Privacy Statement

19 August 2026

1. Purpose and Contact Details

1.1 Purpose

This Privacy Statement explains how Janus Law (hereinafter: Janus, we, us) processes personal data. It describes:

• Which personal data we collect and process;

• Why and on which legal bases we process it;

• How we protect it;

• With whom we may share it;

• How long we retain it; and

• What rights individuals have under the General Data Protection Regulation (“GDPR”).

Janus recognizes that immigration, mobility, nationality, family-migration, human-rights, and conflict-related matters can involve highly sensitive information. We aim to collect only information that is necessary, process it carefully, and use appropriate technical and organisational safeguards.

1.2 Controller

The controller responsible for processing personal data is:

Janus Law
Sole proprietorship (eenmanszaak)
KvK number: 42129724
Business address:

Bankastraat 4
2585 EN The Hague, The Netherlands
Email: info@januslaw.nl
Telephone: 0645126854
Website: www.januslaw.nl

Janus is operated by O.A. Hamed, immigration-law jurist and founder.

1.3 Contact

If you have questions, concerns, or requests regarding this Privacy Statement or Janus’s processing of personal data, contact the controller above. Janus is not currently required to appoint a Data Protection Officer and has not appointed one. If this changes, this Privacy Statement will be updated.

2. Applicability

This Privacy Statement applies when you:

• Visit our Website;

• Contact Janus by email, phone, website form, social media, or another channel;

• Request a consultation or provide instructions for legal services;

• Become a client, representative, employee, intern, volunteer, supplier, referrer, partner, or event participant;

• Register for a workshop, training, webinar, or newsletter;

• Communicate with Janus in connection with a legal, research, advisory, or project matter; or

• Otherwise interact with Janus.

This Privacy Statement does not replace any case-specific confidentiality, data-processing, or engagement agreement that Janus may provide.

3. Data We Process

Depending on the context, Janus may process the following categories of personal data.

3.1 Website and technical data

When you visit the Website, Janus and its service providers may process:

• IP address;

• Device, browser, operating-system, and language settings;

• Approximate location derived from IP address;

• Website pages viewed, date and time of visit, referral source, and interaction data;

• Cookie and consent preferences;

• Technical logs needed to operate, secure, and improve the Website.

3.2 Inquiries and prospective-client data

When you contact Janus or request information, we may process:

• Name, email address, phone number, address, country, and preferred language;

• Organisation, employer, job title, or professional role;

• The content of your inquiry, meeting request, correspondence, and attachments;

• Information about the legal, migration, mobility, policy, or research issue for which you seek assistance;

• Records of communications and meetings;

• Information needed to assess capacity, conflicts of interest, scope, urgency, and whether Janus can assist.

3.3 Client and case-file data

If Janus accepts an engagement, we may process:

• Identity, contact, communication, and billing details;

• Information necessary to provide the agreed legal, advisory, research, or training services;

• Case history, legal position, procedural information, deadlines, correspondence, advice, draft documents, evidence, submissions, and authority decisions;

• Payment, invoice, and accounting information;

• Information necessary to identify the client, verify authority, prevent fraud, comply with sanctions, or manage conflicts of interest;

• Notes made during meetings, consultations, calls, or communications.

3.4 Data about family members and other third parties

Migration, human rights, and conflict-related matters often concern people other than the client. Janus may therefore process data concerning:

• Family members, partners, children, sponsors, employers, colleagues, employees, former employers, landlords, educational institutions, referees, witnesses, interpreters, translators, and other persons involved in a matter;

• Government officials, decision-makers, legal representatives, opposing parties, and professional advisers;

• Persons whose information is included in evidence or correspondence supplied to Janus.

Where you provide Janus with another person’s personal data, you are responsible for ensuring that you have a lawful basis to do so and, where appropriate, that you have informed them about the disclosure.

3.5 Evidence and immigration-document data

For migration, human-rights, and related matters Janus may process documents and evidence such as:

• Passports, identity cards, residence documents, visas, work permits, and citizenship records;

• Birth, marriage, divorce, death, guardianship, and civil-status certificates;

• Employment contracts, payslips, tax information, employer letters, bank statements, proof of income, business records, and accommodation evidence;

• Diplomas, CVs, qualifications, references, and education records;

• Communications with the IND, municipalities, embassies, consulates, courts, employers, educational institutions, NGOs, and other bodies;

• Photos, videos, travel information, location information, social-media material, and other evidentiary material where relevant to the Matter.

3.6 Special-category and highly sensitive data

A migration, human-rights, or conflicts related matter may involve special-category data or otherwise highly sensitive personal information. This may include information concerning:

• Racial or ethnic origin;

• Religion or philosophical beliefs;

• Political opinions;

• Trade-union or political membership;

• Health, disability, medical treatment, or psycho-social circumstances;

• Biometric data used for identification;

• Sexual orientation or sex life;

• Criminal allegations, criminal convictions, or security-related information;

• Asylum narratives, experiences of conflict, persecution, violence, torture, trafficking, discrimination, or other trauma.

Janus asks you not to submit highly sensitive documents through an ordinary Website contact form, social-media message, or un-encrypted email unless Janus has specifically instructed you to do so. If Janus accepts your matter, we will explain the safest available method for sharing documents.

3.7 Events, training, and newsletter data

If you register for an event, training, webinar, mailing list, or newsletter, Janus may process:

• Name and contact details;

• Organisation and role;

• Registration, attendance, access, dietary, or accessibility information where relevant;

• Feedback and evaluation information;

• Consent and unsubscribe records.

3.8 Suppliers, partners, interns, and job applicants

Janus may process personal data relating to:

• Suppliers, contractors, collaborators, referrers, and professional partners;

• Internship applicants, volunteers, and job applicants;

• CVs, application letters, references, work-permit/right-to-work information, interview notes, and correspondence.

4. Why we use personal data

Janus processes personal data for the following purposes:

• Responding to inquiries, meeting requests, and requests for information;

• Assessing whether Janus can accept an engagement, including conflict, capacity, safety, and scope assessments;

• Delivering agreed immigration-law, legal-advisory, research, training, and project-support services;

• Communicating with clients, authorized representatives, public authorities, and relevant third parties;

• Preparing advice, legal analysis, applications, submissions, supporting documents, research outputs, contracts, invoices, and project documentation;

• Managing appointments, consultations, workshops, webinars, and events;

• Invoicing, bookkeeping, payment administration, and compliance with Dutch tax obligations;

• Securing our Website, digital systems, records, and services;

• Improving Janus’s Website, services, accessibility, communications, and client experience;

• Sending newsletters, invitations, or professional updates where you have consented or where permitted by law;

• Establishing, exercising, or defending legal claims;

• Preventing fraud, misuse, conflicts of interest, sanctions breaches, or other unlawful activity;

• Meeting legal, regulatory, professional, insurance, and contractual obligations;

• Recruiting staff, interns, volunteers, contractors, and professional collaborators.

5. Legal bases for processing

Janus processes personal data only where the GDPR permits us to do so. Depending on the situation, we rely on one or more of the following legal bases.

5.1 Contract and pre-contractual steps

We process personal data where this is necessary to take steps at your request before entering into an agreement, or to perform an agreement with you. This includes assessing an inquiry, providing a consultation, delivering agreed services, communicating about a matter, invoicing, and managing the client relationship.

5.2 Legal obligations

We process personal data where necessary to comply with legal obligations, including tax, accounting, record-keeping, sanctions, anti-fraud, and other obligations that may apply to Janus.

5.3 Legitimate interests

We may process personal data where necessary for Janus’s legitimate interests, provided those interests are not overridden by your rights and freedoms. These interests include:

• Managing professional inquiries and client relationships;

• Protecting Janus, clients, and others from fraud, abuse, conflicts, or security incidents;

• Maintaining appropriate business, financial, and case records;

• Improving our Website, services, and professional communications;

• Establishing, exercising, or defending legal claims;

• Maintaining a professional network and communicating with existing contacts, where permitted by law.

5.4 Consent

We rely on consent where required, including for non-essential cookies, marketing communications, or particular uses of personal data where consent is appropriate. You may withdraw consent at any time. Withdrawal does not affect processing that took place before withdrawal or processing based on another legal ground.

5.5 Special-category and criminal data

Where Janus processes special-category data or data relating to criminal convictions or offences, we will do so only where a valid condition applies under Article 9 GDPR and, where relevant, Article 10 GDPR. Depending on the context, this may include:

• Your explicit consent;

• The establishment, exercise, or defense of legal claims;

• Reasons of substantial public interest under applicable law;

• Protection of vital interests where you are physically or legally incapable of giving consent;

• Another lawful basis or condition applicable to the specific Matter.

Janus will seek to minimize the collection and use of sensitive data. We may refuse to accept or retain information that is not necessary, cannot be handled safely, or cannot be processed lawfully.

6. Cookies, Squarespace, and online services

6.1 Squarespace

The Janus Website is hosted on Squarespace. Squarespace may process technical and website-usage information to host, secure, operate, and support the Website. Depending on the configuration of the Website, Squarespace may also provide website analytics.

Squarespace may process personal data internationally. Where data is transferred outside the European Economic Area, we seek to ensure that appropriate safeguards are used, such as an adequacy decision, standard contractual clauses, or another lawful transfer mechanism.

6.2 Cookies

Janus uses cookies and similar technologies. Some are strictly necessary for the Website to function, while others may support analytics, functionality, or marketing.

Where required by law, we will request your consent before placing non-essential cookies. You can accept, reject, or adjust non-essential cookie choices through Cookie Preferences in the Website footer.

For more information, please read the Janus Cookie Policy.

6.3 Contact forms and scheduling

If you use a contact form, booking tool, or scheduling function, the information you provide will be used to respond to your request and manage the appointment. Do not use these tools to send passports, residence permits, medical evidence, asylum narratives, criminal-record documents, or other highly sensitive materials unless Janus expressly asks you to do so.

6.4 Social media

Janus may use social-media platforms such as LinkedIn, Instagram, and X to share general information. Social-media platforms operate under their own privacy terms and may process information outside Janus’s control.

Do not send detailed case information or sensitive documents through social-media channels. If you contact Janus through social media, we may reply with general information and ask you to use a more secure channel for any substantive matter.

7. Who we may share data with

Janus does not sell personal data. We may share personal data only where necessary and lawful with:

• The client and persons formally authorized by the client;

• The IND, municipalities, embassies, consulates, courts, tribunals, government bodies, and other authorities where necessary for a Matter;

• Employers, sponsors, educational institutions, family members, interpreters, translators, experts, and other relevant parties, but only where necessary and appropriately authorised;

• Attorneys (advocaten), external jurists, tax advisers, accountants, mediators, notaries, experts, and other professional advisers where referral or specialist input is necessary;

• IT, website-hosting, secure-cloud-storage, email, document-management, scheduling, accounting, invoicing, payment, cybersecurity, and backup providers;

• Insurers, banks, payment providers, debt-collection agencies, auditors, and professional advisers;

• Regulators, public authorities, law-enforcement bodies, courts, or other parties where disclosure is required by law or necessary to establish, exercise, or defend legal claims;

• A successor or prospective successor to Janus in the event of a merger, restructuring, transfer, or sale, subject to confidentiality safeguards.

Where a provider processes personal data on Janus’s behalf, we aim to use a written data-processing agreement where required.

8. International transfers

Janus may need to transfer personal data outside the European Economic Area where this is necessary for a Matter. This may arise, for example, in communications with a non-EEA employer, embassy, consulate, educational institution, overseas authority, international organisation, or client.

Where a transfer is required, Janus will use an appropriate legal transfer mechanism where necessary, such as:

• A European Commission adequacy decision;

• Standard Contractual Clauses;

• Another safeguard or derogation permitted under the GDPR.

Janus will consider these risks and use proportionate safeguards. If a transfer is necessary for your Matter, Janus may provide additional information in the engagement letter or during the case.

9. Security measures

Janus takes appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorized access, disclosure, alteration, or destruction. Depending on the system and sensitivity of the data, our safeguards may include:

• Role-based access restrictions;

• Strong passwords and multi-factor authentication;

• Encryption in transit and, where appropriate, at rest;

• Secure cloud storage and backup arrangements;

• Device security, software updates, anti-malware measures, and security monitoring;

• Confidentiality obligations for persons working with Janus;

• Processor agreements with relevant service providers;

• Data-minimization and retention practices;

• Incident-response procedures.

No system or online transmission can be guaranteed completely secure. Janus will take reasonable steps to address a security incident and, where required by law, notify the Dutch Data Protection Authority and affected individuals.

10. Retention periods

Janus retains personal data only for as long as necessary for the relevant purpose, subject to legal obligations, professional needs, insurance requirements, and the need to establish, exercise, or defend legal claims.

At the end of the relevant period, Janus will securely delete, anonymize, or destroy personal data unless further retention is necessary or permitted.

11. Your privacy rights

Subject to the GDPR and applicable limitations, you may have the right to:

• Request access to your personal data;

• Request correction of inaccurate or incomplete data;

• Request deletion of data in certain circumstances;

• Request restriction of processing in certain circumstances;

• Object to processing based on legitimate interests;

• Withdraw consent at any time where consent is the basis for processing;

• Receive data you provided to Janus in a structured, commonly used, machine-readable format, or ask us to transfer it to another controller where technically feasible;

• Object to direct marketing at any time;

• Receive information about automated decision-making, where applicable.

To make a request, contact Janus at info@januslaw.nl. We may need to verify your identity before responding. We normally respond within one week, although the GDPR allows more time for complex requests.

Please note that some rights are not absolute. For example, Janus may need to retain records to comply with legal obligations, protect the rights of others, preserve evidence, or establish, exercise, or defend legal claims.

12. Complaints

If you have concerns about the way Janus handles your personal data, please contact us first at: info@januslaw.nl

You also have the right to lodge a complaint with the Dutch supervisory authority:

Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ The Hague
The Netherlands
www.autoriteitpersoonsgegevens.nl

13. Changes to this statement

Janus may update this Privacy Statement when our services, systems, Website, legal obligations, or data-processing practices change. The most recent version will be published on this page with an updated “Last updated” date.