This is the privacy policy of Partners Consultancy Group, located at Willemsparkweg 31, 1071GP, Amsterdam (hereinafter: “PCG”). This privacy policy applies to the processing of personal data of our clients, potential clients, and other individuals who visit our website or contact us. The policy applies to both Advisory services, as Alternative Dispute Resolution services.
In this privacy policy, you will find information about how we handle personal data. If you have any questions after reading this privacy policy about how we handle personal data, if you wish to exercise your rights as mentioned in this privacy policy under the General Data Protection Regulation (GDPR) or other data protection laws, or if you wish to file a complaint about the use of your personal data, you can contact us by phone at 020-2050239 or by email at office@pcg-co.com. If you are not satisfied with the handling of your complaint or prefer not to file it with us, you may also submit it to the Dutch Data Protection Authority via their website autoriteitpersoonsgegevens.nl.
PCG is responsible for processing your personal data and will handle it with the utmost care, complying with the rules derived from the GDPR.
Which Personal Data Do We Process?
Advising File: If you engage PCG for a service, PCG processes the personal data provided by you, your organization, and other party(ies) or persons involved in your case. This includes, at a minimum, the contact details such as name ot he organization, address, email address, and phone number. Additionally, it includes personal data relevant to the file. Depending the advisory assignment, this may also involve sensitive and/or special personal data.
Mediation File: If you engage PCG for a service, PCG processes the personal data provided by you and other party(ies) or persons involved in your case. This includes, at a minimum, your contact details such as your name, address, email address, and phone number. Additionally, it includes personal data relevant to the file. Depending on the mediation assignment, this may also involve sensitive and/or special personal data.
Training Purposes: When you register for a training session with us or when we provide in-house training for you, we process your personal data to the extent necessary to carry out the training and to certify or award (PE) points.
Billing: If you engage us for services, we also process the data necessary for invoicing and processing payments for the services provided by PCG. In addition to your contact details, this includes your bank account number and any other payment information. We may make use of an external financial services party to support with financial administration, and we will share your data solely for the purpose of invoicing.
Contact: If you contact us via the contact form on the website, by email, or by phone, we process the data you provide. This includes the contact details you provide to us (such as name, email address, phone number) and the reason for your contact (for example, if you have a question).
Analysis of Website Visitors: We process analytical data about visitors (and their computers) 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. Cookies are small text files that are automatically placed by the internet browser on your computer. A session cookie, for example, can track which web pages you view and which options you use. We use this data, among other things, to make our website more user-friendly. Session cookies are automatically deleted when you close your internet browser. You can configure your internet browser to warn you when a cookie is placed. You can also block cookies entirely. However, you may not be able to use all parts of our website if you do so.
For What Purposes and on What Legal Basis Do We Process Personal Data?
Advisory: PCG uses the personal data you provide in connection with an advisory assignment to Sensitive and individual related data and/or special personal data may be processed during the process (and this is not always clear in advance), we ask for your consent to process your personal data. You give this consent by signing the agreement. If you do not give this consent, unfortunately, you cannot use PCG ’s services, as PCG cannot perform the services without processing the personal data relevant to the file.
You have the right to withdraw your consent. PCG will then no longer be allowed to process your data. From the moment consent is withdrawn, PCG can no longer perform services for you and will immediately have to close the mediation file.
Mediation File: PCG uses the personal data you provide in connection with a mediation assignment to handle the mediation file. Because sensitive and/or special personal data may be processed during the mediation process (and this is not always clear in advance), we ask for your consent to process your personal data. You give this consent by signing the mediation agreement. If you do not give this consent, unfortunately, you cannot use PCG ’s services, as PCG cannot perform the services without processing the personal data relevant to the file. PCG may use an external partner for mediation services. PCG will share upfront with whom they partner and seek your consent before sharing your data.
You have the right to withdraw your consent. PCG will then no longer be allowed to process your data. From the moment consent is withdrawn, PCG can no longer perform services for you and will immediately have to close the mediation file.
Billing: The payment details you provide are used to invoice work. We need this processing to fulfil our contract with you.
Contact: The contact details you provide to us are used to contact you, if necessary, for example, to answer a question. We process this personal data because it is necessary for the protection of our legitimate interest, namely the interest of being able to carry out our work and acquire new assignments.
Marketing Information: We also use your email address to occasionally send you an update about our services. If you have engaged us for services, a so-called “existing customer relationship” exists, and we send you communication based on our legitimate interest. If you have not previously used our services but have contacted us in another way (such as by filling out the contact form or sending an email with a question), we will ask for your consent to send you informative communication, and we will only do so if you have given your consent.
Analysis of Website Visitors: The data we collect about website visitors is used solely to track statistics about website visits (for example, to see which pages are most viewed). The data is stored anonymously. By using the website, you indicate that you accept the privacy policy.
How Long Do We Retain Your Personal Data?
Advisory file: We retain the advisory file and the personal data contained therein for a maximum of twenty years after the file is closed, in connection with the maximum statute of limitations. In exceptional cases, we retain a file for longer than twenty years, for example, if the statute of limitations is interrupted or if PCG believes there is another legitimate interest in retaining the file longer.
Mediation File:We retain the mediation file and the personal data contained therein for a maximum of twenty years after the file is closed, in connection with the maximum statute of limitations. In exceptional cases, we retain a file for longer than twenty years, for example, if the statute of limitations is interrupted or if PCG ADR believes there is another legitimate interest in retaining the file longer.
Administration: We retain our administration, including invoices and other documents containing the personal data of parties, for a period of seven years after the end of the fiscal year to comply with the tax retention obligation.
Other Contact Details:We retain other contact details for one year after the last contact unless you request us to delete them sooner.
Analysis of Website Visitors: The data about website visitors is retained for two years after the visit to the website; this is the default setting of Google Analytics.
With Whom Do We Share Your Data?
Your data is stored in a digital file and may appear in emails that PCG sends or receives and is thus stored (and therefore processed) by our IT provider. We work with an external party for our mailings that sends the emails and therefore has your last name and email address in their system. This data is not shared further. In addition, the payment details you provided for billing purposes to PCG are passed on to the party that performs the financial administration for PCG . PCG has entered into a data processing agreement with these parties, which ensures at least the same level of security and confidentiality that you may expect from us.
Associated (Freelance) Mediator: It is also possible that we outsource mediation to an associated Partner, but not employed (freelance) mediator. At that time, we transfer the personal data known to us to this mediator, who then also becomes the data controller. This mediator fully complies with this privacy policy and therefore guarantees the same level of security and confidentiality. This mediator will only process the data relevant to the mediation file. This mediator will only use this data for the mediation file and the associated billing.
Complaint Handling: If you or another party involved in a mediation files a complaint against PCG regarding the handling of a mediation file containing your personal data, your personal data may be provided to the Mediators Quality Foundation (SKM) and/or the Mediation Disciplinary Foundation (STM). Your data will be treated confidentially by both organizations.
We do not provide your data to third parties unless we are required to do so by applicable laws and regulations, for example, to the police as part of a criminal investigation.
How Is Your Data Secured?
We have taken appropriate technical and organizational security measures to protect your personal data from loss, misuse, and unauthorized access by third parties. We also require our IT provider to take such appropriate technical and organizational security measures.
What Are Your Rights?
You have the following rights:
- The right to access your personal data and receive a copy thereof.
- The right to rectify your personal data if it is incorrect or incomplete.
- The right to object to the processing and/or, in certain cases, the right to restrict the processing of your personal data.
- In certain cases: the right to have your personal data erased (“right to be forgotten”).
The right to obtain your personal data in a structured, commonly used, and machine-readable format and to transfer that data to another party.
For more information on 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 via the email address or phone number provided at the beginning of this privacy policy.
Changes: Sometimes there may be changes in the personal data we process or the applicable regulations. In such cases, we may adjust this privacy policy. In the event of significant changes, we will post a notification on the website and inform you of the change via email.