We appreciate your interest in our Privacy Policy. At AVR-Law, we take the protection of your data very seriously, and in the below we explain what data we collect when you use our website and how it is used.

General Information

a) What law applies?
Our use of your Personal Data is subject to Curaçao’s National ordinance on data protection (“NODP”), the Dutch GDPR Implementation Act (Uitvoeringswet Algemene Verordening gegevensbescherming) (“UAVG”) and the EU’s General Data Protection Regulation (“GDPR”), and of course we process your Personal Data accordingly.

b) What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an individual. This may include, a name, date of birth, e-mail address, postal address, or telephone number but also online identifiers such as IP addresses or device ID`s.

c) What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

d) Who is responsible for data processing?
The responsible party within the meaning of the NODP, UAVG and the GDPR is AVR-Law of P.O.Box 2045 Willemstad, Curacao. If you have any questions or if you wish to exercise your rights, please contact us using info@avr-law.com, call +5999-5211152, or write to us at the above address.

e) What are the legal bases of processing?
In accordance with the NODP, UAVG and the GDPR, we have to have at least one of the following legal bases to process your Personal Data:

● For the fulfillment of contractual obligations
o The purposes of the data processing are primarily based on the service we provide.

● Within the framework of our legitimate interests Where necessary, we process your data beyond the actual performance of the contract in order
to safeguard legitimate interests of us or third parties. Examples are:
o Ensuring IT security and IT operations,
o Measures for business management and further development of our services,
o Defense against third-party claims and enforcement of own claims.

● Based on your consent
o Insofar as you have given us your consent to process personal data for certain purposes.

f) Is there an obligation for me to provide data?
Within the scope of our business relationship, you are only required to provide personal data that is necessary for the establishment, implementation, and termination of a business relationship or that we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and may have to terminate it. 

Data we collect automatically
a) Log data Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user’s device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

b) Content Management System (CMS) We also use the Content Management System (CMS) of WordPress by Automattic Inc to publish and
maintain the created and edited content and texts on our website. This means that all content and texts submitted to us is transferred to WordPress. This represents a legitimate interest.

c) Hosting To provide our website, we use the services of MochaHost.com, who process all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.

d) Cookies We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. For further information on the Cookies we use, please refer to our Cookie Policy.

e) Google Fonts We integrate Google Fonts by Google LLC, to enable the display of fonts, a connection to Google’s server is established when our website is accessed. This enables Google to determine which website sent the request and to which IP address the display of the font is to be transmitted. The integration is based on our legitimate interest.

Data we collect directly

a) Contacting us Personal data is processed depending on the contact method. In addition to your name and email address, IP address or phone number, we usually collect the context of your message, which may also include certain Personal Data. The personal data collected when you contact us is used to process your request and the legal basis is your consent.

b) Booking a Meeting For booking a Meeting in an easy and convenient way, we use Probooking by KyoSoft B.V. Your data from the form will be transferred to our appointment account at Probooking after you press the “Book appointment” button. You will then receive a confirmation email with a link to the event. Your data will be kept at Probooking until the purpose for storing the data no longer applies (appointment made) or you request us to delete it. Probooking undertakes not to pass on your data to third parties. The legal basis is your consent as well as our legitimate interest.

c) When using our services We process the Personal Data involved in your use of our services in order to be able to provide our contractual services. This includes in particular our services, support, correspondence with you, invoicing, fulfillment of our contractual, accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations.

d) Administration, financial accounting, office organization, contact management We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving or invoicing. Our invoicing and expense management are done through the services of Invoice-Way. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

Social Media

a) General
We have a presence on social media based on our legitimate interests (currently, Facebook , Instagram and Twitter).

b) Contact and interaction
If you contact or interact with us via social media platforms, we and the respective social media platform are jointly responsible for the processing of your data and enter into a so-called joint-controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual performance, if any.

c) Social media links
We refer to our offered social media presences with links. Unlike social media plugins, links do not cause the social media platform to learn of your visit when you access our site. However, like any link, they do lead to your data being processed by the social media platform at the latest when you click on the link. As a rule, the social media platform stores cookies on your device or even your usage behavior in your account, especially if you are logged in yourself. The social media platform may use your data to analyze your usage behavior and use it for (interest-based) advertising. This may result in advertising being displayed to you inside and outside the social media platform.

General Principles

a) Who receives my data?
Within AVR-Law, those that need your data to fulfill our contractual and legal obligations will receive access to it.

Processors used by us may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, and sales and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal provisions.Data is only passed on to third parties within the framework of legal requirements. We only pass on users’ data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business or you have consented to the transfer of data.
b) How long will my data be stored?
As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods, the Tax Administration (belastingdienst) and among others the Chamber of Commerce (kvk). The retention and documentation periods specified there are two to six years.

c) How do we secure your data?
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

d) Is data transferred to a third country or to an international organization?
Your data is not transferred to third countries (countries outside Curaçao and the EEA).

e) Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

f) Minors
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

g) Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision making including profiling does not take place.

h) Do Not Sell
We do not sell your Personal Data. Your Rights and Privileges

a) Privacy rights
You can exercise the following rights:
● Right to information
● Right to rectification
● Right to object to processing
● Right to deletion
● Right to data portability
● Right of objection
● Right to withdraw consent
● Right to complain to a supervisory authority
● Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to
exercise any of your rights, please contact us.

b) Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

c) Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation

d) Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

Validity and questions

This Privacy Policy was last updated on Saturday, 30th of September 2023, and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary. If you have any data protection questions, please feel free to contact us.