Privacy Policy

1.0 Introduction

In this privacy statement, we explain the data we process from you when we have, seek, or have had a business relationship with you. We also inform you about why and how long we process your data and what your rights are regarding each processing. Additionally, we provide information about the parties we collaborate with and our security policy. We consider it important that our service is reliable and transparent. Therefore, we handle your personal data discreetly and carefully, ensuring that every processing of your data complies with applicable laws and regulations.

2.0 Data Controller for the Processing of Personal Data

The Data Controller is:
Name – Van Marrewijk Investments B.V.
Address – Voorstraat 96
Postal Code – 2685EP
City – Poeldijk
Phone Number – +31640959931
Email Address – hi@lucasybrit.com

3.0 Privacy Manager

We have appointed a Privacy Manager. This is not a ‘data protection officer’ as referred to in Article 37 of the GDPR. However, this person ensures that your data is processed in accordance with the law. The Privacy Manager’s responsibilities include supervision, handling queries and complaints. The contact details of our Privacy Manager are:

Name – Frederique van Os
Phone Number – +31640959931
Email Address – frederique@lucasybrit.com

4.0 Personal Data We Process

Depending on your relationship with our organization and the purpose for which we process data, we record (some of) the following data:

1. First and last name of contact persons
2. Address details
3. Phone number
4. Email address
5. Information about your activity on our website

In specific cases, the following special and/or sensitive personal data:

1. None

5.0 Purpose and Legal Basis for Processing Personal Data

We process your personal data for the following purposes:

1. Maintaining financial administration
2. Sending newsletters or mailings
3. Monitoring website visits

The legal grounds for processing are as defined in Article 6 and/or Article 9 of the GDPR (explicit consent, contract, or legitimate interest).

6.0 Automated Decision-Making

We do not make decisions based on automated processing that could have significant consequences for individuals. This refers to decisions made by computer programs or systems without human intervention (such as our staff).

7.0 Retention of Personal Data

Generally, we do not retain your data longer than necessary for the purposes for which we collected it. The retention period may vary from case to case. For instance, we may need to retain certain documents for a minimum period for tax or administrative purposes. In such cases, we will only retain data necessary to comply with our legal obligations. After the legal retention periods, we will delete or anonymize your data.

8.0 Sharing Personal Data with Third Parties

We do not share your personal data with third parties, except when necessary for performing a contract with you or to fulfill a legal obligation. If these third parties qualify as processors, we have concluded data processing agreements with them that include security, confidentiality, and your rights. We remain responsible for these processing activities.

We engage third parties in the following categories of processing:

1. Maintaining financial administration
2. Sending newsletters or mailings
3. Monitoring website visits

9.0 Your Rights (Access, Rectification, Erasure, etc.)

Below are explained your rights regarding the processing of your data.

1. Right to access You have the right to access your own data. This includes information about the purposes of the processing, recipients of the data, and the retention periods.
2. Right to rectification You can ask us to rectify your data. You also have the right to complete incomplete data by sending an email to us.
3. Right to be forgotten You have the ‘right to be forgotten.’ Upon request, we will erase your data without undue delay. However, we may not always delete all your data. Sometimes, processing may still be necessary for legal obligations or for establishing, exercising, or defending claims.
4. Right to restriction of processing In principle, you have the right to restrict the processing of your data, for instance, if you believe your data is inaccurate or the processing is unnecessary.
5. Notification of rectification, erasure, or restriction Unless it is impossible or requires disproportionate effort, we will inform the recipients of your data about each rectification, erasure, or restriction of processing.
6. Right to data portability You have the right to data portability. This means you can request to receive your data and store it for personal reuse. You have this right only regarding data you have provided to us yourself and when processing is based on consent or a contract in which you are a party.
7. Withdrawal of consent If data processing is based on consent, you have the right to withdraw that consent at any time. The processing of your data before withdrawal remains lawful.
8. Right to object In principle, you have the right to object to the processing of your data. After your objection, we will generally stop processing your data.
9. Complaint to the Data Protection Authority or the Court If you believe that the processing of your data violates the law, you can contact our Privacy Manager. You also have the right to file a complaint with the Data Protection Authority (DPA) or take the matter to court.
10. Limitations of Your Rights Sometimes, we can limit your rights, for instance, to prevent, investigate, detect, and prosecute criminal offenses, such as fraud.

You can direct any request to our Privacy Manager. To ensure that a request is made by you, we ask you to send a copy of your ID with the request. In this copy, please black out your photo, MRZ (machine-readable zone, the strip with numbers at the bottom of the passport), passport number, and Citizen Service Number (BSN) for your privacy protection.

10.0 How We Secure Personal Data

We take data protection seriously and implement appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and unauthorized alteration. If you believe your data is not properly secured or there are indications of abuse, please contact our Privacy Manager.

11.0 Changes

We may change this statement if developments require, such as new processing methods. The most up-to-date privacy statement can be found on our website. We recommend that you regularly consult this privacy and cookie statement to stay informed about any changes.