Privacy Statement

Effective 21 July 2026

This statement explains how HALD Advisory handles personal data received through this website, by email and during initial business enquiries. Separate engagement terms and agreed data-handling arrangements apply after HALD accepts an engagement.

1. Who is responsible for your personal data?

The controller is Aldwin Boers, trading as HALD Advisory, based in Amsterdam, the Netherlands.

For privacy questions or to exercise your rights, email info@haldadvisory.com with “Privacy” in the subject line.

2. What personal data may HALD receive?

HALD may receive:

• identity and business contact details, including your name, organisation, role, business email address and telephone number;
• initial matter-screening details, including the matter type, jurisdiction, decision deadline and the names of relevant parties supplied for a conflict and independence check;
• correspondence and non-confidential scoping information you choose to provide;
• limited technical information generated when you visit the website, such as IP address, request time, browser type and security logs; and
• engagement information and records provided after an engagement has been accepted, subject also to the written engagement terms and agreed data-handling arrangements.

If you provide personal data about another person, provide only what is necessary and ensure that you are permitted to share it.

3. Please do not send sensitive material at the enquiry stage

Do not send privileged advice, detailed evidence, financial records, models, identity documents, special-category personal data or information about criminal allegations through the public assessment page or an initial email.

At the enquiry stage, HALD needs only enough information to assess fit, timing and potential conflicts. If the matter can proceed, HALD will agree an appropriate secure transfer route before detailed or sensitive material is shared.

4. Why does HALD process personal data?

HALD processes personal data for the following purposes and legal bases:

Enquiries and pre-engagement steps

To respond to your enquiry, assess fit and urgency, discuss scope and take steps at your request before entering into an engagement. The legal basis is taking pre-contractual steps or performing a contract. Where you act for an organisation rather than in your own name, HALD also relies on its legitimate interest in managing the prospective business relationship.

Conflict and independence checks

To identify relevant parties, protect HALD's independence and avoid incompatible engagements. The legal basis is HALD's legitimate interest in maintaining professional independence and sound governance.

Accepted engagements

To deliver the agreed services, communicate with the client team, manage the engagement and meet the written engagement terms. The legal basis is performance of a contract or, for business contacts acting for a client organisation, HALD's legitimate interest in performing and administering the engagement.

Administration and legal obligations

To maintain financial and business records, issue invoices, comply with tax and other legal duties and respond to competent authorities where required. The legal basis is compliance with legal obligations.

Security, risk management and legal claims

To protect HALD's systems and information, investigate security incidents, maintain appropriate records and establish, exercise or defend legal claims. The legal basis is HALD's legitimate interest in operating securely and protecting its legal position.

HALD does not use personal data for solely automated decision-making or profiling. Submitting an enquiry does not add you to a marketing list.

5. Is information required?

You are not legally required to provide personal data when making an initial enquiry. HALD may, however, be unable to assess or respond to the matter without your name, contact details, the relevant party names and a short non-confidential description of the decision required.

6. Who may receive personal data?

Access is limited to people who need the information for the relevant purpose. This may include:

• HALD personnel and instructed specialists subject to appropriate confidentiality obligations;
• providers of website hosting, business email, secure file transfer, data storage, document management and IT or security support;
• legal, tax, accounting, insurance and other professional advisers; and
• courts, regulators, law-enforcement bodies or other authorities where disclosure is required or permitted by law.

Service providers may process personal data only for the agreed service and under appropriate contractual, confidentiality and data-protection safeguards. HALD does not sell personal data.

7. International transfers

Some service providers may process personal data outside the European Economic Area. Where this happens, HALD uses a lawful transfer mechanism, such as an adequacy decision of the European Commission or approved Standard Contractual Clauses, together with supplementary safeguards where appropriate.

You may request information about the applicable transfer safeguard, or a copy of it where available, by emailing info@haldadvisory.com.

8. How long does HALD keep personal data?

HALD keeps personal data only for as long as it is needed for the stated purpose and then deletes or anonymises it, unless a longer period is required by law or is necessary for a legal claim or documented hold.

• Enquiries that do not become engagements: up to 12 months after the last substantive contact.
• Minimal conflict and independence records: up to seven years after the check, or seven years after the related engagement closes if the matter is accepted. These records are limited to what is reasonably needed to identify the parties, the date and the outcome of the check.
• Accepted engagement files and related correspondence: normally seven years after the engagement closes, unless the engagement terms or a legal requirement justify a different period.
• Invoices and core financial administration: seven years, in line with Dutch tax record-keeping requirements.
• Website security and server logs controlled by HALD: no longer than 30 days, unless a longer period is necessary to investigate a security incident or comply with law.

9. Your rights

Depending on the circumstances, you may have the right to:

• access your personal data;
• correct inaccurate or incomplete personal data;
• request deletion or restriction of processing;
• object to processing based on legitimate interests;
• receive personal data you provided in a portable format where the legal conditions apply; and
• withdraw consent at any time where consent is the legal basis, without affecting earlier lawful processing.

To exercise a right, email info@haldadvisory.com with “Privacy” in the subject line. HALD may request information needed to verify your identity and will respond without undue delay, normally within one month. A legal duty, confidentiality obligation or the need to establish, exercise or defend legal claims may limit a request in specific circumstances.

You may also lodge a complaint with the Autoriteit Persoonsgegevens, the Dutch supervisory authority. HALD would appreciate the opportunity to address your concern first.

10. Cookies and website analytics

At the effective date of this statement, the website does not use analytics, advertising cookies or tracking pixels and HALD does not set cookies. The hosting service may create limited server and security logs as described above.

If HALD later introduces analytics, embedded media or another non-essential technology, this statement and any required consent mechanism will be updated before that technology is enabled.

11. Security

HALD applies technical and organisational measures proportionate to the nature and sensitivity of the information. These include restricting access, using controlled accounts and devices, agreeing secure transfer routes for engagement material and managing retention and disposal.

No method of transmission or storage is completely secure. Please follow the intake instructions and do not send sensitive material until HALD has confirmed an appropriate route.

12. Changes to this statement

HALD may update this statement when its services, suppliers or processing activities change. The current version and effective date will be published on this page.

Current version: 1.0, effective 21 July 2026.