NELEOS sets great store by the privacy of its clients and also of visitors to its website. It has therefore taken numerous steps in the office to prevent third parties gaining access to data on the server or to paper information. Unexpected data leaks are reported immediately.

NELEOS does not analyse the traffic on its website. Nor is it active on social media. The NELEOS website does however show links to other sites. By following them you are not just leaving the NELEOS domain visually, but also as regards the processing of data. NELEOS is never responsible or liable therefore for this processing by third parties.

Also otherwise NELEOS handles information with the utmost care. Prior to working for a client, agreements must be made. To record and carry out them, NELEOS always needs what is known as ‘general’ personal data from its clients (and often also from opposing parties). This is the (full) name, (email) address, gender and telephone number of individual persons. Under the Dutch Money Laundering and Terrorist Financing (Prevention) Act and the rules of professional practice in the legal profession a particular identification protocol also applies, which sometimes makes additional information necessary. The person providing this data to NELEOS is regarded as granting consent for its processing in the office in line with the privacy policy. Specifically this processing means that the data is entered in the office’s data system or paper files. It is retained following the closure of the file, subject to the rules governing this.

NELEOS only shares personal data with third parties for the purposes of fulfilling engagements or (as with notifying a (proposed) unusual transaction to the Financial Intelligence Unit) complying with a legal obligation. In so far as NELEOS engages external parties to process personal data on its behalf, it ensures that a processor’s agreement is concluded with them. A level of data security and confidentiality comparable to that of NELEOS is guaranteed through such an agreement.

Everyone (after prior identification) has the right to ask NELEOS what personal data of his or hers it has stored. This right does not however automatically extend to the inspection of underlying documents. If recorded data is incorrect, it will be amended on request.

It is unlikely that we will be able to honour a request to have personal data deleted in practice. It is after all almost always required for the institution, pursuit or substantiation of legal action of the person concerned him or herself or that of someone else and is therefore exempt from the right to removal.