookies and similar technologies (hereinafter collectively referred to as “cookies”). In both the cookie banner and this Privacy and Cookie Notice, we explain which cookies we use, for what purposes we use them, and how you can manage your cookie preferences. For more information, see paragraph 8.
2. Processing by Pels Rijcken
Pels Rijcken is generally the controller with regard to your personal data within the meaning of the General Data Protection Regulation (hereinafter: “GDPR”). This means that Pels Rijcken determines the purposes and means of the processing of your personal data and is responsible for compliance with the GDPR.
What is relevant to you depends on your relationship with Pels Rijcken:
- If you are a client of Pels Rijcken, paragraph 3 of this Privacy Notice is relevant.
- If you supply goods or services to Pels Rijcken, please refer to paragraph 4 of this Privacy Notice.
- If you are a visitor to Pels Rijcken, paragraph 5 of this Privacy Notice is relevant.
- If you have signed up to receive certain mailings from Pels Rijcken or are interested in information, please refer to paragraph 6 of this Privacy Notice.
- If you have shared your contact details with Pels Rijcken, please refer to paragraph 7 of this Privacy Notice.
- If you are a visitor to our website, please refer to paragraph 8 of this Privacy Notice.
- If you wish to apply or have applied to Pels Rijcken, please refer to paragraph 9 of this Privacy Notice.
In the relevant paragraphs, we explain, among other things, which personal data we process, for what purposes and on what legal basis we process them, how long we retain them, and with which categories of recipients we may share them. Your rights regarding the processing of your personal data are explained in paragraph 12.
3. If you are a client of Pels Rijcken
3.1 How do we collect your personal data, which personal data do we collect and why?
3.1.1. Client identity verification
All legal and financial service providers, including Pels Rijcken, must have data and/or documents enabling them to verify the identity of their clients. Pels Rijcken collects specific information to comply with our legal obligation to verify our client’s identity and to report unusual transactions. We do this on the basis of applicable anti-money laundering legislation (Wwft), the Regulation on the Legal Profession (Verordening op de Advocatuur), and the performance of the agreement. For example, we are obliged to verify the status of identity documents and, in the event of particularities, share information with the relevant authorities.
In practice, this means that prior to our services we conduct a client due diligence. For this purpose, we ask you for a valid identity document, such as a passport, identity card, or driver’s license, so that we can verify the authenticity and status thereof. We also record your basic details, including your full name, date of birth, and address. When you engage us on behalf of an organization, we also map the legal structure and the ultimate beneficial owner(s) (UBO).
Finally, the law requires us to be alert to unusual transactions during our services. If there is a situation that is considered unusual under the legal guidelines, we are legally obliged to report this to the Financial Intelligence Unit (FIU-Netherlands).
3.1.2 Processing of personal data in the context of our services
In the context of our services, Pels Rijcken processes personal data of clients, contact persons, witnesses, experts, opposing parties and their lawyers or advisors, as well as other persons whose data form part of a file. The legal basis we use for this processing depends on our relationship with the data subject. Where the client is a natural person, we base the processing of personal data on the necessity for the performance of the agreement concluded with that data subject.
In all other cases, such as contact persons of clients that are legal entities, witnesses, opposing parties, and other third parties, we do not have a direct agreement with the data subject. We therefore base the processing of their personal data on our legitimate interest. This legitimate interest consists of being able to carry out our legal services efficiently, to properly safeguard the interests of our clients in ongoing engagements, and to maintain proper administration and business operations.
We may process the following personal data:
- Contact information: name, address, job title, titles, telephone and fax number, Chamber of Commerce (KvK) number, VAT number, bank account number, website, email address and other business and contact information;
- Communication: letters and email messages with contact persons;
- Engagement information: information about the legal services provided to our clients and information about the substance of the matter;
- Billing information: data for the purpose of calculating and recording fees and expenses, making payments and collecting receivables;
- Other: other data, including date of birth, nationality, place of birth and gender, copy of ID.
Finally, in the context of our client relationship, we may process data relating to (contact persons of) our clients.
3.2 Use of AI
Use of AI AI is used within our firm as a supportive tool for legal analyses, document formatting, and internal process optimization. AI never replaces the legal judgment of a lawyer. Every outcome produced with the help of AI is reviewed by an authorized lawyer for accuracy, relevance, and applicability.
We do not process clients’ personal data or confidential information in open, publicly accessible AI systems. Such data are only used in AI systems if the processing takes place within a closed and controlled system and consent has been obtained.
3.3 How long do we retain your personal data?
How long do we retain your personal data? Your personal data for the purposes described above in the context of the client relationship or the relevant file/matter are retained for up to 20 years.
3.4 With whom do we share your personal data?
With whom do we share your personal data? Where relevant, we share your personal data with the Reporting Point for Unusual Transactions, debt collection agencies, relevant (tax) authorities within the EU, and third parties, insofar as this is required for the purposes set out above or insofar as these third parties assist us in this regard. The recipients of your personal data are located in countries within the European Economic Area, under the protection of the GDPR.
4. If you supply goods or services to Pels Rijcken
4.1 How do we collect your personal data, which personal data do we collect and why?
When you or your employer supplies goods or services to Pels Rijcken, we process certain data we have obtained from you. These include data such as your name, email address and position. We use this information, among other things, to process or handle invoices, to have an audit performed by an accountant, or to comply with our legal obligations.
Where personal data are processed for the performance of the agreement and the supplier acts as a processor, Pels Rijcken will in principle present its processor agreement for execution.
We process these data for the performance of the agreement. The legal basis for recording invoices is our legitimate interest in maintaining a financial register for Pels Rijcken. We may also process your personal data because we are legally obliged to do so.
4.2 How long do we retain your personal data?
Pels Rijcken retains the data no longer than necessary for the performance of the agreement.
4.3 With whom do we share your personal data?
We share your personal data only with our accountant, with third parties such as the tax authorities when we are legally obliged to do so, or when we have obtained your express consent.
5. If you are a visitor to Pels Rijcken
5.1 How do we collect your personal data, which personal data do we collect and why?
If you visit Pels Rijcken’s offices, you must identify yourself. The reception staff will verify your identity on the basis of your passport or identity card. Once your appointment has been checked, you will receive a temporary access pass and your name and purpose of visit, as well as the time of entry and exit, will be recorded in the system used for that purpose.
Cameras are present inside the office. In addition, Pels Rijcken has an outdoor camera to monitor the entrance. This means that if you visit Pels Rijcken, you will appear on our CCTV footage. A specialized third party provides our security services in our office. The security personnel of this service provider monitor these camera images in real time and may consult the camera images on a non-real-time basis for 24 hours if we have reason to believe that certain irregularities have occurred. In that case, the security personnel will grant access to the camera images to a limited number of designated persons under the security and camera policy. We use CCTV (closed-circuit television) to ensure that only authorized persons enter our offices, to protect our (business) interests, property and employees, and to investigate and handle irregularities. Where relevant, we will also use the footage to establish, exercise or defend our (legal) position in the event of (judicial) proceedings. For the use of CCTV, we rely on our legitimate interests in protecting our office against access by unauthorized persons, in particular with regard to the confidential information stored in our office.
5.2 How long do we retain your personal data?
If you visit Pels Rijcken’s office, your name and the purpose of the visit, as well as the time of entry and exit, are retained in the system for 48 hours. CCTV footage is retained for 28 days. If the CCTV footage shows irregularities, the footage may be retained longer for investigation purposes. CCTV footage is retained in accordance with the periods set out in the camera policy and then destroyed. For information concerning the outdoor camera, please refer to the specific Privacy Statement on Camera Surveillance: Privacy Statement Cameratoezicht - Pels Rijcken.
5.3 With whom do we share this personal data?
Only the professional third-party security provider has access to the CCTV footage. In exceptional cases, for example, in the event of criminal offences apparent from the footage, we share relevant CCTV footage with the police, the public prosecutor, or intelligence and investigative services and bodies. Furthermore, if we are (legally) obliged to do so, we will provide the CCTV footage to competent authorities upon their request, and we may use the footage as evidence in legal proceedings and therefore provide the footage to competent courts and opposing parties.
6. If you have signed up to receive Pels Rijcken newsletters, or as an interested party in general information from Pels Rijcken
Pels Rijcken strives to meet our clients’ needs at the highest quality level. We are pleased to share our knowledge, keep interested parties informed of webinars and themed meetings, and send tailored newsletters by practice area. To send you information and invite you to events on topics of your specific interest, we process your personal data in our CRM system (Interaction) after your consent.
6.1 How do we collect your personal data and why?
We may collect information about you:
- Directly from you, such as the information you provided to us when registering for newsletters or webinars;
- From publicly available sources such as LinkedIn or your employer’s company website; and
- By means of cookies (which are placed when you sign up for our newsletters or visit the website). See paragraph 8.1 for more information about the cookies we use in this context.
Pels Rijcken processes your personal data in relation to newsletters and mailings based on your consent.
We want to inform you about legal developments that are relevant to you. To that end, we use the information to better understand your preferences and wishes and to tailor our digital messages and propositions accordingly.
Personal Data |
Purposes |
Name (including initials) |
Appropriate salutation |
Address (business and private) |
To contact you |
Position or profession |
For a correct salutation and to personalise messages |
Title(s) |
For appropriate salutation |
Email address |
To contact you |
Phone number, mobile number |
To contact you |
Gender |
For appropriate salutation |
Link to LinkedIn page |
To keep personal data up to date |
Interest areas (practice areas, themes, and/or sectors) only if provided by you |
To personalise and ensure relevant messaging |
(Previous) newsletters, whitepapers, event invitations sent to you |
To check accuracy and analyze communications sent |
Dietary Requirements* |
To customise event menus accordingly |
Opt-in |
To correctly record and observe opt-in forms for messaging preferences |
Opt-out |
To correctly record and observe opt-out forms, so that you do not receive unwanted messages (immediately deleted after processing) |
Click behavior by name |
To analyze readership and improve communications |
*Only insofar as you provided these data in connection with a specific Pels Rijcken event.
6.2 How long do we retain your personal data?
We retain your personal data as mentioned above until the moment you have informed us that you no longer wish to receive our mailings, Pels Rijcken stops sending the relevant newsletters, or it appears that your email address is no longer in use.
6.3 With whom do we share your personal data?
Pels Rijcken does not share your personal data with third parties.
7. If you have shared your contact details with Pels Rijcken
7.1 How do we collect your personal data, which personal data do we collect and why?
If you have shared your contact details with a member of staff or partner of Pels Rijcken, or otherwise provided them to us, we process your personal data, such as your name, contact details, company, position and your contact person at Pels Rijcken. We use your personal data to contact you and, for example, to ask whether you wish to subscribe to our information or, if you have provided your contact details to us for a specific purpose such as sending information about our firm or a specific matter, to send you that information.
We process your personal data on the basis of your consent (by actively providing your contact details to us for a specific purpose).
7.2 How long do we retain your personal data?
We retain your data until you request deletion of your data.
7.3 With whom do we share your personal data?
We do not share your personal data with third parties unless there is explicit consent to do so.
8. If you are a visitor to our website
8.1 How do we collect your personal data, which personal data do we collect, and why?
Your personal data may be used to improve our website, for marketing purposes and for social media sharing. We collect your data by means of Cookiebot.
8.1.1 Cookies
To optimize visits to pelsrijcken.nl, we keep anonymous visitor statistics. Cookies are used for this purpose. We use cookies to personalize content and advertisements, to provide functionalities for social media, and to analyze our website traffic. We also share information about your use of our site with our social media, advertising and analytics partners. These partners may combine this data with other information you have provided to them or that they have collected based on your use of their services. You can indicate in the settings whether you wish to allow these cookies. You only need to indicate this once (until you delete your temporary files). You can change these settings at any time by clicking on the paperclip icon at the bottom left of the website.
8.1.2 What are cookies?
Cookies are small text files that can be used by websites to make user experiences more efficient. By law, we may store cookies on your device if they are strictly necessary for the use of the site. For all other types of cookies, we need your consent. Some cookies are placed by third-party services that appear on our pages. The collected data cannot be traced back to a person and does not contain personal data. We anonymize all IP addresses. There are 4 types of cookies:
1. Necessary cookies
These are cookies that are necessary for the proper functioning of the website, enabling basic functions such as page navigation and access to secure areas of the website. Without these cookies, the website cannot function properly. These cookies are not shared with third parties.
2. Preference cookies
Preference cookies ensure that a website can remember information that influences the behavior and appearance of the website, such as your preferred language or the region where you live.
3. Statistical cookies
Statistical cookies help website owners understand how visitors use their website by collecting and reporting data anonymously.
4. Marketing cookies
Marketing cookies are used to track visitors across different websites. Their purpose is to display advertisements that are tailored to and relevant for the individual user. These advertisements thus become more valuable for publishers and external advertisers.
For further information, please refer to Cookiebot’s cookie banner on the websites.
9. If you wish to apply or have applied to Pels Rijcken
In the context of an application to Pels Rijcken or in relation to potential candidates for future vacancies, we process certain personal data.
9.1 How do we collect your data, which personal data do we collect and why?
Pels Rijcken obtains your personal data from:
- You provide your personal data to Pels Rijcken yourself for the purpose of a recruitment procedure at Pels Rijcken;
- you have entered your personal data in a contact or web form;
- you otherwise provide your contact details during introductory meetings, events, conferences, etc.;
- you provide your personal and contact details via an external recruitment agency;
- public sources such as social media or, for example, the website of the organization where you work, in addition to the data for which you have given consent, as indicated under ‘yourself’.
Pels Rijcken processes your personal data for filling vacant positions and for recruitment purposes. Pels Rijcken processes your personal data on the basis of your consent or on the basis of legitimate interest. The table below describes the personal data processed by Pels Rijcken and for what purpose.
Personal Data |
Purposes |
Name (including initials) |
Appropriate salutation |
Title(s) |
Appropriate salutation |
Email address |
To contact you |
Phone number, mobile number |
To contact you |
Gender |
Appropriate salutation |
Study |
To match qualifications |
Link to your LinkedIn page |
To keep personal data up to date |
CV |
Assessment of candidacy and/or application |
Cover letter |
Assessment of candidacy and/or application |
Grades |
Assessment of candidacy and/or application |
Assessment results |
Assessment of candidacy and/or application |
Assessment forms (internship, work-study or current job) |
Assessment of candidacy and/or application |
Thesis |
Assessment of candidacy and/or application |
Other documents provided by you |
Assessment of candidacy and/or application |
9.2 How long do we retain your personal data?
Pels Rijcken retains:
- Your personal data in connection with an application for a maximum of 4 weeks after the recruitment procedure has ended, if you withdraw from the recruitment process, or if you are no longer considered for the position. After this period, the documents you have provided, such as CVs and cover letters and any assessments, are irreversibly deleted from Pels Rijcken’s systems.
- Your personal data arising from a recruitment event, if you have given consent, for up to one year after the recruitment event, for the purpose of other recruitment events and potential vacancies for which you may be suitable.
Your personal data will be deleted when it appears that:
- your email address is no longer in use (for example, when bounce messages are received); or
- you withdraw your consent for processing personal data following a recruitment event.
9.3 With whom do we share your personal data?
We use external service providers for screening applicants. Where relevant, we share your personal data with these service providers in order to contact you.
Pels Rijcken does not otherwise share your personal data with third parties for commercial purposes. Pels Rijcken may organize an activity with another party. In that case, the relevant contact details will only be shared to the extent necessary for organizing that activity.
10. Data Protection and Security
It is essential that the confidentiality, integrity and availability of our client information are ensured at all times by managing the risks to which it is exposed in accordance with applicable laws and regulations and internal standards. Pels Rijcken’s information security policy holds an ISAE3000II certification and is audited annually.
11. Changes to this privacy notice
Pels Rijcken reserves the right to amend this privacy notice at any time and for any reason, and therefore advises you to check this section of the website regularly.
12.Data subject rights
Under the GDPR, you have the rights below that you can exercise in relation to our processing of your personal data. To exercise your rights, you can reach us via the contact details provided below.
Right to information
You have the right to be informed about the processing of your personal data. This Privacy Notice and the Cookie Notice provide this information. If you require further information, you can request it from Pels Rijcken.
Right of access
You have the right to access the personal data we collect and store about you. This access also includes information about the purposes for which the personal data are processed, how long and where they are stored, and who receives the personal data.
Right to rectification
We do our best to ensure that the personal data we process are accurate and complete. If you nevertheless believe that your personal data are incorrect or incomplete, you can request that your personal data be supplemented or amended.
Right to erasure
In certain situations, you have the right to have your personal data erased. This is the case, for example, if the data have been processed in violation of legal frameworks or if the personal data are no longer necessary for the purpose for which they were collected and stored.
Right to restriction of processing
You have the right to restrict the processing of your personal data. This means that we suspend the processing of your data for a certain period. Circumstances that may give rise to this include situations in which you doubt the accuracy of the data, or because you believe that the personal data are no longer necessary for the purpose for which they were collected and stored. This right does not prevent us from continuing to process your personal data. We will inform you when the restriction is lifted.
Right to data portability
In certain cases, you can request personal data that Pels Rijcken stores about you in a structured, commonly used, and machine-readable format. After receiving the personal data, you are free to transfer this information to third parties.
Right to object
You have the right to object to the processing of your personal data that is based on our legitimate interests. Unless we have a compelling, legitimate reason for the processing, we will no longer process your personal data when you file an objection.
Right to withdraw your consent
Where data processing is based on your consent, you have the right to withdraw the consent given at any time. After receiving your request, Pels Rijcken will immediately stop processing your personal data for which you had granted consent. However, the withdrawal of consent does not affect the lawfulness of the processing prior to that time. Please note that your rights are in some cases not absolute and that we may not be obliged to comply with your request. We will always assess on a case-by-case basis whether compliance is required and will inform you accordingly.
If you have any questions, comments or complaints regarding this Privacy Notice or the processing of your personal data by us, please feel free to contact your regular contact person within our firm or via privacy@pelsrijcken.nl. You can also lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, AP) if you suspect that the organization is not complying with privacy legislation.