HBN Law & Tax (“HBN’’) acts as data controller under the General Data Protection Regulation (“GDPR”) which means that we have certain legal duties and responsibilities for our processing activities.
2. For what purposes does HBN process your personal data?
HBN processes the personal data listed below exclusively for the purposes stated below:
- To provide legal services, including the implementation of an agreement and conducting (legal) proceedings;
- To process and to respond to requests, enquiries or complaints received from you;
- To onboard and execute our services and supporting processes and systems required;
- To manage and administer our relationship with you;
- To comply with regulatory and policy requirements;
- To provide services requested by you;
- To identify services you may be interested in;
- To communicate with you about our services;
- To collect invoices;
- To provide and improve our website by generating statistics regarding the use of the website;
- To monitor and analyze our business processes and systems;
- To handle your job application or subscription to any of our recruitment services or events;
- To establish, exercise or defend a legal claim and proceeding against HBN and its staff;
- Business development activities.
3. What personal data does HBN process about you?
HBN processes the following personal data for the requested services or the personal data provided on the (own) initiative of the person concerned:
- Basic information, such as your date of birth, nationality, place of birth and gender, name, job title, address, Chamber of Commerce number, VAT number;
- Contact details, such as your e-mail address, telephone and fax number;
- Data necessary for processing invoices, such as your bank account number;
- Metrics of your visit on our website, such as used device-type, IP-address and user-agent;
- Data relating to your attendance of events and interests;
- Personal data that we need for compliance purposes;
- Personal data provided to HBN in the course of rendering services which may include special categories of data;
- Any other personal data relating to you that you provide to us.
The aforementioned personal data is processed by HBN because it was provided by you as the person concerned on your own initiative, it was obtained in connection with the provision of services, it was made known to HBN by third parties, including counterparties, or became known through public sources.
4. On what basis does HBN use your personal data?
HBN processes the above-mentioned personal data exclusively on the basis of the following grounds as referred to in Article 6 of the GDPR:
- To conclude and perform a contract;
- To comply with regulatory and policy requirements;
- For a legitimate interest (e.g. managing and administering the relationship with clients and suppliers);
- With your consent.
5. When can HBN share your personal data with third parties?
First of all HBN may, in connection with the provision of our services, need to share personal data between our offices in Curacao, Aruba, Bonaire, Sint Maarten and the Netherlands for the purposes specified above.
HBN will only share your personal data with third parties insofar necessary for the services it provides taking into account the aforementioned purposes. This includes allowing our suppliers and sub-suppliers access to your personal data when they perform services on our behalf (mainly to maintain and support our ICT systems) and regulatory authorities, courts, tribunals, government agencies and law enforcement agencies for the purposes specified above. Any transfer of personal data outside the EU/EEA is made in line with applicable data protection laws. Our international transfers of personal data outside the EU/EEA are based on the EU Commission’s standard contractual clauses.
A processing agreement is concluded with the third party that processes your personal data on behalf of and on behalf of HBN, whereby that third party is also obliged to comply with the GDPR. Third parties engaged by HBN, who offer services as a controller, are responsible for compliance with the GDPR for the (further) processing of your personal data. This includes an accountant, notary, other third party engaged for the purpose of a second opinion or expert report.
6. How does HBN protect your personal data?
HBN attaches great value to the security and protection of your personal data and therefore has taken appropriate technical and organizational measures to protect personal data against loss or against any form of unlawful processing.
In the event that HBN uses services from third parties, such as an IT supplier, HBN will include adequate security measures in the context of the protection of personal data in a processing agreement.
7. How long does HBN keep your personal data?
8. What rights do you have regarding your personal data?
The GDPR and other applicable laws foresee in certain rights for data subjects under the conditions set out therein. You, as a data subject, specifically have the following rights:
- Right to access your personal data;
- Right to rectification or correction of your personal data;
- Right to erasure of your personal data;
- Right to object or to request restriction of processing of your personal data;
- Right to data portability;
- Right to object to profiling;
- Right to lodge a complaint with a supervisory authority;
- Right to withdraw your consent for the future to the extent that the processing of your personal data takes place on the basis of your consent.
You can send a request for inspection, correction, limitation, objection, transferability of data, deletion of your personal data or withdrawal of previously given permission via the contact details below. You will receive a further message from HBN within four weeks of receiving your request.
Circumstances may arise where HBN cannot or not fully implement your request as a data subject. This includes the duty of confidentiality of lawyers and legal retention periods.
HBN keeps track of usage data of the website (s) for statistical purposes. The personal data collected via this route are in principle anonymous and are not sold to third parties.
In order to increase the ease of use of our website, so-called “cookies” are used. A cookie is a small text file that is placed during your visit on the website of HBN on, for example, your computer, tablet or smartphone. You can refuse the use of these cookies at any time, although this may limit the functionality and ease of use of the website.
10. Adjustment policy
11. Contact information