Privacy Statement
Less Grey at Alkmaar
Version 1.3, December 18, 2018
1. Introduction
Less Grey is an independent indirect tax consultancy specializing in sales tax (VAT). In addition to providing advice, support is provided for clients' reporting obligations and foreign VAT refund requests. When deploying the legal remedies of objection and appeal, we act as agents.
Less Grey's work is carried out from Less Grey B.V. (consulting), Less Grey Rep B.V. (tax representation and compliance) and Less Grey Refund Services B.V. (VAT4U Netherlands).
Less Grey's clients are primarily businesses and institutions acting as sales taxpayers. Our services consist of advising and assisting our clients in the design and execution of their business operations and the business models to be adopted in this regard.
For the performance of our advisory work, you will receive an order confirmation for your signature and your business data, including contact details, will be included in a data file. In fulfillment of legal obligations under the Money Laundering and Terrorist Financing Act (Wwft), we identify the client and record data.
This data also relates to the identification of the natural person representing the client. This personal data is protected by us in compliance with the General Data Protection Regulation (GDPR).
2. Capture and processing
The company and personal data we record relate to the performance of our work as defined and agreed in the order confirmation. In addition, company and personal data are recorded in fulfillment of our legal obligation under the Wwft.
Your information will be included in a separate database and used only for our communications in the performance of our consulting work.
The capture, storage and retention of personal data in a database means that we are processors within the meaning of the AVG. Less Grey is the processor as referred to in the AVG
2.1 Consulting work
For the work within the consulting office, personal data are recorded and stored only insofar as they are part of the business data of our clients with whom we have concluded an order confirmation.
2.2 Compliance work, VAT returns
We use third-party software for work related to fulfilling tax return obligations and/or additional reporting obligations for clients. In this regard, we have entered into a processing agreement with the relevant supplier of the software package.
2.3 Applications for foreign VAT refunds.
We use the software solutions of VAT4U for the work related to reclaiming foreign VAT. Less Grey Refund Services B.V. has been appointed as the Dutch representative of VAT4U and acts under the name VAT4U Netherlands when performing these activities.
The agreements entered into by VAT4U with Dutch clients for reclaiming foreign VAT, and the relevant legal obligations under the AVG, are included and reflected in a separate Privacy Statement.
3. Less Grey privacy policy
The agreements with Dutch clients form the basis for us to record company and personal data. In addition, the legal obligation referred to in the Wwft is a basis on which personal data are recorded, stored and retained.
The personal data we capture relates to:
- The name of our client's representative(s);
- The phone number of such representative(s);
- The e-mail address of the representative(s);
- the information as shown on the identification document that was provided in copy or inspected, containing name, place of birth, date of birth and the number of the identification document.
The identification document number is a mandatory prescribed part of the identification of persons under the Wwft.
Personal data will be retained for the duration of our agreement and, after the expiration of this agreement, subsequently for the period during which we are required to comply with legal retention periods, including those imposed in connection with the levying of taxes in the Netherlands.
3.1 Other personal data
We may capture, store and retain personal information that relates to individuals who are not known to be clients' representatives.
These are relationships whose personal data have been provided to us by the data subject. This data can be used for sending invitations, newsletters or other business communication aimed at informing data subject.
The data captured relate to:
- Company name;
- First name and/or initials;
- Last name;
- E-mail address;
- Phone number;
- Profile/sector classification
This personal data will be stored and retained for the period of time the individual is considered a Less Grey relationship who is interested in our information.
3.2 Personnel data
Records of individuals who are and/or have been employed by Less Grey as employees shall be recorded, stored and retained in such a manner that such records are accessible within the organization only to the human resources officer designated for human resources.
The services of third parties are used in performing work related to the payroll and salary administration of staff members, as well as for the recording of disability, illness and pensions. Processing agreements have been concluded with these parties.
3.3 Provision of personnel data to third parties
When various activities are performed, the use of a third party is explained in section 2. In addition to the processors mentioned there, one or more third-party software packages are used for Less Grey's financial administrations, and the management and security of our IT environment uses the service and support of an external service provider.
Less Grey has also entered into processor agreements with parties offering Less Grey services, such as in the areas of IT, accounting, disability and absence administration, pensions & payroll.
We do not provide personal data to parties with whom we do not have a processor agreement.
3.4 Security
We have taken technical and organizational measures appropriate for the collection and storage of company and personal data. Digital data is stored on a server located within our office building in a special room accessible only to authorized persons.
Access to this digital data uses usernames and passwords on all of our systems.
The backup of this digital data is provided in a secure environment in a data center, located in the Netherlands. In this regard, a processing agreement has been concluded with our ICT administrator.
Less Grey employees have been informed of the importance of protecting company and personal data.
3.5 Cookies or similar techniques
Less Grey respects the privacy of visitors to its website www.lessgrey.eu and of users of the portal mylessgrey.eu.
When visiting the website www.lessgrey.eu, your personal data are processed for the improvement of our website and social media sharing. The website keeps general visit data, such as IP addresses of the computer, any user name, the time of retrieval and data sent by a visitor's browser.
This data is recorded and may be used to obtain statistical information about the quality and/or effectiveness of the website.
Our website uses three types of cookies: necessary cookies, analytical cookies and social media plug-ins. A cookie is a small text file placed on the hard drive of your computer or mobile device by a website you visit. This text file stores information about your visit. This information can be recognized again by this website on a later visit. Sometimes another website can also read the cookie and store information in it.
Necessary cookies are cookies required for the website to function.
Analytical cookies are cookies used to track how users use the website. This involves the use of utilities, such as Google Analytics.
Google stores this data on servers in the United States. Google is a member of the EU-U.S. Privacy Shield Framework.
We have taken measures within Google Analytics to limit the traceability of visitors to the website and we do not allow Google to use the information obtained for other Google services.
Google may provide the obtained information to third parties if Google is legally obliged to do so, or for these third parties process the information on behalf of Google (processors of Google). Google's Privacy Policy can be read here. the specific privacy policy of Google Analytics can be read here.
Social media plug-ins for the social networks LinkedIn, Twitter and Facebook are buttons on a website that allow information on our website to be shared. The transmission of data is established by a code of the social networks themselves.
There is a plug-in for LinkedIn on our website. You can read LinkedIn's privacy statement here.
You have control over cookies and can refuse their placement by adjusting the cookie settings in your browser. Most browsers will tell you how to refuse the placement of cookies, how to be notified of a cookie placement, and how to delete placed cookies.
3.6 News facilities & invitations
Less Grey may offer a newsletter and/or send invitations to those registered as client contacts and business associates. To send this newsletter or invitations, we use the services of mailchimp, which stores the data in the U.S. Mailchimp is affiliated with the EU-U.S. Privacy Shield Framework. You can read Mailchimp's privacy policy here.
3.7 Rights regarding your personal data
Natural persons whose data we have recorded, stored and retained have the right to access, rectify or delete all or part of the personal data.
3.8 Complaints and or questions
If you have a complaint or question about Less Grey's processing of your personal data, please contact us.
Less Grey
Robijnstraat 26
1812 RB ALKMAAR
secretariaat@lessgrey.eu