Privacy statement

Pennino lawyers

Pennino Advocaten, based in Kerkrade and Maastricht, attaches importance to the protection of personal data. This privacy statement explains how Pennino Advocaten handles information about an identified or identifiable natural person, as referred to in the General Data Protection Regulation (AVG).

1. Application

This privacy statement applies to the following categories of natural persons from whom Pennino Advocaten processes personal data:
a. (potential) clients;
b. visitors to the office premises of Pennino Advocaten;
c. visitors to Pennino Advocaten's website;
d. recipients of newsletters from Pennino Advocaten;
e. participants in meetings of Pennino Advocaten;
f. applicants;
g. all other persons who contact Pennino Advocaten or whose personal data Pennino Advocaten processes, with ui

2. Processing of personal data

Pennino Advocaten processes personal data that:
a. a data subject has himself or herself provided in person (during a meeting or meeting), by telephone, or digitally (via e-mail or web forms on the office website), such as contact details and -depending on the nature of the occasion or case- other personal data;
b. provided by a professional liability or legal expenses insurer, professional or trade association, for the purpose of handling a case;
c. were generated during a data subject's visit to Pennino Advocaten's website or while reading digital newsletters, such as the IP address, browsing behaviour on the website (such as data on the first visit, previous visit and current visit, the pages viewed and the way through the website is navigated) whether the data subject opens a newsletter or commercial e-mail and which parts of it the data subject clicks on;
d. have been recorded by camera images when visiting the office premises of Pennino Advocaten. At the office premises in Kerkrade, camera images are made in order to know who is in the building in case of emergencies and to ensure that unauthorised persons do not gain access to the office. Camera images are in principle destroyed after (...) days];
e. Pennino Advocaten has derived from other sources, including business social media platforms such as LinkedIn, public business websites, the trade register of the Chamber of Commerce, the Land Registry, such as completed and required contact details and other personal data.

Pennino Advocaten's website contains hyperlinks to other parties' websites and social media buttons from Twitter, Facebook and/or LinkedIn. When these buttons are clicked, personal data are processed by the relevant social media platform. Pennino Advocaten is not responsible for the content of those websites or the services of those social media platforms. Nor is Pennino Advocaten responsible for the privacy policies and use of cookies on those websites and social media platforms. For answers on how Twitter and LinkedIn handle personal data, please refer to the privacy statements of those platforms.

3. Purposes of processing

Pennino Advocaten processes personal data for the following purposes:
a. execution of an agreement to provide legal services and billing for work performed;
b. complying with a legal obligation, including the Prevention of Money Laundering and Financing of Terrorism Act (Wwft);
c. obtaining funded legal aid;
d. maintaining contact, by sending the office newsletter, invitations to meetings and information requested by a data subject himself or herself;
e. improving product and service information and carrying out targeted marketing campaigns in order to provide clients/target groups with relevant information, without involving special personal data or confidential data in the combination and analysis of data required for this purpose and without creating individual client profiles;
f. evaluating a meeting (such as a workshop or seminar), on the basis of evaluation forms completed by participants; g. improving the office website Pennino Advocaten;
h. maintaining user statistics. User statistics of the office website provide information about the number of visitors, the duration of the visit, which parts of the website are viewed and the click behaviour. These are generic reports, which cannot be traced back to individual visitors;
i. monitoring access to the office and protecting confidential data.

4. Legal basis

Pennino Advocaten processes personal data on the following legal grounds:
a. consent of the data subject, which may be withdrawn at any time, without prejudice to the lawfulness of the processing based on the consent before the withdrawal; 
b. execution of or with a view to concluding an agreement of assignment to provide legal services, including billing to third parties (Legal Aid Board, insurance company, etc.);
c. a legal obligation, such as under the Wwft and the Legal Aid Act which require lawyers to obtain and record certain information;
d. a legitimate interest, such as the use of contact details to invite to a meeting (such as a workshop or seminar) or to send the office newsletter.

5. Processors

Pennino Advocaten may engage service providers (processors) to process personal data, who will process personal data solely on the instructions of Pennino Advocaten. Pennino Advocaten concludes a processing agreement with processors that meets the requirements set by the General Data Protection Regulation (AVG). Pennino Advocaten uses an IT contractor to manage and secure the office IT environment.

6. Sharing personal data with third parties

Pennino Advocaten shares personal data with third parties if necessary for the handling of a case or to comply with a legal obligation. For the handling of a case, it may be necessary to share personal data in the context of legal proceedings (such as with a judicial authority or (the lawyer of) the opposing party), the conclusion of an agreement (such as (the lawyer of) the other contracting parties), the claiming of services (such as to the Legal Aid Board or an insurer) or in response to a court order (such as a bailiff). Compliance with a legal obligation may include reporting unusual transactions to supervisory authorities. Pennino Advocaten does not share personal data with third parties for commercial purposes.

7. Transfer outside the EEA

In principle, Pennino Advocaten does not transfer personal data to countries outside the European Economic Area (EEA). If this should nevertheless be necessary, Pennino Advocaten will ensure that the transfer only takes place if the European Commission has indicated that the country in question offers an adequate level of protection or if there are adequate safeguards within the meaning of the General Data Protection Regulation (AVG).

8. Retention of data

Pennino Advocaten does not retain personal data for longer than necessary. In principle, Pennino Advocaten applies the following retention periods:
a. paper work file: 7 years after case completion;
b. digital case file: after completion of the case, in principle with no time limit;
c. (financial) administrative data: 7 years after data capture;
d. applicant data: 4 weeks after completion of the application process; 4
e. visitors to the Pennino Advocaten website and recipients of newsletters from Pennino Advocaten: 5 years after the last visit to the website or after unsubscribing to the newsletter respectively, unless an objection is made earlier in which case destruction will be carried out.

9. Changes to privacy statement

Pennino Advocaten may amend this privacy statement at any time. Changes will be published on the Pennino Advocaten website. You are advised to consult this privacy statement regularly so that you are aware of any changes.

10. Rights, questions and complaints

A data subject has the right to request Pennino Advocaten to inspect, rectify, delete, transfer, restrict and object to the processing of personal data. A data subject may contact Pennino Advocaten in this regard by sending an e-mail message to: mail@pennino.nl.

Also, if you have any questions or complaints about the way Pennino Advocaten processes personal data, please contact Pennino Advocaten by sending an e-mail message to: mail@pennino.nl explaining what the complaint entails.
We always try to resolve a complaint to your satisfaction. Should this fail, you can turn to the Personal Data Authority (AP).