Privacy Statement

Last updated: June 03, 2022

Meijburg & Co1 is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, Meijburg & Co is committed to the appropriate protection and use of personal information (sometimes referred to as “personal data”) that has been collected online.

Generally, our intent is to collect only the personal information that we require within the scope of our service and information provision. Please review this Privacy Statement to learn more about how we collect, use, share and protect the personal information that we have obtained.

1. Collection and use of personal information
1.1. What information we collect

We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you will have previously provided your personal information to us (if, for example, you are a former employee). In addition to the information you have provided, we will, under circumstances, also collect data from public sources so as to meet our statutory obligations under such legislation as the Dutch Money Laundering and Terrorist Financing Prevention Act (Dutch acronym: Wwft). As part of our service provision, we will also collect information that is not provided to us directly by data subjects, but by such parties as their employer.

If you choose to register or log in to a Meijburg & Co website using a third-party single sign-on (SSO) service that authenticates your identity and connects your social media log-in information (e.g., LinkedIn, Google, or Twitter) with Meijburg, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect will depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.

We will, in principle, only collect the personal information that is required to meet your request or our statutory obligations. Where additional, optional information is retrieved, you will be so notified at the point of collection.

Your personal data will not be used for other purposes than the purposes for which you have provided the information to us, unless we obtain your permission, unless required for meeting a statutory obligation, professional standard or quality rule, or unless further processing is permitted under privacy legislation. For example, if you send us an email message requesting information about Meijburg & Co, we will use your email address and other information you provide to respond to your request. If you send us a resume or curriculum vitae (CV) to apply online for a position with Meijburg & Co, we will use the information that you provide to match you with available Meijburg & Co job opportunities.

We may process the following types of personal data when you visit our website:

• Name
• Email address
• Company name
• Job title
• Phone number
• IP address
• Log-in details
• Your interests and preferences
• Social media name
• Information about your surfing and browsing habits, possibly your location and other cookie information

We may also process other personal information as part of other activities, such as our service provision, recruiting, marketing and events, and tools we have provided. It depends on the activity and the information you have provided, as well as on the then prevailing statutory requirements and professional standards which data we process while carrying out these activities. Examples of information we may process for all these activities are your name and address details, date of birth, gender and private and business contact information. We have listed a number of specific processing situations below:

Service provision	Recruitment	Marketing and events
Information about role and department	Employment history/CV	Information about role and department
Information about corporate structure and shareholders	Educational background	Preferences and interests (consent and objection)
Financial information	LinkedIn URL	User account and log-in details
Information from chats and other messaging tools (KPMG tools)	Personal data shared in cover letter	Technical information (such as IP address)
		Video and audio materials

Within the scope of these activities, we may in some instances – where this is permitted by law and/or subject to your consent – process special categories of personal data (such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or sexual orientation, or medical information) as well as information about alleged or proven criminal offenses. We are occasionally also required to process national identification numbers (in the Netherlands: BSN) or redacted or unredacted copies of identity documents.

1.2. Legal grounds we have to use your personal information

Dutch law allows us to process personal information, so long as we have a ground under the law or consent to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions: 

• Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract or to enter into this contract. 
   
• Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as:
  • • Keeping records for tax purposes;
    • Performing client due diligence reviews and meeting other requirements under the Dutch Money Laundering and Terrorist Financing Prevention Act;
    • Performing independence screenings;
    • Documenting our procedures in files;
    • Providing information to a public body or law enforcement agency.
       
• Legitimate interest: we may process information about you where it is in our or a third party’s, e.g., a client’s, legitimate interest in running a lawful business to do so in order to further that business, so long as it does not outweigh your interests. Examples of the legitimate interests referred to above are:
  • • To offer information and/or services to individuals who visit our website;
    • To prevent fraud or criminal activity and to safeguard our IT systems;
    • To customize individuals’ online experience and improve the performance usability and effectiveness of Meijburg & Co’s online presence;
    • To conduct and analyze our marketing activities;
    • To meet our corporate and social responsibility obligations;
    • To exercise our fundamental rights in the EU under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property.
       
• Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting Meijburg & Co at privacymeijburg@kpmg.com

1.3 Automatic collection of personal data

Meijburg & Co uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of Meijburg & Co’s online presence, and measure the effectiveness of our marketing activities.

1.3.1. IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses of visitors from which visitors appear to originate will be recorded for IT security and system diagnostic purposes. This information will also typically be used in aggregate form to conduct website trend and performance analysis.

1.3.2. Cookies

Cookies will typically be placed on your computer or internet-enabled device (e.g., a computer or smartphone) whenever you visit us online. This allows the site to remember your device and serves a number of purposes.

On our websites, a notification banner will appear allowing you to manage your consent to collect cookies. If you do not consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookies, referred to as user-input cookies may be required to ensure the necessary functionality. These cookies will not be blocked through the use of the banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.

Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that, if you do not accept cookies, you may not be able to fully experience some of our websites’ features.

Further information about managing cookies can be found in your browser’s help file or through sites such as www.allaboutcookies.org.

Below is a list of the types of cookies used on our websites:

Purpose	Outline	Type & Expiry
Performance (i.e., user’s browser)	Our websites are built using common internet platforms.  These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content).	Session; deleted upon closing the browser
Security (e.g., Asp.NET)	If you register for access to a restricted area, our cookies ensure that your device is logged for the duration of your session. You will need your username and password to access the restricted areas.	Session; deleted upon closing the browser
Site preferences	Our cookies may also remember your site preferences (e.g., language) or seek to enhance your experience (e.g., by personalizing a greeting or content). This will apply to areas where you have registered specifically for access or to create an account.	Session; deleted upon closing the browser
Analytical	We use different cookies to help us understand how site visitors use our website. This allows us to improve the quality and content on meijburg.com for our visitors. The aggregated statistical data covers items such as total visits or page views, and referrers to our websites. For further details on our use of Google Analytics, see below.	Persistent, but deleted automatically after two years if you no longer visit meijburg.com.
Site visitor feedback	We use a third-party survey tool to invite a percentage of visitors to provide their feedback. Cookies are used to prevent visitors from being invited multiple times. The first cookie (1) is set if the visitor is not invited to participate in the survey, and is used to ensure visitors are not invited after their first page view. The second cookie (2) is set if the visitor is invited to participate in the survey, and is used to ensure the visitor is not invited again to participate for a period of 90 days.	1: Session; deleted upon closing the browser   2: Persistent; deleted automatically after 90 days or presenting survey invite.
Social sharing	We use third-party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed on our web pages (e.g., the social share count cache is updated) and log information about your activities across the internet and on our websites. We encourage you to review each provider’s privacy information before using any such service. For further details on our use of social media widgets and applications, see below.	Persistent, but deleted automatically after two years if you no longer visit meijburg.com.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers, including IP addresses, but this is for the purpose of identifying the number of unique visitors to our websites and geographic origin of visitor trends, and not to identify individual visitors.

Google Analytics

Meijburg & Co uses Google Analytics. More information on how Google Analytics is used by Meijburg & Co can be found here: Privacy controls in Google Analytics – Google Analytics Help. In addition, Meijburg & Co follows the manual provided by the Dutch Data Protection Authority for the private-friendly setup of Google Analytics. This means we have a data processing agreement with Google, that we anonymize your IP address, that Google is not authorized to collect our users’ personal data for its own purposes, that marketing options and user IDs have been deactivated, and that we use a banner to inform our visitors.

To provide website visitors with more choice on how their data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

1.3.4. Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. Meijburg & Co only uses web beacons in accordance with applicable laws.

In some of our newsletters and other communications, we will monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to improve our services and communication.

1.3.5. Location-based tools

Meijburg & Co may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

1.4. Social media widgets and applications

Meijburg & Co websites will typically include functionality to enable sharing via third-party social media applications, such as the Facebook Like button and Twitter widget. These social media applications will collect and use information regarding your use of Meijburg & Co websites (see details on social sharing cookies above). Any personal information that you provide via such social media applications will often be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, Meijburg & Co websites may host blogs, forums, crowd-sourcing and other applications or services (collectively: “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any Meijburg & Co social media feature will typically be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we have limited or no control.

1.5. Children

Meijburg & Co understands the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for, or directed at, children under the age of 16. It is our policy never to knowingly collect or retain information about anyone under the age of 16, except as part of an engagement to provide professional services.

2. Sharing and transfer of personal information

Transfer within the network of KPMG firms

Meijburg & Co will share information about you with KPMG International and other members of the KPMG network as part of our engagement where required or desirable to meet our legal and regulatory obligations around the world. Other parts of the KPMG network are also used to provide services to us and you, for example hosting and supporting IT applications, assisting with KPMG services, performing client conflicts checks and meeting the provisions of Dutch Money Laundering and Terrorist Financing Prevention Act.

Transfers to third parties

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests and/or as required or permitted by law or professional standards. This would include:

• Our service providers: Meijburg & Co works with partners, service providers or agencies so they can process your personal information on our behalf. Meijburg & Co will only transfer personal information to them when they meet our strict standards on the processing of data and security. We only share personal information that allows them to provide their services.
• If we are reorganized or sold to another organization: Meijburg & Co may also disclose personal information in connection with the sale, assignment, or other transfer of any element of the business to which the personal information relates.
• Courts, tribunals, law enforcement or regulatory bodies: Meijburg & Co may disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government or professional regulations. 
• Audits: disclosures of personal information may also be needed for data privacy or security audits and/or to investigate, or respond to, a complaint or security threat.
• Insurers: in the event of a claim, we will share information with our insurer.

In some instances, Meijburg & Co may share personal data about you with various outside companies or service providers or vendors working on our behalf to help fulfill your requests.

In addition, Meijburg & Co may transfer personal data across geographical borders to other KPMG member firms or outside companies working with us or on our behalf. Meijburg & Co will also typically store personal data in a jurisdiction other than where you are based. Personal data is transferred by Meijburg & Co in accordance with privacy and other laws and regulations, such as the General Data Protection Regulation (GDPR) and other EU-approved standard data protection clauses.

Meijburg & Co will not transfer the personal data you provide to any third parties for their own direct marketing use.

3. Choices

In general, you are not required to submit any personal data to Meijburg & Co, but we may require you to provide certain personal data in order for you to receive additional information about our services and events. Meijburg & Co may also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

4. Your rights

If Meijburg & Co processes personal information about you, you have the following rights:

• Access and rectification: you have the right to access your personal data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge if your request is reasonable. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. Depending on the service level, we may ask you, in certain instances, to specify your subject access request. If the information we hold about you is incorrect, you may ask us to correct any inaccuracies in the personal information.
   
• Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it anymore or if you believe that our use of your personal information qualifies as inappropriate.
   
• Other rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in a common electronic format that can be used by a different service provider.

You can make a request or exercise these rights by contacting privacymeijburg@kpmg.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

5. Data security and integrity

Meijburg & Co has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, destruction or unauthorized access. Despite Meijburg & Co’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual’s request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected.

6. Links to other sites

Please be aware that Meijburg & Co websites will typically contain links to other sites, including sites maintained by other KPMG member firms that are not governed by this Privacy Statement but by other privacy statements that will often differ somewhat. We encourage users to review the privacy policy of each website visited before disclosing any personal information.

By registering on any KPMG website and then navigating to another KPMG website while still logged in, you agree to the use of your personal information in accordance with the privacy statement of the KPMG website you are visiting.

7. Changes to this statement

Meijburg & Co may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. Any changes to the processing of personal data as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

8. Policy questions and enforcement

Meijburg & Co is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at privacymeijburg@kpmg.com. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement. We will acknowledge your complaint or request within one month of receipt and seek to resolve your concern or request.

In any event, you always have the right to lodge a complaint with the Dutch Data Protection Authority.                   

1. Throughout this document, “Meijburg & Co” [“we,” “our,” and “us”] refers to Meijburg & Co, an association of limited liability companies under Dutch law, registered under Chamber of Commerce registration number 53753348, and/or to any one or more of the member firms of the KPMG network of independent firms affiliated with KPMG International.