PRIVACY STATEMENT
AZAROVA CONSULTING

This is the privacy statement of Azarova Consulting, with offices at Cornelis de Wittlaan 39 A, 2582 AB, The Hague, The Netherlands, registered at the Dutch Chamber of Commerce under number 68010141 (“Azarova Consulting”). This privacy statement applies to the processing of personal data of our clients, potential clients and other persons who visit our website https://www.azarova-partners.com (the “Website”) or have contact with us.

In this privacy statement you can find information about how we handle personal data. You can contact us via telephone number + 31 (0) 6 45590665 or e-mail address info@azarovaconsulting.com if you have any questions after reading this privacy statement about the way we handle personal data, or if you want to use your rights under the General Data Protection Regulation (“AVG”) or other laws and regulations regarding personal data, or if you want to submit a complaint about the use of your personal data. If you are not satisfied with the handling of your complaint or if you prefer not to submit your complaint to us, you can also submit it to the Dutch Data Protection Authority, via the Website www.autoriteitpersoonsgegevens.nl.

Azarova Consulting is responsible for the processing of your personal data and will exercise the greatest possible care.

Which personal data do we process?

Files
If you give us an assignment, we will process personal data that you and any other party involved may provide to us. These are in any case:
– your contact details such as your name, address, e-mail address and telephone number;
– a copy of your passport or proof of identity

– personal data relevant to the file. Which personal data these are differs per file. Examples include: information about financial assets, bank accounts, taxes, annual accounts, and all information necessary for the performance of the assignment by Azarova

Contact
If you contact us, by email, social media or by telephone, we process the data that you provide to us. This concerns the contact details that you provide to us (name, e-mail address, telephone number) and the reason why you are contacting us (for example because you have a question).

Analysis of Website visitors
Finally, we process analytical data about (the computer of) visitors to our Website, via cookies that are placed when you visit the Website. Through these cookies (part of) the visitor’s IP address is stored, with the last octet of the IP address being masked.

For what purposes and on what basis do we process personal data?

Files
We use the personal data that you provide in the context of your assignment to us to process your file. The basis for this is the performance of the agreement that you have entered into with us. We also use your data to invoice our activities and to refund any overpaid advances. This processing is also necessary to perform the agreement you conclude with us. We keep a copy of the passport or ID of new clients because we are required by the Dutch Money Laundering and Terrorist Financing (Prevention) Act (“Wwft”) to identify our clients and to record evidence thereof. We make the BSN number illegible because there is no legal basis for the processing thereof. We process personal data of persons other than our clients if this is necessary for the representation of the legitimate interests of our clients.

Contact
We use the contact details you provide to us by email or telephone to contact you if necessary, for example to answer a question. We process this personal data because this is necessary for the representation of our legitimate interest, namely to be able to carry out our work and to obtain new assignments.

Invitations
We may also use your e-mail address to send you invitations to any events we organize and holiday messages. If you have given us an order, there is a so-called “existing customer relationship” and we will send you these mailings on the basis of our legitimate interest. If you have not previously used our services but have come into contact with us in another way (such as by sending an e-mail with a question), we will only send you these mailings if you have given your permission for this.

Analysis of Website visitors
The data that we collect about the visitors to the Website is only used to keep track of statistics about the visit to the Website (for example, to see which pages are viewed the most). The data is kept anonymous. The option “share data” is turned off. We do not use other Google services in combination with Google Analytics.

How long do we keep your personal data?

File
We keep our files, and the personal data contained therein, for three months after the file has been closed.

Administration
We keep our administration, including the invoices and other documents on which the personal data of the parties are stated, for a period of seven years after the end of the financial year in order to comply with the fiscal retention obligation.

Other contact details
We keep other contact details for one year after the last contact, unless you previously submit a request to us to delete them.

Analysis of Website visitors
The data about Website visitors are stored for two years after the visit to the Website, these are the standard settings of Google Analytics.

Whom do we share your data with?

Your data is stored in a digital file and billing system and may appear in emails that we send or receive. This means that the data is stored (and therefore processed) by our ICT providers. We make use of Simplicate and Microsoft Cloud for exchanging data and data

Storage. We use Exact, Snel Start and Nextens for accounting and tax filings. We have concluded a processor agreement with the aforementioned parties in which at least the same level of security and confidentiality is regulated as you may expect from us.

We can also provide your information to third parties if this is necessary for the execution of the assignment you have given. For example, we submit your financial information to the Dutch Tax Authorities in the execution of the assignment.

The data collected through Google Analytics is processed by Google. We have concluded a processor agreement with Google. We will not provide your information to third parties, unless we are obliged by applicable laws and regulations to provide certain information, for example to the police in the context of a criminal investigation.

How are your data secured?

We have taken appropriate technical and organizational security measures to protect your personal data against loss, misuse and unauthorized access by third parties. For example, we use strict access authorization, both offline and online, our servers are regularly backed up and we work with secure connections.

What are your rights?

You have the following rights:
a. The right to inspect your personal data and receive a copy thereof.
b. The right to rectification of your personal data if it is incorrect or incomplete.
c. The right to object to the processing and / or – in certain cases – the right to limit the processing of your personal data.
d. In certain cases: the right to have your personal data erased (‘right to be forgotten’).
e. The right to obtain your personal data in a structured, commonly used and machine-readable form and to transfer that data to another person. For more information about these rights and when you can exercise them: see Articles 15 to 20 of the General Data Protection Regulation. You can exercise your rights by contacting us at the email address or phone number listed at the beginning of the privacy statement.

Changes

Sometimes something can change in the personal data we process or the applicable regulations. In that case, we can adjust this privacy statement. In case of major changes, we will post a notification on the Website or inform you of the change by email.

The Hague, May 2022