Privacy Statement

Note: This General Privacy policy applies to AFS Group BV (herein “AFS”, “we” or “us”) and all its affiliated entities.

Introduction on the General Data Protection Regulation (GDPR) and the processing of personal data
Protecting privacy is important to AFS and we are committed to maintaining the accuracy, confidentiality and security of your personal information. This privacy policy applies if you are a (representative of) a client of our organization. This privacy policy sets out the basis on which any personal data about you may be processes by AFS as a controller. As a data controller we are responsible for ensuring that we process your data in compliance with the General Data Protection Regulation, the code of conduct for financial service providers and other applicable national data protection legislation. Please take the time to read and understand this policy carefully.

Who can you contact for data processing?
If you would like further information on the collection, use, disclosure, transfer or processing of your personal data, please address questions, comments and requests to the following address:

AFS Group BV
Beursplein 5, 1012JW Amsterdam
privacy@afsgroup.nl
020 5707200

Which data are processed and from which sources do they come?
We process the personal data that we receive from you or your employer as part of our business relationship. In addition, we process data that we have legitimately collected from publicly available sources (e.g. business register, association register, land register or media).

Personal data means any information that can be used to identify directly or indirectly a specific individual. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual). Personal information includes your personal details and contact information (e.g. name, address, date and place of birth, nationality, etc.).

Certain categories of personal data, such as race, ethnicity, religion, health, sexuality or biometric data are classified as “special categories of data” and benefit from additional protection under GDPR.

AFS does not collect and process these special categories of data.

For which purposes and on which legal basis are data being processed by AFS?
We process your personal data in accordance with article 6 of the European General Data Protection Regulation (GDPR):

  • to fulfil contractual obligations (Article 6 (1) (b) GDPR)

The processing of personal data is carried out for the performance of our brokering contracts with you as (the contact person of) a client. Example of such cases are:

– Storing contact data of representatives of a client

– Invoicing

– Providing news & research packages to clients

  • to fulfil legal obligations (Article 6 (1) (c) GDPR)

The processing of personal data shall be carried out for the purpose of fulfilling various legal obligations. Examples of such cases are:

– Collecting data in the context of performing a Know-Your-Customer –Procedure;
– Reporting obligations to Local Regulators.
– Provision of information to federal tax authorities.
– Recording of telephone conversations and electronic communication regarding customer orders
– Administer insider lists
– Assess and manage risks

  • as part of your consent (Article 6 (1) (a) GDPR

If you have given us your consent to the processing of your personal data for specific purposes, processing will only take place in accordance with the scope of your consent. Examples of such cases are:

– Providing regular research notes, every one of these will include an option to unsubscribe from this service

  • to safeguard legitimate interests (Article 6 (1) (f) GDPR) in general

If necessary, data processing may be carried out to protect legitimate interests of AFS such as maintaining the business relationship and acquiring new clients.

Who receives my data?
Within AFS, those departments or employees receive your data, as required by them to fulfil their contractual, legal and / or regulatory obligations and legitimate interests.

We will not transfer your personal data to any third parties, unless there is a legal or regulatory obligation, public authorities and institutions (e.g. Local Central Banks, Local Financial Market Authorities, Local tax authorities, Auditors etc.).

How long will my data be stored?

AFS processes your personal data, as far as necessary, for the whole duration of the entire business relationship which we consider to be until 1 year after last contact, unless a longer period is required to comply with mandatory storage and documentation obligations as required by legislation.

Which data protection rights do I have?
Under the GDPR you, as a data subject, have the right to access, rectification, erasure or restriction of the processing of your stored data, a right to object to processing and a right to data portability in accordance with the requirements of the GDPR. For requests related to these rights contact AFS at privacy@afsgroup.nl.

Right of erasure
You have the right to request to be forgotten by AFS. For these requests AFS will remove all data except data that is still required for the performance of an ongoing contract or to fulfil its legal obligations.

Complaint
In case of a complaint, the data subject can submit a complaint to the responsible contact person of AFS as mentioned above. You also have the right to lodge a complaint with the relevant authority of your country, for the Netherlands this is the Autoriteit Persoonsgegevens (https://autoriteitpersoonsgegevens.nl/).

How is personal data protected?
AFS endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure. Internally access is restricted to those persons who have a legitimate purpose to access it.

Cookies
Cookies are small text files stored on your browser to retain certain information while using a website.

AFS only uses functional cookies on its website (https://afsgroup.nl). These cookies are used to remember your choice of language on the website. These are first-party cookies and are not shared.

Changes to this privacy policy
This privacy policy may change periodically. An up to date version will always be available at (https://afsgroup.nl/privacy-statement/). In the case of significant changes to this policy you will be informed in a more direct manner, for example by email.