Your personal information

Holla may collect your personal data when you avail legal or fiscal services from us, visit our websites www.holla.nl or www.werkenbijholla.nl, contact us, provide us with a business card, file a complaint with us, attend our events, receive our newsletter, or apply to us. Additionally, we may obtain your personal data from other sources, such as in the context of a case we handle, from public websites, or from (commercial) registers. In all these cases, this privacy policy applies, and Holla is the data controller for your personal data.

In this privacy policy, we explain how we handle your personal data, including when we collect which personal data and how long we retain them. It is important that you are aware of this.

For any questions, comments, or complaints about this privacy policy or our use of your personal data, please contact us using the following contact details:

Holla N.V.
Stationsplein 101
5211 BM ’s-Hertogenbosch
Tel: +31 (0) 88 440 24 00
Email: privacy@holla.nl

Performing legal or fiscal services

When you avail legal or fiscal services from us, we may process your personal data to fulfill the agreement Holla has entered into with you (or your employer). Without this personal data, it is not possible for us to provide our services. We only process data necessary for preparing, executing, and completing the relevant matter, such as providing advice or conducting proceedings. In this context, we may also receive your personal data from a counterparty or other third parties.

Additionally, based on the Law on the Prevention of Money Laundering and Financing of Terrorism ('Wwft') and the Regulation on the Legal Profession ('VODA'), Holla is obligated to identify clients and conduct investigations to prevent money laundering and terrorism financing when performing its services. For this purpose, we must record and process certain personal data. In some cases, based on the law, we are required to scan your identity document. We use the RegLab system for this purpose. Furthermore, we want to inform you that we may use your personal data to verify data and comply with administrative requirements.

If you have filed a complaint during the provision of our services, we have a legitimate interest in handling your complaint in accordance with our customer regulations.

For these purposes, we may process the following personal data:

• First and last names;
• Date of birth;
• Place of birth;
• Gender (salutation);
• (Business) address details;
• (Business) phone number;
• (Business) email address;
• (Business) payment details;
• Company details and position;
• Data in the context of the identification and investigation obligation, including possibly a scan of the identity document;
• Information about a complaint and other data in the context of the complaint;
• Other data you provide to us in the context of our services.

By law, we are obliged to keep records for at least five years. We must keep fiscal and administrative data for seven years. For the rest, we retain your data for as long as necessary for our services or handling a complaint, unless we receive a request for deletion of your personal data earlier and we can comply with this request.

Management of our website(s) and handling contact requests

When you visit Holla's website(s), we process your personal data, among other things, by placing cookies and similar technologies. We place various cookies on our websites, including functional, analytical, and marketing cookies. In our cookie statement, we explain why we place these cookies and what data we collect with these cookies.
Additionally, we may collect your personal data via our contact form on the website or when you provide us with your business card or contact us in any other way. In these cases, we use your personal data to communicate with you and process your request. We process this personal data because we have a legitimate interest therein. The interest lies in being able to respond to your requests and ensure well-functioning websites. For certain cookies, we request your consent via the cookie banner.

For these purposes, we may process the following personal data:

• First and last name;
• (Business) phone number;
• (Business) email address
• Company details and position;
• Technical data and other data we collect via cookies, such as your IP address, your device, and the pages you view;
• Other data you provide to us, for example, in the contact form.

Holla retains the data collected in the context of the contact request for as long as necessary to fulfill your contact request. After this, your personal data will be deleted. For the retention periods of the cookie data, we refer to our cookie banner.

Newsletters, events, or other marketing activities

We like to keep our clients and other interested parties informed about the latest developments in the legal and fiscal fields. We can do this by sending newsletters, organizing events, using social media, and other marketing activities.
If we already have a client relationship, we may use your contact details to send marketing materials about our services. However, you can always object to this by emailing us; each email contains an unsubscribe button. If there is no client relationship but you are interested in our marketing materials, we will only send these messages with your consent. We obtain this through a subscription on our website(s).
Furthermore, you can register for one of our events. To register your participation, confirm your participation, and keep you informed about the event, we may collect personal data from you.

For these purposes, we may process the following personal data:

• First and last name;
• Gender (salutation);
• (Business) email address;
• (Business) phone number;
• Company details and position;
• Moment of registration and unsubscription;
• Preferences and interests.

Holla retains your personal data for these purposes until objection, unsubscription, or after the event. If there is no longer a client relationship, we will continue to send newsletters or other communications for up to one year after the last client contact.

Applications and recruitment activities

When you apply to us, we need your personal data to assess the application and to contact you regarding the application. Holla has a legitimate interest therein. When you are in the final stages of the application process, the personal data will be necessary for drafting and executing the employment contract. We may also collect your personal data if you sign up for one of our recruitment activities.

For these purposes, we may process the following personal data:

• First and last name;
• Place of residence;
• Phone number;
• Email address;
• Cover letter;
• CV and all data contained therein;
• Grade lists;
• Photo;
• Internship evaluations;
• Bachelor's and/or master's thesis;
• Other data you provide to us in the context of the application process or the recruitment activity.

Holla retains your personal data for up to four weeks after the end of the application process. With your consent, Holla can retain this personal data for up to one year. This allows us to contact you if we have an interesting vacancy later on.

To provide our services, we sometimes collaborate with other parties. Some parties (such as software suppliers) process your personal data on our behalf, as stipulated in a data processing agreement. We only give these parties access to personal data when necessary for their work and only based on our instructions. Your personal data is stored within the European Union.

Furthermore, Holla may share your personal data with:

• Affiliated companies, to the extent necessary for the purposes described in this privacy policy;
• Other recipients, to the extent necessary for the purposes described in this privacy policy, for example, to a bailiff or the judiciary in the context of the provision of our legal or fiscal services, or to third parties involved in the organization of an event;
• Any other recipient as required by law, a court order, or a (other) legal procedure, such as a merger, acquisition, or sale of assets, notification to a regulator, or in the event of bankruptcy.

These other recipients are also (independently) data controllers for the processing of your personal data. If we are joint data controllers, we will make agreements with these parties about this. If these agreements differ from what is stated in this privacy policy, we will inform you thereof.

We have implemented appropriate technical and organizational measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and unauthorized alteration of your personal data. If you have questions about these specific measures or suspect a breach of our security, please contact us immediately via privacy@holla.nl.

On our websites, you may also find links to other websites. Although these websites have been carefully selected, we cannot be held responsible for how these organizations handle your personal data. For this reason, we strongly recommend consulting the privacy policy of these websites as well.

Furthermore, our buildings are also secured with cameras, and we keep track of who our visitors are. In this context, we may also process personal data. However, we do not process this personal data longer than necessary and up to a maximum of 72 hours, unless there is an incident.

Under the law, you have certain rights regarding your personal data. We explain below what rights these are and how you can invoke them.

• Right of access and information. You have the right to request information about how we process your personal data and to receive copies of the personal data. However, there are certain exceptions, so you may not always receive all information about the personal data we process. 

• Right to rectification. You have the right to have your personal data changed to ensure that this data is (again) correct and up-to-date. You also have the right to request rectification of your personal data if third parties have provided this personal data to us and you believe it to be incorrect or incomplete. 
  
• Right to erasure. In general, you have the right to request that your personal data or part thereof be erased (for example, when the personal data are no longer necessary for our purposes or when the personal data have been unlawfully processed); however, we will not always be able to erase your personal data because processing may still be necessary. This may be because the personal data are still needed to comply with a legal obligation or for submitting, exercising, or substantiating a legal claim. For this reason, we will weigh your interest in erasing your personal data against our need to retain the personal data for other legitimate interests. Please note that if you request us to erase your personal data, you may no longer be able to use our services.
  
• Right to restriction of processing. Under certain circumstances, you can have the processing of your personal data by us restricted. This can be done, for example, if the accuracy of your personal data is disputed, the processing is unlawful, or personal data are no longer necessary for the purposes of processing. However, in certain circumstances, we may still use your personal data, for example, if your personal data are still necessary for legal claims or to protect the rights of another data subject.
  
• Notification of rectification, erasure, or restriction. Unless it is impossible or requires disproportionate effort, we will inform the recipients of your personal data about the rectification, erasure, or restriction of processing.
  
• Right to data portability. Under certain circumstances, you can request us to transfer your personal data, provided by you, to another data controller. You also have the right to receive your personal data, provided by you, in a structured, commonly used, and machine-readable format, to transmit this data to another data controller.
  
• Right to object. Under certain circumstances, you can object to the processing of your personal data by us or by third parties engaged by us, for example, in the case of direct marketing. We will consider various factors when assessing an objection to our processing, including: the reasonable expectations of our users; the benefits and risks to you, us, other users, or third parties; other available means to achieve the same purpose that may be less intrusive and require no disproportionate effort. Your objection will be honored, and we will cease processing your data, unless the processing is based on compelling legitimate grounds or the processing by us is still necessary for legal reasons.
  
• Right to withdraw consent. If we have asked for your consent for data processing, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
  
• Right to lodge a complaint. If you believe that the processing of your personal data is unlawful, you can always contact us via privacy@holla.nl. We will always try to find a solution together with you. If this is not possible, you have the right to lodge a complaint with the Dutch supervisory authority – the Dutch Data Protection Authority. 

You can submit your request(s) to exercise these rights to us via privacy@holla.nl. To protect your privacy and security, we will take reasonable steps to verify your identity before responding to your request(s). Only you or someone legally authorized to act on your behalf can submit a verifiable request regarding your personal data. For example, if you make a request, we will ask you to confirm your name, email address, or other information in our records to verify your identity. This is a security measure to ensure that personal data are not disclosed to someone who is not entitled to it. 

We will respond to your request as soon as possible, but no later than one month after receipt of your request. We will also assess whether, and if so to what extent, we can or must comply with your request according to the law. If a longer period of up to two months is necessary, we will inform you about this within one month after receipt of the request. Submitting and processing your request is free of charge, unless your request is clearly unfounded or excessive, especially due to its repetitive nature.

Holla reserves the right to make adjustments to this privacy policy. We therefore advise you to regularly view this webpage. If we make significant changes to this privacy policy, we will inform you in a reasonable manner, for example, by sending an email or by posting a notice of the changes on our website before the changes take effect.