Privacy and cookie statement

1. Introduction

In this Privacy and Cookie Statement 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 Statement applies to all personal data processed by or on behalf of Pels Rijcken when you use our services, visit 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 "Websites") or otherwise communicate with us.

We use cookies and similar technologies (hereinafter: collectively referred to as "cookies") in providing our Websites. We also inform you in this Privacy and Cookie Statement about what cookies are, how we use cookies on our Websites, and how you can manage these cookies. For more information, please see: Section 8.

2. Processing by Pels Rijcken

Pels Rijcken is a processor with respect to your personal data within the meaning of the General Data Protection Regulation (hereinafter: "AVG"). This means that our firm has certain statutory duties and responsibilities for processing activities.
 

This ‘Privacy and Cookie Statement’ addresses your rights as a data subject with respect to the processing of your personal data.

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 Statement is relevant.
• If you provide goods or services to Pels Rijcken, please refer to Section 4 of this Privacy Statement.
• If you are a visitor to Pels Rijcken, paragraph 5 of this Privacy Statement is relevant.
• If you have signed up to receive certain mailings from Pels Rijcken, or are interested in information, please refer to Section 6 of this Privacy Statement.
• If you have shared your contact information with Pels Rijcken, please refer to Section 7 of this Privacy Statement.
• If you are a visitor to our website, please refer to Section 8 of this Privacy Statement.
• If you wish to apply for a job or have applied for a job at Pels Rijcken, please refer to section 9 of this Privacy Statement.

All of the above sections of this ‘Privacy and Cookie Statement’ describe:

• the individuals whose data are being processed,
• The type/category of personal data being processed,
• The manner in which the personal data are processed, and
• The persons/parties to whom the personal data may be disclosed.

3. If you are a client of Pels Rijcken

3.1 How do we collect your personal data, what personal data do we collect and why?

Pursuant to applicable legislation, all legal and financial service providers, including Pels Rijcken, must have information and/or documents relating to the possibility of establishing the identity of their clients. Within the scope of these services we collect personal data of, (among others) clients, contact persons of clients, witnesses, experts, contact persons of counterparties, lawyers and advisors of counterparties and persons whose personal data are part of a file.

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 pursuant to the applicable ‘Dutch Anti-Money Laundering and Anti-Terrorist Financing Actlegislation’ (hereinafter: Wwft). For example, we are obliged to check the status of identity documents and share information with the relevant authorities in the event of details.

Finally, we may process data relating to (contact persons of) our customers as part of our customer relationship.

Pels Rijcken processes this personal data to perform the services we provide to clients. This means that if the client is a natural person, we base our processing on the necessity for the performance of the agreement entered into with the data subject and if the client is a legal entity on our legitimate interests to perform the agreement entered into with the client (who is not the data subject himself).

3.2 How long do we keep your personal information?

Your personal data for the purposes specified above in the context of the client relationship or the relevant file/case will be kept for up to 20 years.

3.3 With whom do we share your personal data?

To the extent relevant, we share your personal data with the Unusual Transactions Disclosure Office, debt collection agencies, relevant (tax) authorities within the EU and third parties, to the extent required for the purposes set out above or to the extent these third parties assist us in doing so. The recipients of your personal data are located in countries within the European Economic Area, under the protection of the AVG.

4. If you supply goods or services to Pels Rijcken

4.1 How do we collect your personal data, what personal data do we collect and why?

When you or your employer provides goods or services to Pels Rijcken, we process certain data we have obtained from you. This is information such as your name, e-mail address and position. We use this information to process or handle invoices, to have an audit performed by an accountant, or to comply with our legal obligations.

When personal data are processed for the execution of the agreement, the supplier, if processor, is obliged to accept the processor agreement proposed by Pels Rijcken.

We process this data for the execution of the agreement. The basis for booking invoices is the legitimate interest to keep financial records for Pels Rijcken. We may also process your personal data because we are required to do so by law.

4.2 How long do we keep your personal information?

Pels Rijcken keeps the data no longer than necessary for the execution of the agreement.

4.3 With whom do we share your personal data?

We share your personal data with our accountant only when we are legally required to do so with third parties such as the tax authorities or when we have obtained explicit consent from you.

5. If you are a visitor to Pels Rijcken

5.1 How do we collect your personal data, what personal data do we collect and why?

When you visit the Pels Rijcken office, you must identify yourself. The desk clerk will check your identity on the basis of your passport or identity card (ID). When your appointment has been verified, you will receive a temporary access pass and your name and purpose of visit, as well as time of entry and exit will be registered in the system used for that purpose.

There are cameras in the office. This means that if you visit Pels Rijcken, you may be seen on our camera images. 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 this case, security personnel will allow a limited number of designated individuals access to the camera footage pursuant to security and camera policies. 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 camera images to establish, exercise or defend our (legal) position in case of (legal) proceedings. For the use of CCTV, we invoke our legitimate interests to protect our office from unauthorized access, in particular in view of the confidential information kept in our office.

5.2 How long do we keep your personal information?

If you visit the Pels Rijcken office, your name and the purpose of the visit, as well as time of entry and exit, will be stored in the system for 48 hours. Camera images will be stored for 28 days. However, if the camera images show irregularities, the camera images may be kept longer for investigation purposes. Camera images are kept in accordance with the time limits set forth in the camera policy and then destroyed.

5.3 With whom do we share this personal data?

Only the professional security third party has access to the camera images. In exceptional cases, for example in the case of criminal offenses evidenced by the camera images, we will share relevant camera images with police, justice or intelligence and investigative agencies. Furthermore, if we are (legally) obliged to do so, we will provide the camera images to competent authorities at their request and we may use the camera images as evidence in legal proceedings and thus provide the camera images to competent courts and counterparties.

6. If you have registered to receive newsletters from Pels Rijcken, or are interested in general information from Pels Rijcken

Pels Rijcken strives to meet the needs of our clients at the highest level of quality. We like to share our knowledge, keep interested parties informed about webinars and theme meetings, and send customized newsletters for each practice area. In order to send you information and invite you to events on matters of your specific interest, after your consent, we process your personal data in our CRM system (Interaction).

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 the corporate website of the organization you work for; and
• through cookies (which are placed when you sign up for our newsletters or visit the website). See below for more information about the cookies we use in this regard.

Pels Rijcken processes your personal data related to newsletters and mailings based on your consent.

We want to inform you about legal developments that are relevant to you. To do so, we use the information we receive from you to better understand your preferences and needs and tailor our digital messages and propositions accordingly.

*Only to the extent that you provide this data in the context of a specific event of Pels Rijcken gave up.

For the website www.cassatieblog.nl, we process the following data:

6.2 How long do we keep your personal information?

We retain your personal information as stated above until such time as you have notified us that you no longer wish to receive our mailings, Pels Rijcken ceases sending the newsletters in question, or it appears that your e-mail address is no longer in use.

6.3 With whom do we share your personal information?

Pels Rijcken does not share your personal data with third parties.

7. If you have shared your contact information with Pels Rijcken

7.1 How do we collect your personal data, what personal data do we collect and why?

If you have given your business card to (an employee or partner of) Pels Rijcken or otherwise provided us with your contact information, we process your personal data, such as your name, contact information, company, position and your contact person at Pels Rijcken. We use your personal data to contact you and, for example, to ask you if you wish to subscribe to our information or, if you have provided us with your contact data for a specific purpose such as sending you information about our firm or a specific case, to send you this information.

We process your personal data based on your consent (by actively providing your contact information to us for a specific purpose).

7.2 How long do we keep your personal information?

We will retain your data until you request deletion of your data. 

7.3 With whom do we share your personal data?

We do not further share your personal data with third parties until explicit consent is obtained.

8. If you are a visitor to our website

8.1 How do we collect your personal data, what personal data do we collect and why?

Your personal data may be used for the improvement of our website, marketing purposes and for social media sharing. We collect your data through 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 ads, to provide social media features, 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 specify in the settings whether you want to allow these cookies. You only need to indicate this once (until you clear your temporary files). You can change these settings at any time by clicking on the paperclip 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. We require your consent for all other types of cookies. Some cookies are set by third-party services displayed on our pages. The data collected cannot be traced back to an individual and does not contain any personal data. We anonymize all IP addresses. There are 3 types of cookies:

1. Necessary cookies

These are cookies necessary for the proper functioning of the website, by 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. Preferred cookies

Preference cookies allow a website to remember information that affects the behavior and design of the website, such as your preferred language or region of residence.

3. Statistical cookies

Statistical cookies help website owners understand how visitors use their website by anonymously collecting and reporting data.

4. Marketing Cookies

Marketing cookies are used to track visitors as they visit different websites. Their purpose is to display ads that are tailored and relevant to the individual user. These ads thus become more valuable to publishers and third-party advertisers.

For other information, please refer to the Cookiebot on the website.

9. If you want to apply for a job or have applied for a job at Pels Rijcken

In the context of a job application at Pels Rijcken or in the context of potential candidates for future vacancies, we process certain personal data.

9.1 How do we collect your personal data, what 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 job application procedure at Pels Rijcken;
• you have entered your personal data on a contact or web form;
• you otherwise provide your contact information during introductory meetings, events, conventions, etc;
• you provide your personal and contact information through an outside recruitment agency;
• public sources such as social media or, for example, the website of the organization where you work, in addition to the data you have consented to, 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 legitimate interest. The schedule below describes the personal data Pels Rijcken processes and for what purpose.

9.2 How long do we keep your personal information?

Pels Rijcken preserves:

• Your personal data as a result of an application for a maximum of 4 weeks after the application process has been completed, when you withdraw from the application process or when you are not included further in the selection for the position. After this period, the documentation you provide, such as resumes and cover letters and any assessments, will be irreversibly deleted from Pels Rijcken's systems.

• Your personal data following a recruitment event if you have given your consent, for up to one year after the recruitment event, for the purposes of other recruitment events and potential vacancies for which you may be suitable.

Your personal data will be deleted when revealed:

• That your e-mail address is no longer in use (for example, when error messages are received); or
  
• you withdraw consent to the processing of personal data in response to 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 further 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 data will only be shared to the extent necessary for organizing that activity.

10. Data protection & security

Pels Rijcken has one ambition: to perform at the highest level every day. Pels Rijcken always puts the client's interests first. It is essential to safeguard the confidentiality, integrity and availability of our client information at all times by managing the risks to which it is exposed in accordance with applicable laws and regulations and internal standards. The information security policy of Pels Rijcken has an ISAE3000II certification and is audited annually.

11. Changes to this privacy statement

Pels Rijcken reserves the right to change this privacy statement at any time and for any reason and therefore advises you to check this section of the website regularly.

12. Rights of data subjects

You may ask us for information about and access to your personal data and you may object to the processing of your personal data by us. Furthermore, under certain circumstances, you have the right to ask us to rectify or delete your personal data, to restrict the processing of your personal data by us, and to receive your personal data in a structured, commonly used and machine-readable format and to transfer your personal data to another organization (or have it transferred).

If you have any questions, comments or complaints regarding this Privacy Statement or our processing of your personal data, please feel free to contact your regular contact person within our office or at privacy@pelsrijcken.nl . You may also file a complaint with the Dutch Data Protection Authority (AP) if you suspect that the organization is not complying with privacy laws.

This privacy statement was last updated May 2025.