Effective Date: from 25 May 2018
This Privacy Notice explains how Unsworth & Associates B.V., Unsworth & Associates S.à r.l. and U&A Liquidators N.V. (collectively “U&A”) collect, use and disclose your personal data, and your rights in relation to the personal data it holds.
This Privacy Notice applies to the processing activities of U&A, who are the (individual) data controllers of your personal data and who are subject to the EU General Data Protection Regulation 2016/679 (the “GDPR”).
What data do we collect?
U&A collects the following data:
- Your name and contact information such as your home or business address, email address and telephone number;
- Biographical information which may confirm your identity including your date of birth, tax identification number and your passport number or national identity card details, your BSN, country of domicile and/or your nationality;
- Information relating to your financial situation such as income, sources of wealth, as well as your bank account details;
- An understanding of the business rationale behind your decision to procure our services;
- Information about your employment, education, family, your (criminal) background or personal circumstances, and interests;
- Information to assess whether you may represent a politically exposed person or money laundering risk.
How do we collect your data?
You directly provide U&A with most of the data we collect. We collect data and process data in several ways, for example:
- From the information you provide to us when you meet us;
- From information about you provided to us by your company or an intermediary;
- When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may store any such communication;
- When you complete (or we complete on your behalf) client on-boarding or application or other forms;
- From other companies in the Unsworth Group;
- From your agents, advisers, intermediaries, and custodians of your assets;
- From publicly available sources or from third parties, most commonly where we need to conduct background checks about you;
How will we use your data?
U&A collects your data so that we can perform effective mind and management of target companies in the Netherlands. We process your personal data because it is necessary for the performance of a contract to which you are a party to or in order to take steps upon your request prior to entering into a contract.
In this respect, we use your personal data for the following purposes:
- To prepare a proposal for you regarding the services we offer;
- To assess whether we can onboard you as client or re-accept you as a client in the event of changes within the group;
- To provide you with the services as set out in the Management and Domiciliation Agreement or other Service Agreement that we have in place with you;
- To deal with any complaints or feedback you may have;
- For any other purpose for which you provide us with your personal data.
In this respect, we may share your personal data with, or transfer it to, the following (subject to your approval, unless we are required by law to disclose such data):
- Our advisers where it is necessary for us to obtain their advice or assistance;
- Our auditors where it is necessary as part of their auditing functions;
- Third parties who assist us in conducting background checks;
- Relevant regulators or law enforcement agencies where we are required to do so.
- Our data storage providers.
How do we store your data?
U&A securely stores your data on servers physically located in Amsterdam, the Netherlands, accredited with full ISO 27001:2013 certification. The servers are hosted by KPN Internet Services B.V., which enjoy ISO 27001:2013, 20000 and 9001:2008 certifications, as well as NEN 7510 and ISAE 3402.
How long will we retain your data?
Where we have collected your personal data as required by anti-money laundering legislation, including for identification, screening and reporting, we will retain that personal data for seven years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings.
Otherwise, we will in most cases retain your personal data for a period of seven years after the termination of our contractual or other relationship with you in case any claims arise out of the provision of our services to you.
What are your data protection rights?
U&A would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
- The right to access – You have the right to request U&A for copies of your personal data. We may charge you a small fee for this service.
- The right to rectification – You have the right to request that U&A correct any information you believe is inaccurate. You also have the right to request U&A to complete information you believe is incomplete.
- The right to erasure – You have the right to request that U&A erase your personal data, under certain conditions.
- The right to restrict processing – You have the right to request that U&A restrict the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to U&A’s processing of your personal data, under certain conditions.
- The right to data portability – You have the right to request that U&A transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: firstname.lastname@example.org;
Call us at: +31 (0)20 622 3243
Or write to us: Herengracht 540, 1017 CG, Amsterdam, The Netherlands
How to contact us
If you have any enquiries, you can reach us at the email address email@example.com or by phone: +31 (0)20 622 3243.
How to contact the appropriate authority
You can learn more about your rights at https://autoriteitpersoonsgegevens.nl/en If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact us.
If you are not satisfied with how we are processing your personal data or if you feel that U&A has not addressed your concern in a satisfactory manner, you can file a complaint with the Dutch Data Protection Authority.
Telephone number: +31 (0)70 888 8500
Fax: +31 (0)70 888 8501
Address: Autoriteit Persoonsgegevens, Postbus 93374, 2509 AJ DEN HAAG