Privacy Policy

Introduction

TPA Global is committed to safeguard the privacy and confidentiality of data TPA Global is entrusted with. Therefore, TPA Global strives to ensure the protection and correct use of your personal information that identifies you or makes you identifiable (referred to as “personal data”).

This Privacy Statement mainly concerns the TPA Global website and online applications. By means of this Privacy Statement, TPA Global informs its website visitors and users of the TPA Global services on the manner in which personal data is handled by TPA Global. In general, TPA Global solely collects personal data if you voluntarily provide this in order to enable us to provide information and/or services to you. This Privacy Statement informs you on the collection, use, disclosure and protection of personal data by TPA Global.

1. Collection and use of personal data

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 TPA global (for example if you are a client or former client).

You can register or login to a TPA Global website using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., TP Genie, GoToWebinar, social media etc) with TPA Global. If you choose to use this option, we will collect any information or content needed for the registration or login, such as your name and e-mail address. Other information we collect will depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.

When you register or submit personal information to TPA Global 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, or to optimize the quality of our services and to inform you about other services of TPA Global.

We will, for example, use the information regarding your preferences that you provided to us to personalize your user experience. Or, if you request us per e-mail to provide information about TPA Global, we will use your e-mail address and other information you provide to us to respond to such request. If you send us a resume or curriculum vitae (CV) to apply online for a position with TPA Global, we will use the information that you provide to match you available TPA Global job opportunities. We will keep your resume and other application information no longer than 4 weeks if we do not hire you.

1.2 The legal grounds we have to use your personal information

TPA Global generally only collects 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 privacy legislation, including the General Data Protection Regulation (“GDPR”) allows us to process personal information, so long as we have a ground (pursuant to the GDPR) to do so. If we process your personal data, we will rely on one of the following processing conditions:

  • Processing of your personal data is necessary in order to perform our obligation under a contract to which you are party.
  • Processing of your personal data is necessary 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.
  • Processing of your personal data is in TPA Global’s legitimate interest. This processing is allowed as long as this does not outweigh your interests. Legitimate interests includes for example processing for the purposes of: 1) marketing; and 2) acquisition (sales) with regard to clients with whom we have a commercial relationship; 3) customer relationship management & account management; optimizing and/or personalizing content and 5) maintaining and optimizing effective business operations.
  • You have provided specific and explicit consent for the processing of your personal data for a specific purpose. For example for the receipt of content per e-mail for marketing purposes, including invitations for events organized buy TPA Global. We will only process your personal data in this way if you agree to us doing so.

You may withdraw your consent at any time via the link that will be included in every e-mail that we send you with that regard, by logging in to our website or by contact TPA Global at info@tpa-global.com.

Special categories of personal data will only be collected if you voluntarily provide these to us or if this is required or permitted by law. Special categories of personal data are i.a. data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership, data about sexual life and sexual orientation and health data. We ask you to only provide special categories of personal data to TPA Global if you consent to processing thereof by TPA Global. If you have any questions on the provision of special categories of personal data to TPA Global, please contact TPA Global via info@tpa-global.com

1.3 Automatic collection of personal data

TPA Global uses cookies and other technologies to automatically collect certain types of information when you visit us online and/or if you use our online services. The collection of thee data enables us to improve the performance, usability and effectiveness of TPA Global’s online presence, to customize your online experience and to measure the effectiveness of our marketing activities.

1.3.1 IP addresses

An IP address is a number assigned to our computer whenever you access the internet. IP addresses will be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct website trend and performance analysis, in which case information will not be processes on individual (identifiable) level.

1.3.2. Cookies

A “cookie” is a small text file that is placed by a website in the browser of the device you use to visit the website (for example a computer or smartphone). This enables the website to recognize your device. Cookies are used for various purposes.

In general we assume that no cookies will be used, or that the use does not cause an (significant) infringement on the rights and freedoms of website visitors and the users of TPA Global’s services. Therefore, it is not required to obtain explicit consent for cookies used on our websites or the use of these cookies is modified in such way that these are allowed. This is done, inter alia, by anonymizing IP addresses. Some cookies are required for necessary functionality of the website. These ‘functional’ cookies will not be blocked by the use of the cookie banner and no consent is required for the use of these functional cookies.

Via your browser’s setting you can configure your browser to notice you on the receipt of a cookie or to refuse cookies. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our websites’ features.

Below is a list of the types of cookies used on our websites.

Purpose Description Type & Expiry
Security (e.g. Asp.NET) Our website is built using common internet platforms. These have built-in cookies which help compatibility issues (e.g. to identify your browser type) and improve performance (e.g. quicker loading of content) Session

Deleted upon closing the browser.

Analytical We use several third party analytical tools to help us understand how site visitors use our website. This allows us to improve the quality and content in tpa-global.com for our visitors. Information collected is: IP address, number of unique visitors, search terms, location (land code) of visitor, date, duration and frequency of visit, used hardware, browser type, marketing campaign data. Persistent

Deleted automatically after three years if you no longer visit the TPA Global website.

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

1.3.3 Google Analytics

TPA Global uses Google Analytics. More information about how Google Analytics is used by TPA Global can be found here.

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate the information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-Out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

1.4 Children

TPA Global understands the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 16. It is our policy never to knowingly collect or maintain information about anyone under the age of 16, except as part of an engagement to provide professional services.

2. Sharing and transfer of personal information

We do not share personal data with third parties, unless this is necessary in order to carry out you request, for our professional or legitimate business needs or as required or permitted by law, professional standards. For example, TPA Global, may, in some instances, share your personal data with third parties or service providers engaged by TPA Global, in order to carry out your requests.

In the following circumstances, TPA Global shares personal data with third parties:

  • Registrations with regard to events organized by TPA Global;
  • Optimizing and/or personalizing content on our websites;
  • Effective business operations;

In all circumstances above, appropriate arrangements will be made with these parties in order to ensure a correct and secure data processing in compliance with applicable legislation. Furthermore, TPA Global may share personal data with other TPA Global member firms or third parties abroad with who we collaborate or who provide services for and on behalf of TPA Global (further: TPA Global Members).

TPA Global may process personal data with regard to the assignment of services which include personal data processing. Legal obligations, court orders or government decrees may also require TPA Global to disclose personal data. Personal data may also be required to perform privacy- or security audits or to invest a complaint. TPA Global does not sell personal data to third parties. TPA Global will not transfer the personal data you provide to any third parties for their own direct marketing use.

3. Choices

You have several choices with regard to use of our online services (including website). In general, you are required to submit any personal data to TPA Global online. However, TPA Global may require you to provide certain personal data in order for you to receive additional information about our services and events. TPA Global may also ask for your permission for certain uses of your personal data, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as e-newsletter, you will be able 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 TPA Global processes personal data about you, you have, in most cases, the right to access this personal data and to correct possible inaccuracies. You can request us for access. 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 inaccuracies in the personal information.

You have the right to object to us processing your personal information if we are not entitled to use it anymore, and furthermore, you have the right to have your personal data deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or obtain copies of information we hold about you in electronic form.

You can make a request or exercise these rights by contracting TPA Global at info@tpa-global.com 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. TPA Global strives to follow up a request within the legal time frame of one month. Where the request is complex or we have a large volume of requests, we will notify you that it will take longer than one month to resolve, and we will seek to resolve your request within three months of the concern being first raised. You will be informed on such extension within one month. It may also occur that we do not need to follow up a request, for example if we have legal ground to process your personal data. If this would be the case, this will be substantiated to you.

5. Data security and integrity

TPA Global has reasonable security policies and procedures in place to protect personal data from unauthorized loss, misuse, alteration, or destruction. Despite TPA Global’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal data 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 data.

We also make reasonable efforts to retain personal data only for so long as the data is necessary to provide services to you, we are legally entitled to retain data or until you ask us to delete your personal data. The personal data that you provide to us for the purposes of 1) marketing; 2) acquisition (sales); 3) customer relationship management & account management; 4) optimizing and/or personalizing content and 5) maintaining and optimizing effective business operations, we apply standard retention of 1 year upon ending of the contract or relation, unless explicitly informed otherwise. The standard retention period takes effect whenever your personal data are no longer actively used by you or TPA Global.

The retention period consists of two parts:

  1. Within 3 months after the retention period has taken effect, your personal data will be archived, meaning that they may no longer actively be used for said purposes;
  2. Within 12 months after the retention period has taken effect, your personal data will effectively be deleted (this includes deletion from underlying systems, used for e.g. report and back-up purposes). If during this retention period your personal data is actively used by you or TPA Global for said purposes, for example if you register an update on your personal data, the archiving- and delete process is stopped.

6. Links to other sites

Please be aware that TPA Global websites will typically contain links to other sites, including sites maintained by other TPA Global 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 website visited before disclosing any personal information.

7. Changes to this statement

TPA Global may modify this Privacy Statement from time to time reflect our current privacy practices. When we make changes to this statement, we will revise the “ updated” date at the top of this page. We encourage to regularly review this Privacy Statement.

8. Policy questions and enforcement

TPA Global is committed to protecting the online privacy of your personal information. If you have questions or comments about the processing of your personal data, please contact us at info@tpa-global.com. 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 Persoonsgegevns (AP). Throughout this website, “TPA Global”, “we”, “our” and “us” refers to Transfer Pricing Associates B.V. and TPA Global are registered with the trade register in the Netherlands under number 34186801.

TPA Global is committed to safeguard the privacy and confidentiality of data TPA Global is entrusted with. Therefore, TPA Global strives to ensure the protection and correct use of your personal information that identifies you or makes you identifiable (referred to as “personal data”). This Privacy Statement mainly concerns the TPA Global website. By means of this Privacy Statement, TPA Global informs its website visitors and users of the TPA Global services on the manner in which personal data is handled by TPA Global. In general, TPA Global solely collects personal data if you voluntarily provide this in order to enable us to provide information and/or services to you. This Privacy Statement informs you on the collection, use, disclosure and protection of personal data by TPA Global.

Headquarters
H.J.E Wenckebachweg 210
1096 AS Amsterdam