Private Mental Health Care is a trading name of Private Addiction Care B.V. Legally, that B.V. is responsible for your data; in this regulation, it is referred to as Private Addiction Care.
This is the complete privacy policy of Private Addiction Care B.V. It describes how we handle personal data in our service provision — from initial contact through to ongoing support. You will also receive this document with the service agreement. If you would like to know in plain language what we collect on this website, please check the privacy policy; for cookies see the cookie policy.
Article 1: Definitions
- Personal data: any information relating to an identified or identifiable natural person.
- Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Private Addiction Care: The service provider Private Addiction Care B.V. that offers Services to the Client.
- Clients: the natural persons who commission or have commissioned Private Addiction Care.
- Third parties: persons who are not his clients and/or Private Addiction Care.
- Provision of Personal Data: the disclosing or making available of personal data.
Article 2: Legal framework and applicability
- Clients, suppliers, business partners and employees have the right to expect Private Addiction Care to handle their data with care. Private Addiction Care has developed a privacy policy that complies with the (European) General Data Protection Regulation (GDPR) and the Dutch GDPR Implementation Act (UAVG). Private Addiction Care's privacy policy is implemented in agreements, codes of conduct and (security) measures, among other things. Processing takes place primarily in EU data centres. Some processors are located outside the EEA. For these transfers, Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework are used.
- Private Addiction Care adheres to the principles for the processing of personal data as set out in privacy legislation. These are:
- Lawful, fair and transparent: The processing of personal data takes place in accordance with the legal requirements. Private Addiction Care handles your personal data with care and will inform you adequately about this.
- For legitimate purposes only: Personal data is processed by Private Addiction Care only for specific purposes and if there is a legal basis for doing so as set out in the GDPR.
- No more or longer than necessary: Private Addiction Care processes no more personal data than is necessary. If data are no longer required, they are removed in a controlled manner.
- Accurate, up-to-date and confidential: Private Addiction Care ensures that personal data is treated confidentially and periodically checks whether the personal data is still accurate and reliable. Employees of Private Addiction Care and others who process personal data on behalf of Private Addiction Care are bound by a duty of confidentiality.
- Appropriate technical and organisational security: Private Addiction Care has taken appropriate technical and organisational measures to secure personal data against unauthorised or unlawful processing, loss, damage or destruction, and also requires this from involved organisations such as suppliers.
Personal data will not be shared with family members, partners, employers, referrers or other involved parties, unless there is a legal basis for doing so or the Client has given prior explicit consent.
- These privacy regulations apply to the processing of all personal data provided to Private Addiction Care in any way.
- Private Addiction Care attaches the utmost importance to confidentiality and thus also the privacy of clients and third parties who have provided personal data to Private Addiction Care.
- The collection and processing of personal data takes place for the purpose of offering, organising, executing and improving the Services of Private Addiction Care, including guidance, coaching, support, consultation and advisory services.
- Private Addiction Care uses all personal data provided to it solely for the purposes set out in this privacy policy and complies with the applicable laws and regulations on the protection of personal data.
Article 3: Provision of personal data
- In order to use the services of Private Addiction Care, clients must provide the personal data required for Private Addiction Care's services. Providing is understood to mean disclosing or making personal data available.
- The personal data processed by Private Addiction Care in accordance with the law and in a proper and careful manner for specified, expressly described and legitimate purposes, originating from clients or third parties, includes, without limitation:
- name, address, postcode, town or city, telephone number(s), email address;
- personal details: date of birth, place of birth, gender, marital status, nationality;
- personal data relating to a person’s health;
- data relating to the services provided by Private Addiction Care, such as appointment details, session reports, recovery support, family counselling, aftercare programmes, assistance with interventions, support with admissions, lifestyle counselling, relapse prevention, family counselling and/or other sessions.
Article 4: Purposes of use
- Private Addiction Care processes personal data with the aim of optimising the information used to provide its services.
- The personal data provided to Private Addiction Care by clients is therefore processed for the following purpose:
- making proposals to clients;
- entering into, registering and managing agreements with clients;
- checking the accuracy and completeness of these data;
- enabling the use of Private Addiction Care’s services, in the broadest sense of the term;
- facilitating participation in support programmes, coaching sessions, consultations, support activities and appointments offered by Private Addiction Care;
- putting clients in touch with, or referring them to, relevant care providers or network partners of Private Addiction Care, solely to the extent that there is a valid legal basis for doing so and, where required, subject to the Client’s prior consent.
- Private Addiction Care processes personal data only to the extent that there is a lawful basis for doing so as referred to in Article 6 of the GDPR and, where applicable, Article 9 of the GDPR. Depending on the purpose of the processing, such processing may be necessary, amongst other things, for:
- taking pre-contractual measures at the Client’s request;
- the performance of a contract to which the Client is a party;
- to comply with a legal obligation incumbent on Private Addiction Care;
- the protection of Private Addiction Care’s legitimate interests, provided that these do not override the Client’s interests or fundamental rights and freedoms;
- the Client’s express consent, insofar as such consent is required by law.
- Where the processing of personal data is based on consent, the Client has the right to withdraw this consent at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out prior to the withdrawal. Personal data may be used in anonymised form for the purposes of Private Addiction Care’s policy-making, organisation and policy tasks.
- Personal data shall be processed in a fair and careful manner in accordance with these regulations and shall not be further processed in a manner incompatible with the purpose for which it was obtained.
- Private Addiction Care informs clients prior to entering into an agreement about how it handles personal data. Clients are requested to read this privacy policy before signing an agreement and to declare that they agree with it.
Article 5: Retention period
- Personal data shall not be kept longer than is necessary for the purposes for which it was collected, unless a statutory retention obligation or legitimate interest justifies a longer retention period.
- Private Addiction Care stores the data in accordance with statutory provisions.
- Once the agreed or statutory retention period has expired, the personal data shall be removed from the files and destroyed as soon as possible.
Article 6: Providing data to third parties / disclosing data
- Private Addiction Care does not provide personal data of clients to third parties, unless and to the extent that:
- as indicated as such in this privacy policy;
- Private Addiction Care is authorised and/or obliged to do so pursuant to laws and/or regulations, or is requested to do so by a government institution or other regulatory body;
- that this, in the judgement of Private Addiction Care, is necessary to protect its rights and/or property;
- This is done to verify the completeness and accuracy of the provided personal data, and other, less intrusive options are lacking.
Private Addiction Care concludes data processing agreements with parties that process personal data on behalf of Private Addiction Care, in order to guarantee the same level of security and confidentiality. These parties may include – without being exhaustive – cloud providers, email providers, CRM systems, video calling software, bookkeeper or accountant, hosting provider.
- Private Addiction Care ensures that personal data is processed in accordance with the law and in a proper and careful manner.
- Private Addiction Care does not register more personal data than is necessary for the purpose described above and does not record personal data for purposes other than those described above.
- Private Addiction Care has drawn up procedures for the security of physical and digital personal data and has established access restrictions for the digital system. Private Addiction Care makes every effort to take appropriate organisational and technical measures in order to secure clients' personal data against unlawful processing and/or loss. Employees at Private Addiction Care who have authorised access to clients' personal data on behalf of Private Addiction Care are bound by a confidentiality clause. Confidentiality is guaranteed in the agreements with clients.
- The management of Private Addiction Care is the competent authority regarding the granting of authorisation. Data is only processed by persons who are bound by a duty of confidentiality by virtue of their position.
- Private Addiction Care is subject to periodic audits regarding quality standards. It has been agreed with the auditing bodies under which conditions and with which quality guarantees access to the administration is possible.
Article 7: Rights of data subjects
- Every data subject whose personal data is processed by Private Addiction Care has the rights granted to them under the General Data Protection Regulation (GDPR), including:
- the right of access to processed personal data;
- the right to rectification of inaccurate or incomplete personal data;
- the right to erasure of personal data, insofar as the law does not preclude this;
- the right to restriction of processing;
- the right to data portability;
- the right to object to the processing of personal data;
- the right to withdraw consent for data processing at any time, insofar as the processing is based on consent.
- A request to exercise one of the aforementioned rights can be submitted in writing or by email to Private Addiction Care via info@privateaddictioncare.com or gijs@privateaddictioncare.com.
- Private Addiction Care carefully assesses every request and provides information on the follow-up to the request no later than one month after receipt. If a request cannot be dealt with within this period due to its complexity or the number of requests, this period may be extended by two months. The client will be informed of this in good time.
- If Private Addiction Care rejects a request in whole or in part, this decision shall be communicated to the data subject with reasons.
- If personal data are corrected, supplemented, deleted or their processing is restricted following a request, Private Addiction Care shall take reasonable measures to inform third parties to whom these data have been provided of this, unless this proves impossible or involves a disproportionate effort.
- The exercise of the rights referred to in this article is free of charge, unless a request is manifestly unfounded or excessive. In that case, Private Addiction Care is entitled to charge a reasonable fee or to refuse the request, all insofar as the GDPR permits.
- Data subjects also have the right to lodge a complaint with the Dutch Data Protection Authority if they consider that the processing of their personal data infringes applicable privacy legislation.
- Requests concerning minor data subjects or individuals under legal guardianship or administration are handled in accordance with the applicable legal rules concerning representation.
Article 8: Processing of special categories of personal data
Private Addiction Care processes special category personal data exclusively if there is a legal exception for this as referred to in Article 9 of the GDPR and the Dutch implementation act for the GDPR (UAVG).
Article 9: Website
- Private Addiction Care is responsible for the operation of its website.
- The Private Addiction Care website is publicly accessible.
- Anyone can visit the public section of the Private Addiction Care website without providing personal data.
Article 10: References and links
The Private Addiction Care website may contain references and/or hyperlinks to one or more third-party websites. Private Addiction Care is in no way liable for the manner in which these third parties handle privacy legislation. Private Addiction Care therefore advises clients to read the privacy policy of these third-party websites so that they are aware of how these third parties handle their personal data.
Article 11: Use of log files
The website of Private Addiction Care automatically collects certain non-identifiable information regarding its website visitors, including the Internet Protocol (IP) address of the visitors' computer, the date and time of access to the website, the internet address of the website from which a link was made to the Private Addiction Care website, the IP address of the Internet Service Provider, the operating system, the components, information, and pages of the website that were visited and/or viewed, as well as the material that is forwarded or downloaded from the website. This technical information is used for the management of the website and to optimise the website and services of Private Addiction Care. In addition, this data may be used for historical, statistical, or scientific purposes. This data is not retained longer than necessary for the purposes for which it was collected and is only provided to third parties if there is a lawful basis for doing so.
Article 12: Cookies and similar technologies
- On its website, Private Addiction Care uses functional cookies and, where applicable, analytical cookies and other similar technologies to ensure the website functions properly, to guarantee the security of the website, and to analyse and improve the use of the website.
- In so far as the placement of cookies requires consent under applicable laws and regulations, these cookies are only placed after the visitor has given consent via the cookie banner or a comparable consent mechanism.
- Functional cookies that are necessary for the technical operation of the website and the provision of the requested services can be placed without prior consent.
- If Private Addiction Care uses analytical cookies, they are set up to be as privacy-friendly as possible. Insofar as personal data is processed, this is done in accordance with the GDPR and this privacy policy.
- Visitors can modify their cookie settings at any time or withdraw previously granted consent via their browser settings or via the cookie settings on the website, insofar as this functionality is available.
- Further information regarding the use of cookies, the types of cookies used, their purposes, and any third parties involved is included in the cookie statement and/or privacy statement of Private Addiction Care.
- If personal data is processed via cookies or similar techniques, the provisions of these privacy regulations apply in full.
Article 13: Security and liability for third parties
- Despite the security measures taken by Private Addiction Care, it could unexpectedly occur that third parties succeed in bypassing these measures and/or using clients' personal data for improper purposes. Private Addiction Care cannot be held liable for this.
- Private Addiction Care accepts no liability for any damage arising from the use of personal data by third party/parties to whom these data have been provided pursuant to these privacy regulations or with the consent of clients. Furthermore, Private Addiction Care is not liable for compliance with applicable laws and/or regulations (including privacy legislation) by these third party/parties.
Article 14: Liability
Regarding the (limitation of) liability of Private Addiction Care, Private Addiction Care refers to Article 15 of its general terms and conditions.
Article 15: Questions, comments and/or complaints
If you have any questions, comments or complaints about this privacy policy and the way Private Addiction Care registers, uses and processes data, you can contact us by email at info@privateaddictioncare.com or gijs@privateaddictioncare.com.
Complaints can also be submitted to the Dutch Data Protection Authority, autoriteitpersoonsgegevens.nl/contact
Article 16: Amending the privacy policy
- Private Addiction Care reserves the right to amend this privacy policy at any time. In the event of a relevant and specific amendment to the privacy policy, clients will be informed accordingly. The most up-to-date privacy policy can be viewed on the Private Addiction Care website.
- If any provisions of this privacy policy are wholly or partially void, voidable or contrary to the law, they shall be deemed to be independent and inapplicable and shall be replaced. The remaining provisions of the privacy policy shall in that case remain in full force and effect.