Privacy notice

I. Introduction

Below you will find the privacy notice of Axon Lawyers. In order to provide its services, Axon Lawyers processes personal data. Personal data is any information relating to an identified or identifiable natural person. All personal data is processed with the greatest possible care and with due observance of the European General Data Processing Ordinance (GDPR), as well as applicable national laws and regulations.

In this document Axon Lawyers describes its privacy policy that applies to external parties. This privacy notice consists of a general part and a specific part to the various external parties of which Axon Lawyers processes personal data.

II. General part

A. Controllers

The following parties process your personal data in the capacity of joint controllers:

  • Praktijkvennootschap Carine van den Brink B.V. (KvK: 34297647),
  • Erik Vollebregt Legal Services B.V. (KvK: 58563512) of
  • de maatschap Axon Advocaten (KvK: 53846745).

All three of the aforementioned controllers are established at the Piet Heinkade 183 te Amsterdam (1019HC). These three controllers are hereinafter jointly referred to as “Axon Lawyers”.

B. Sharing of personal data with third parties

In the execution of its activities, Axon Lawyers involves both parties that process personal data (“processors”) on behalf of Axon Lawyers as well as parties that act as independent controllers of the processing data involved. Independent data controllers concern fellow lawyers in the context of a collaboration or a specific request for advice, counterparties, our accountant, judicial authorities, administrative bodies and supervisors.

Axon Lawyers uses the services of the following regular processors:

  • Basenet
  • Mailchimp
  • Eventbrite

In addition, Axon Lawyers makes incidental use of the services of translators, couriers and bailiffs. Axon Lawyers enters into a processing agreement with all processors it engages.

Processing outside the EEA
To the extent that processors are located outside the European Economic Area (“EEA”), Axon Lawyers ensures that transfers of personal data take place only under strict safeguards. Mailchimp, Eventbrite and Code42 are all certified under the EU-US Privacy Shield (adequacy decision). This means that the European Commission has judged that these US parties adequately protect your privacy.

C. Automated processing

All personal data that are processed in connection with the activities of Axon Lawyers are included in a digital CRM system hosted by BaseNet Internet Services B.V. These personal data are processed automatically.

D. Security of the personal data

Axon Lawyers takes the protection of personal data seriously and takes appropriate measures for the legal profession to prevent abuse, loss, unauthorized access, unwanted disclosure and unauthorized changes.

Axon Lawyers is not responsible for information sent to Axon Lawyers and/or its employees via unsafe networks.

E. Exercise of the rights of data subjects

Under the GDPR, data subjects have a number of rights with regard to personal data relating to them:

  • The right of access
  • The right of rectification
  • The right of removal
  • The right to limit the processing of personal data concerning him or her
  • The right to data portability
  • The right to object to processing

If processing, as described in this privacy notice, takes place on the basis of consent, the data subject has the right to withdraw his or her consent to the processing of personal data concerning him or her. This has no consequences for processing that took place prior to the revocation of that consent. The personal data that Axon Lawyers has processed up to that moment will be removed, unless another processing basis is applicable to the processing that justifies the storage of the personal data.

If you do not agree with the way in which Axon Lawyers processes your personal data or if you have any questions about the processing of your personal data or this privacy notice, we kindly request you to contact your contact person at Axon Lawyers or our complaints officer via complaints@axonlawyers.com. If we are unable to resolve this issue, or if you prefer not to discuss your complaint with us, you have at all times the right to contact the Dutch Personal Data Authority (Autoriteit Persoonsgegevens), the Dutch supervisory authority.

F. Opt-out marketing

The data subject has the right to object at any time to the use of his or her personal data for marketing purposes, which means receiving newsletters and/or invitations. Unsubscribing is possible by using the link at the bottom of the newsletters/invitations or by sending an e-mail to info@axonadvocaten.nl.

III. Specific part

Axon Lawyers processes personal data of various external persons, namely:

  • (former) clients and involved parties
  • external experts;
  • potential clients who use question time;
  • participants in seminars organised by Axon Lawyers;

For each category of data subjects, it will be explained below which personal data are processed, on which processing basis the processing takes place, which processing purposes apply to the processing and which retention periods are applicable. The specific section on the processing of applicant’s personal data can be found on our careers page.

(Former) Clients and data subjects

Personal data
Axon Lawyers processes the following personal data of its clients (or their representatives/contact persons) and other parties involved in a client case:

  • surname;
  • first names;
  • gender, in order to use the correct title;
  • address (work, unless it concerns a private person);
  • telephone numbers
  • function;
  • e-mail address;
  • company/employer;
  • domain name;
  • Relationship or contact number assigned by Axon Lawyers;
  • information provided to it by third parties, including counterparties, insofar as this holds relevance to the performance of the services;
  • account numbers, in connection with the payment of settlements, orders to pay legal costs and necessary other payments arising from the services provided by Axon Lawyers to its clients;

Where we are legally obliged to do so under the Counter Terorrism and Anti-Laudering Act (in Dutch: “Wet ter voorkoming van witwassen en financieren van terrorisme”) or the Regulation on the Legal Profession (in Dutch: “Verordening op de Advocatuur”), Axon Lawyers will process a copy of the ID of the client or his director/representative. Axon Lawyers requests clients to send a copy of their passport without a citizen service number and therefore does not process the citizen service number.

Processing purposes
Axon Lawyers processes the aforementioned personal data of its clients and contact persons/directors at clients for the following purposes:

  • the provision of legal services to its clients and the invoicing thereof,
  • the performance of an agreement between Axon Lawyers and its clients,
  • compliance with the legal and professional obligations incumbent upon Axon Lawyers;
  • compliance with the requirements of our professional liability insurance;
  • mediating and settling complaints;
  • to the extent necessary, conducting legal proceedings.
  • Marketing and communication activities.

Legal bases of the processing
Axon Lawyers only processes the personal data if:

  • Axon Lawyers has a legitimate interest for the processing, which is understood to mean the provision of services by Axon Lawyers to its clients, bringing the products and services of Axon Lawyers to the attention of the party concerned, as well as the legitimate interest Axon Lawyers has in running its firm (including compliance with insurance obligations and professional obligations);
  • the processing is necessary for the execution of an agreement that Axon Lawyers has concluded with the data subject;
  • Axon Lawyers must comply with a statutory obligation; or
  • the data subject whose data are being processed has given his consent for the processing;

Retention periods
Axon Lawyers shall not retain the collected personal data for longer than is strictly necessary to realise the purposes for which the data was collected, or for longer than retention is legally required. To this end, Axon Lawyers maintains the following retention periods for each processing purpose:

  • For personal data that have been processed for providing legal advice and/or conducting legal proceedings, a retention period of 20 years applies on the basis of the conditions that are imposed on Axon Lawyers by virtue of its professional liability insurance. The aforementioned term of 20 years shall apply from the moment a case is closed by the attending attorney-in-law. A case will be closed when the attending attorney-in-law is of the opinion that the client’s specific request for advice has been fulfilled and no further work can be expected in the case. The case shall be considered to have been closed from the moment a closing letter is sent to the client or from the moment that the client has the file transferred to another lawyer.
  • Personal data that are processed for marketing purposes (including personal data that are processed for the purpose of sending the newsletter and/or advertising) are kept for five years, unless the personal data are also processed for other purposes, for which a longer period is necessary.

Third parties
Personal data can be shared with:

  • the opposing party and/or its lawyer in the context of legal proceedings or negotiations;
  • Employees, contact persons or representatives designated by Axon’s clients;
  • External experts who are called in with the client’s permission in the context of a specific request for advice and with whom Axon Lawyers cooperates;
  • Judicial or administrative bodies;
  • Regulators;
  • The accountant of Axon Lawyers;
  • Processors engaged by Axon Lawyers to provide specific services.

External experts

Personal data
Axon Lawyers processes the following personal data of external experts:

  • surname;
  • first names;
  • gender, in order to use the correct title to address the expert;
  • company
  • work address
  • business e-mail address
  • business phone number and business mobile phone number
  • domain name
  • relationship or contact number assigned by Axon Lawyers;
  • account numbers, in connection with the payment of settlements, orders to pay legal costs and necessary other payments arising from the services provided by Axon Lawyers to its clients.

Processing purposes
Axon Lawyers processes the aforementioned personal data for the following purposes:

  • The provision of legal services to its clients, the execution of an agreement between Axon Lawyers and its clients and, where this forms part of the conduct of (legal) proceedings and the preparation and settlement of the consequences thereof;
  • Sending and collecting invoices in connection with work performed by Axon Lawyers;
  • Mutual advice and consultation and referral of clients;
  • To comply with the legal and professional obligations to which Axon Lawyers is subject;
  • Mediating in and resolving complaints;
  • To the extent necessary, conducting legal proceedings;
  • Participation in marketing and communication activities and dispatch of marketing communications of Axon Lawyers.

Legal bases of the processing
Axon Lawyers processes the personal data exclusively on the following legal basis:

  • a legitimate interest of Axon Lawyers, which is understood to mean the provision of services by Axon Lawyers to its clients, maintaining the Axon Lawyers supported network of life science lawyers and (informal) collaborations between the data subject and Axon Lawyers
  • the processing is necessary for the execution of an agreement that Axon Lawyers has entered into with the data subject.

Storage periods
Axon Lawyers will not keep the collected personal data for longer than is strictly necessary, or is legally regulated, to achieve the purposes for which the data was collected. To this end, Axon Lawyers applies the following retention periods for each processing purpose:

  • For personal data that have been processed for providing legal advice and/or conducting legal proceedings, a retention period of 20 years applies on the basis of the conditions that are imposed on Axon Lawyers by virtue of its professional liability insurance. The aforementioned term of 20 years shall apply from the moment a case is closed by the attending attorney-in-law. A case will be closed when the attending attorney-in-law is of the opinion that the client’s specific request for advice has been fulfilled and no further work can be expected in the case. The case shall be considered to have been closed from the moment a closing letter is sent to the client or from the moment that the client has the file transferred to another lawyer.
  • As long as the lawyer in question is part of the Life Sciences Alliance or can be regarded as a connection of Axon. This is assessed periodically;
  • The processing of personal data of external experts for other purposes is subject to a retention period of five years from the end of the informal cooperation, unless the informal cooperation is renewed.

Third parties
Personal data can be shared with:

  • A client of Axon Lawyers in the context of legal proceedings or negotiations;
  • Employees, contact persons or representatives designated by a client of Axon;
  • An external lawyer who, with the permission of Axon Lawyers’ client, is called in for a specific request for advice and with whom Axon Lawyers collaborates;
  • Judicial or administrative bodies;
  • Supervisors;
  • Processors engaged by Axon Lawyers to provide specific services.

Question Time

Axon Lawyers offers parties interested in the services of Axon Lawyers the opportunity to briefly become acquainted with Axon Lawyers and to explore whether Axon Lawyers is able to assist the party in question. In order to book a Question Time appointment, Axon Lawyers processes the following personal data:

  • Name;
  • E-mail address;
  • Telephone number.

This data will be processed on the basis of the legitimate interest of Axon Lawyers to carry out the Question Time appointment and, where necessary, provide follow-up.

Retention period
Axon Lawyers will not keep the collected personal data for longer than is strictly necessary, or is legally regulated, to achieve the purposes for which the data was collected. For question time Axon Lawyers uses a retention period of 1 year. Notwithstanding the foregoing, where the potential client decides to engage Axon Lawyers, any personal data pertaining to the Question Time appointment leads to an agreement, the Question Time data will be transferred to the file of the client in question and the retention time applicable to client cases shall apply accordingly.

Third parties
Personal data can be shared with:

  • Regulators; and
  • Processors engaged by Axon Lawyers to provide specific services.

Participants in Axon seminars

Axon Lawyers regularly sends its clients and other interested parties invitations to seminars. The seminars fulfil the role of network meetings within the life sciences sector. During these seminars, relevant developments are discussed. Axon Lawyers invites its contacts at clients for these seminars. Each invitation contains the possibility to unsubscribe for further invitations (the so-called ‘opt-out’). Other interested parties can also register to attend a seminar.

Personal data
Axon processes the name, job title, company name and e-mail address of the person who signs up for a seminar.

Processing basis
The personal data will be processed on the basis of the legitimate interest of Axon Lawyers to send its clients marketing and invitations and to facilitate the participation in the seminar. After registration for a seminar, the personal data will be processed on the basis of the legitimate interest of Axon Lawyers to invite the person concerned to further seminars. The data subject has the right to object to this processing at any time.

Based on the consent of the person involved, his personal data will be shared with other participants in the seminar. The processing of personal data is necessary for the purposes of the seminar.

Third parties
Axon Lawyers shares the name, job title and company name of the seminar participant with other seminar participants.

Axon Lawyers also shares the personal data with its processors.