Privacy Policy

This document concerns the privacy statement of Rosa Kelly, relationship therapist and coach, located at Keizersstraat 8c, 1011GD, Amsterdam (hereinafter ‘Rosa Kelly Coaching’ or ‘I’).

Coaching and couples therapy are my core activity.   However, the statement applies to all my services and concerns the processing of personal data of all my (potential) clients and other persons who have contact with me and / or visit my website. In this privacy statement you can find information about how I deal with personal data. If, after reading this privacy statement,  you still have questions about the way in which I handle personal data, if  you want to make use of  your rights mentioned in this privacy statement under the General Data Protection Regulation (‘GDPR’) or other laws and regulations on personal data, or if  you want to file a complaint about the use of  your personal data,  you can contact  me  by phone: 0655274060 or  e-mail: info@rosakelly.com. If you are not satisfied with the handling of your complaint or if you prefer not to submit your complaint to me, you can also submit it to the Dutch Data Protection Authority, via the website www.autoriteitpersoonsgegevens.nl.

I am responsible for the processing of your personal data, and I must exercise the greatest possible care and of course comply with the rules arising from the GDPR.

What personal data do I process? 

Coaching files or any other files concerning my services

If a referrer (for example, occupational health and safety service or insurer) or you yourself gives me an assignment, I process this personal data that the referrer and / or you and the (possible) other party (s) in your case provide to me.  A referrer will only provide personal data to me with your written consent. In any case, it concerns jo your contact details such as your name, address, e-mail address and telephone number. Furthermore, it concerns personal data that are relevant to the file. Depending on the subject of the coaching (or other types of services), this may also involve sensitive and/or special personal data.

Training and education 

If you sign up for one of my services, by e-mail, by telephone or via the registration form on my website, I process the data provided to me.  This will at least concern your contact details (such as name, e-mail address, telephone number), any deviating billing details, profession, etc.

Invoicing 

If you give me an assignment, I also process data that is necessary for sending invoices and processing payments for the services I perform. In addition to your contact details, it concerns your bank account number and any other payment details.

Contact 

If a referrer or you contact me, by e-mail, via the contact form on the website or by telephone, I process the data provided to me. This will at least concern your contact details (name, e-mail address, telephone number) and the reason why the referrer and / or you yourself contact me (for example because you have a question).

Website visitor analysis 

Finally, I process analytical data about (the computer of) visitors to my website, via cookies that are placed when you visit the website. Through these cookies (part of) the IP address of the visitor is stored. 

For what purposes and on what basis do I process personal data?

Coaching file or any other file concerning my services

I only use your personal data in the context of the services provided by me.   A file is created for this purpose. Because it is possible that sensitive and / or special personal data are processed during a coaching process (and this is not always clear in advance), I ask your permission to process your personal data.

In the case of coaching and related services, I obtain clients’ prior consent to process their personal data in accordance with our privacy statement by confirming this by e-mail (or by post).  

Invoicing 

I use the payment details you have provided to invoice work. This processing is necessary to execute the agreement you conclude with me.  

Contact

I use the contact details you provide to me to contact you, if necessary, for example to answer a question. I process this personal data because this is necessary for the representation of my legitimate interest, namely the interest of being able to perform my work and obtaining new assignments.

Customer satisfaction survey 

I can use your e-mail address to send a customer satisfaction survey after completing a coaching process or another form of service.

Website visitor analysis 

The data I collect about the visitors of the website is only used to keep statistics about the visit to the website, for example to be able to see which pages are viewed the most. The data is stored anonymously. 

How long do I keep your personal data? 

Coaching files or any other file concerning my services

In principle, I keep your file and the personal data contained therein for twenty years after the file has been closed, in connection with the maximum limitation period. In exceptional cases, I will keep a file for more than twenty years, for example if the limitation period is interrupted or if I believe   that there is another legitimate interest in keeping the file longer. Before a professional is called in, I create both a paper and a digital file, in which relatively limited personal data are processed. In particular, the digital file is supplemented with data that is collected and processed during the process of providing services after the engagement of a professional. This mainly concerns feedback about the process and the result of the service. In a form that makes it possible to identify data subjects, I use a retention period of 5 years for the storage of these written and digital files. The written files will be destroyed after 5 years. The digital files may be kept longer (for historical, statistical, or scientific purposes), but will first be anonymised. 

Administration 

I keep my administration, including the invoices and other documents on which the personal data of the parties are stated, for a period of 7 years after the end of the financial year to be able to comply with the fiscal retention obligation. 

Other contact details

I keep my contact details for a maximum of 1 year after the last contact unless you submit a written request to me earlier to delete it.

Website visitor analysis

The data about website visitors is stored 2 years after the visit to the website, these are the default settings of Google Analytics. 

With whom do I share your personal data?

I do not provide your data to third parties, unless I am obliged (on the basis of applicable laws and regulations) or am otherwise obliged to provide certain data to a third party, for example to the police in the context of a criminal investigation or to a collection agency in the event of non-compliance with the agreement concluded with a customer.

How is your personal data protected? 

I have taken appropriate technical and organizational security measures to protect your personal data against loss, misuse, and unauthorized access by third parties. 

What are your rights? 

You have the following rights: a. The right to access your personal data and to receive acopy thereof.b. The right to rectification of your personal data if they are incorrector incomplete.c. The right to object to the processing and/or – in certain cases – the right to restriction of the processing of your personal data. d. In certain cases:  the right to have your personal data erased (‘right to be forgotten’). e. The right to obtain your personal data ina structured, commonly used and machine-readable format and to transfer that data to another person. For more information about these rights and when you can exercise them: see Articles 15 to 20 of the General Data Protection Regulation. You can exercise your rights by contacting me at the e-mail address or telephone number mentioned at the beginning of the privacy statement.

Alterations 

Sometimes something can change in my privacy statement, whether on the basis of changed rules or legislation. In the event of major changes, I will place a notification on the website and inform you of the change by e-mail, if the agreed service has not yet been terminated.