PRIVACY POLICY

Robinia Family Office Services B.V. (“Robinia”) considers the protection of your privacy and the security of your personal data to be of great importance. We will only process your personal data in the capacity of controller in accordance with the provisions of the General Data Protection Regulation (hereinafter: “GDPR”). We would like to inform you about our privacy policy.
Robinia reserves the right to make changes to this privacy policy in accordance with applicable laws and regulations. Therefore, please check this web page from time to time to see if any changes have occurred.

This privacy policy covers the following topics:

  1. 1. To whom does this privacy policy apply?;
  2. 2. Categories of personal data and how they are collected;
  3. 3. Purpose of use of personal data;
  4. 4. Legal basis for processing personal data;
  5. 5. Are your personal data shared?;
  6. 6. Period of retention of personal data;
  7. 7. The protection of your personal data;
  8. 8. Your rights as a data subject;
  9. 9. Cookie Policy;
  10. 10. Contact details.
  11. 11. To whom does this privacy policy apply?
    This privacy policy applies to the following persons:
  • (potential) clients;
  • visitors to our website;
  • recipients of emails from Robinia; and
  • all other persons whose personal data Robinia processes.
  1. 2. Categories of personal data and how they are collected
    Robinia processes personal data. This is data about identified or identifiable natural persons and includes data that can be traced directly or indirectly to a person. This may be data that you have provided to us yourself, such as when you enter into an agreement with us, by visiting our website and filling in contact forms or if you apply for a job with us. It is also possible that Robinia receives your personal data from a third party, if data comes from public platforms such as the trade register of the Chamber of Commerce, the Land Registry or from other public sources.

This includes the following data: data necessary for the handling of your case by a Robinia employee;

  •  your first and last name, title, date of birth, and contact details such as your e-mail address, postal address and telephone number;
  •  your bank account number, VAT number and other information that you disclose to us in the context of the Agreement concluded with Robinia, or an internally assigned number such as a relationship number;
  •  data originating from your visit to our website;
  •  data entered on (online) contact forms, such as name and e-mail address and other data that you have entered that could be personal data;
  •  data obtained through the use of cookies about your surfing behaviour on our website;
  •  the Internet Protocol (IP) address of the equipment you use;
  •  e-mail address for sending newsletters and mailings;
  •  data that we have obtained through public platforms, such as the Chamber of Commerce and the Land Registry;
  •  the name and address details, the Chamber of Commerce number, e-mail address and telephone number included herein;
  •  data that you provide to us in the context of a job application:
  • your first and last name, date of birth, insert, title, gender, nationality, education, marital status and contact details such as your e-mail address, postal address and telephone number and all other personal data stated in your application;
  • all other personal data relating to you that you provide to us or that we can obtain in connection with (legal) proceedings or on the basis of the principles as stated below.
  1. 3. Purpose of use of personal data
    Robinia uses your personal data for the following purposes:
  • to carry out the assignment you have given Robinia, to declare the services provided and all other uses necessary to provide our services;
  • to comply with legal obligations, such as tax obligations and compliance with the Money Laundering and Terrorist Financing (Prevention) Act;
  • to maintain contact with you, so that you can, for example, be invited to certain events and to marketing communications addressed to you;
  • to be able to analyze and improve the use of the website;
  • to carry out research/make analyses.
  1. 4. Legal basis for processing personal data
    Robinia processes personal data on the basis of one of the following (legal) grounds:
  • on the basis of an agreement of assignment to provide services;
  • compliance with legal obligations as mentioned above;
  • in connection with a legitimate interest of Robinia to process personal data. Processing on the basis of this basis will meet the requirements of proportionality and subsidiarity and various security and organisational measures have been taken to protect your data;
  • you have given permission to process your personal data. You have the right to withdraw your consent at any time. This does not affect the use of your data before the moment of withdrawal of your consent.
  1. 5. Is your personal data shared?
    The persons associated with Robinia may receive your personal data. Personal data may also be shared with third parties that are important for our services, such as lawyers, (tax) advisors, regulatory authorities and government institutions. In addition, Robinia uses various ICT support companies that work on behalf of and on the instructions of Robinia. Such companies have (or will not) conclude (or will) processing agreements with Robinia.
    In principle, Robinia does not provide your personal data to other third parties. However, Robina may, only to the extent necessary for its services, pass on your personal data to parties in third countries, outside the European Economic Area (EEA), for example to foreign regulators. When Robinia proceeds to share your personal data with parties in a country outside the EEA, Robinia will check whether an adequate level of protection is ensured in that third country and ensure that such transfer is in accordance with applicable laws and regulations before informing you thereof. Only if we are legally obliged to do so, your personal data will be provided to regulators, other parties or persons or authorities.
    Transfer of your personal data to third parties only takes place for the purposes mentioned above in the privacy policy and/or solely on the basis of the (legal) bases already mentioned.

  2. 6. Period of retention of personal data
    Robinia does not store your personal data longer than is strictly necessary to achieve the purposes as mentioned in this privacy policy.

  3. 7. The protection of your personal data
    Robinia has taken the necessary technical and organizational measures for the protection of your personal data. These protections protect, among other things, against loss, destruction, damage and against the prevention of unauthorized or unlawful processing or disclosure of the data. For example, data connections and physical spaces are secured. The persons working at Robinia have also made statements in which they maintain confidentiality under penalty of a fine. If you have any questions about the security of your personal data, or if there are indications of abuse, please contact us, using the contact details listed under 10.

  4. 8. Your rights as a data subject
    As a data subject, you have the following rights;
  • the right of access. This means that you can request access to the personal data that we have collected from you;
  • the right to rectification of your data if it is incorrect;
  • the right to erasure of your data. Robinia may not be able to comply with this for legal and legal reasons;
  • the right to object to (future) processing of your data or to limit it, provided that there are no legal and legal bases that prevent this;
  • the right to withdraw certain consent to processing issued by you;
  • the right to data portability. You can receive the data you provide to Robinia in a structured, commonly used and machine-readable form. You can then transfer this data to another controller;
  • the right to file a complaint with the Dutch Data Protection Authority.

You can address your requests, questions or complaints to the contact details mentioned in number 10.

  1. 9. Cookie policy
    Robinia’s website uses the “Google Analytics” service offered by Google Inc. This service analyzes the use of the website by its visitors. For example, based on the number of visits per page, how long visitors stay on a page, the countries from which these visits come and the pages that are clicked through. We use this service to improve our website.

Google Analytics uses cookies to perform this analysis. Robinia has (or will enter into) a processor agreement with Google. Google does not use data for its own purposes.

  1. 10. Contact details
    Robinia would like to hear your questions or complaints about the privacy policy. This can be done by letter, e-mail or telephone.


By letter

Robinia Family Office Services B.V.
Welnastraat 404 A
1096 GJ AMSTERDAM

By e-mail
info@rfos.eu

By phone
T: +31 (0)6 53 57 74 14

You can also file a complaint with the Dutch Data Protection Authority in The Hague.