Privacy Statement Customs Knowledge – last updated March 2018

Customs Knowledge is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, Customs Knowledge is committed to the appropriate protection and use of personal information (sometimes referred to as "personally identifiable information" or "PII") that has been collected online.

Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals.  Please review this Privacy Statement ("Privacy Statement") to learn more about how we collect, use, share and protect the PII that we have obtained.

1. Collection and use of personal information

1.1. What information we collect

We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you will have previously provided your personal information to Customs Knowledge.

When you register or submit personal information to Customs Knowledge we will use this information in the manner outlined in this privacy statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to a Customs Knowledge web site and provide information about your preferences we will use this information to personalize your user experience.

In some cases where you have registered for certain services we will store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).

1.2 The legal grounds we have to use your personal information

Customs Knowledge generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.

The law in Europe allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:

• Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
• Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
• Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
• Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting Customs Knowledge at info@customsknowledge.nl.

1.3 Cookies

In some instances, Customs Knowledge and its service providers uses cookies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of Customs Knowledge's online presence, and to measure the effectiveness of our marketing activities.

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.

Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites' features.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.

1.4 IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used to conduct web site trends.

1.5 Google Analytics

Customs Knowledge uses Google Analytics. More information about how Google Analytics is used by Customs Knowledge can be found on Google Analytics web site.

1.6 Social media widgets and applications

Customs Knowledge web sites may include functionality to enable sharing via third party social media applications, such as LinkedIn.

2. Sharing and transfer of personal information

We share information about you with other member firms of the Customs Knowledge network as part of international engagements, and other member firms where required or desirable to meet our legal and regulatory obligations around the world. Other parts of the Customs Knowledge network are also used to provide services to us and you, for example provision of certain forms of insurance for member firms and its clients, performing client conflicts checks and Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run Customs Knowledge’s business.

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. In addition, Customs Knowledge will transfer certain personal information outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. If we do this your personal information will continue to be protected by means of contracts we have in place with those organizations outside the EEA, containing standard data protection clauses which are in a form approved by the European Commission.

Customs Knowledge will not transfer the personal information you provide to any third parties for their own direct marketing use.

3. Choices

In general, you are not required to submit any PII to Customs Knowledge online, but we may require you to provide certain PII in order for you to receive additional information about our services and events. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in "Cookies" above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

4. Your rights

If Customs Knowledge processes personal information about you, you have the following rights:

• Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.
• Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more.
• Other Rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.

You can make a request or exercise these rights by contacting Customs Knowledge at info@customsknowledge.nl and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

5. Data security and integrity

Customs Knowledge has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite Customs Knowledge's best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual's request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected.

6. Links to other sites

Please be aware that Customs Knowledge web sites will typically contain links to other sites, including sites maintained by other Customs Knowledge member firms that are not governed by this Privacy Statement, but by other privacy statements that will often differ somewhat. We encourage users to review the privacy policy of each web site visited before disclosing any personal information.

7. Changes to this statement

Customs Knowledge may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the "updated" date at the top of this page. Any changes to the processing of personal information as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

8. Policy questions and enforcement

Customs Knowledge is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at info@customsknowledge.nl. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

In any event, you always have the right to lodge a complaint with the Dutch regulator in charge of protecting personal information, the Dutch Data Protection Authority / De Autoriteit Persoonsgegevens (AP).