Privacy policy
This Privacy and Cookie Policy explains how Unsworth & Associates B.V. and Unsworth & Associates S.à r.l. (collectively “U&A”) collect, use and disclose your personal data, and your rights under the EU General Data Protection Regulation 2016/679 (the “GDPR”).
Each U&A entity acts as a data controller for the personal data it processes.
What Data Do We Collect?
U&A may collect and process the following categories of personal data:
- Identity & contact data: name, home or business address, email address, telephone number.
- Biographical identifiers: date of birth, tax identification number, passport or national identity card details, BSN, country of domicile, nationality.
- Financial information: income, sources of wealth, bank account details.
- Client onboarding data: business rationale behind procuring our services, employment, education, family, personal circumstances, and interests.
- Compliance data: information regarding your (criminal) background, whether you are a politically exposed person (PEP), or present a money laundering risk.
How Do We Collect Your Data?
We collect data from multiple sources:
- Directly from you when you meet us, complete forms, or communicate via phone, email, or website forms.
- From your company, agents, advisers, intermediaries, or custodians.
- From other U&A group companies.
- From publicly available sources or third parties when conducting background checks.
- Via service providers supporting our website and digital tools (e.g., WordPress, Elementor, Google Ads).
Why Do We Process Your Data?
We process your personal data for specific purposes, with a lawful basis under GDPR:
- Purpose of Processing | Legal Basis
- Preparing proposals and providing services under the Management and Domiciliation Agreement or other Service Agreements | Contract performance (Art. 6(1)(b))
- Client onboarding, compliance, and re-acceptance checks | Legal obligation (AML legislation) (Art. 6(1)(c))
- Conducting background checks (PEP/AML, criminal records where required by law) | Legal obligation (Art. 6(1)(c)) + Art. 10 GDPR
- Internal administration, group-level management | Legitimate interests (Art. 6(1)(f))
- Responding to feedback or complaints | Legitimate interests (Art. 6(1)(f))
- Website analytics and advertising cookies | Consent (Art. 6(1)(a))
Data Sharing
We may share your personal data with:
- Advisers, auditors, and professional consultants.
- Background check providers.
- Regulators or law enforcement when legally required.
- Group companies where necessary for administration.
- IT and cloud service providers (acting as processors).
International transfers: Some providers (e.g., Google, WordPress) may process data outside the EEA. Where this occurs, U&A ensures appropriate safeguards are in place, such as EU Standard Contractual Clauses.
Data Storage and Security
Your data is stored on Microsoft SharePoint with MFA protection. Data is hosted on servers in Amsterdam, the Netherlands, managed by KPN Internet Services B.V., which holds ISO 27001:2013, ISO 20000, ISO 9001, NEN 7510, and ISAE 3402 certifications.
Data Retention
- Personal data collected under AML legislation will be retained for a minimum of seven years after the end of our client relationship.
- For more information regarding specific retention periods, contact us at management@amsterdamoffice.com
Your Data Protection Rights
Under GDPR, you have the right to:
- Access your data (free of charge, unless requests are excessive).
- Rectify inaccurate or incomplete data.
- Erase data in certain circumstances.
- Restrict processing in certain circumstances.
- Object to processing based on legitimate interests.
- Data portability.
We will respond to all requests within one month.
To exercise your rights:
management@amsterdamoffice.com
+31 (0) 20 622 3243
Unsworth & Associates B.V., Herengracht 540, 1017 CG, Amsterdam, The Netherlands
Cookies
Cookies are small files placed on your device to improve your browsing experience.
We use:
- Functional cookies (necessary for the website to operate, deleted after the session).
- Analytical cookies (to measure site usage).
- Tracking cookies (for advertising and remarketing).
Consent: On your first visit, you will see a cookie banner. Non-essential cookies (analytical and tracking) will only be placed if you give active consent. You can withdraw consent anytime via browser settings.
Changes to This Policy
Last updated: 13 August 2024. Updates will be published on this page.
Complaints
If you are not satisfied with our handling of your data, you can file a complaint with the Dutch Data Protection Authority:
+31 (0)70 888 8500
Autoriteit Persoonsgegevens, Postbus 93374, 2509 AJ DEN HAAG, The Netherlands
