This is the full privacy policy of Private Addiction Care B.V. It describes how we handle personal data in our services — from the initial contact through to ongoing support. You will also receive this document with the service agreement. If you want to know in plain English what we collect on this website, please check the Privacy statement; for cookies see the Cookie statement.
Article 1: Definitions
- Personal data: all 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 of data.
- Private Addiction Care: The service provider Private Addiction Care B.V. which offers Services to the Client.
- Clients: the natural persons who give or have given instructions to Private Addiction Care.
- Third parties: persons who are not his clients and/or Private Addiction Care.
- Provision of Personal Data: the disclosure 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, amongst other things, in agreements, codes of conduct and (security) measures. 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 follows 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.
- Exclusively for legitimate purposes: 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 does not process any more personal data than is necessary. If data are no longer needed, they are checked and deleted.
- Accurate, current 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 of 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.
- This privacy policy applies to the processing of all personal data provided in any way to Private Addiction Care.
- Private Addiction Care attaches the utmost importance to confidentiality and thus also to 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 advice.
- Private Addiction Care uses all personal data provided to it solely for the purposes described in this privacy policy and complies with the applicable laws and regulations concerning 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 data is understood to mean disclosing or making available personal data.
- The personal data processed by Private Addiction Care in accordance with the law and in a proper and careful manner for specific, expressly described and legitimate purposes, originating from clients or third parties, include, but are not limited to:
- name, address, postcode, town/city, telephone number(s), email address;
- personal details: date of birth, place of birth, gender, marital status, nationality;
- personal data concerning health;
- data relating to the services of Private Addiction Care, such as appointment dates, meeting notes, recovery support, family counselling, aftercare programmes, intervention assistance, admission support, lifestyle coaching, relapse prevention, family guidance and/or other sessions.
Article 4: Purposes of use
- Private Addiction Care processes personal data with the aim of optimising the information for the provision of services.
- Personal data provided by clients to Private Addiction Care are therefore processed for the purpose of:
- making offers to clients;
- entering into, registering and managing agreements with clients;
- checking the accuracy and completeness of these data;
- enabling the use of the services of Private Addiction Care, in the broadest sense of the word;
- facilitating participation in guidance programmes, coaching sessions, consultations, support activities and appointments offered by Private Addiction Care;
- putting clients in touch with, or introducing them to, relevant care providers or network partners of Private Addiction Care, solely to the extent that a lawful basis exists for doing so and, where required, after prior consent from the Client.
- Private Addiction Care processes personal data solely insofar as a lawful basis exists therefor as referred to in Article 6 GDPR and, where applicable, Article 9 GDPR. Depending on the purpose of the processing, the processing may, amongst other things, be necessary for:
- taking pre-contractual measures at the request of the Client;
- the performance of an agreement to which the Client is a party;
- compliance with a legal obligation resting on Private Addiction Care;
- the representation of the legitimate interests of Private Addiction Care, in so far as the interests or fundamental rights and freedoms of the Client do not override them;
- the explicit consent of the Client, insofar as such consent is required by law.
- If 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 shall not affect the lawfulness of the processing based on consent before its withdrawal. Personal data may be used in an anonymised form for the purposes of policy-making, the organisation and policy tasks of Private Addiction Care.
- Personal data shall be processed in accordance with these regulations in a proper and careful manner and shall not be further processed in a way that is incompatible with the purpose for which they were 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 prior to signing an agreement and to declare that they agree with it.
Article 5: Retention period
- Personal data shall not be kept longer than 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 will be removed from the files and destroyed as soon as possible.
Article 6: Provision of data to third parties / disclosure of data
- Private Addiction Care does not provide personal data of clients to third parties, except if and to the extent that:
- as indicated as such in this privacy policy;
- Private Addiction Care is authorised and/or required to do so pursuant to legislation and/or regulations, or is requested to do so by a government institution or other regulatory body;
- this, in the opinion 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 limitation: cloud providers, e-mail 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 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 board 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. Agreements have been made with the auditing authorities regarding the conditions and quality safeguards under which access to the administration is permitted.
Article 7: Rights of data subjects
- Any data subject whose personal data is processed by Private Addiction Care has the rights to which they are entitled under the General Data Protection Regulation (GDPR), including:
- the right to access the personal data being processed;
- the right to have inaccurate or incomplete personal data rectified;
- the right to have personal data erased, insofar as this is not prevented by law;
- 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, provided 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 assesses each request carefully and provides information on how the request will be dealt with within one month of receipt at the latest. If a request cannot be processed within this timeframe due to its complexity or the volume 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 will 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 will take reasonable steps 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 set out in this article is free of charge, unless a request is manifestly unfounded or excessive. In such cases, Private Addiction Care is entitled to charge a reasonable fee or to refuse the request, to the extent permitted by the GDPR.
- 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 regarding minor data subjects or persons placed under 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 a legal exception as referred to in Article 9 of the GDPR and the Dutch Implementation Act of the General Data Protection Regulation (UAVG) applies.
Article 9: Website
- Private Addiction Care is responsible for the operation of its website.
- The Private Addiction Care website is accessible to the public.
- Anyone can visit the public section of the Private Addiction Care website without providing any 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 Private Addiction Care website automatically collects certain non-identifiable information about visitors to its website, including the Internet Protocol (IP) address of visitors’ computers, the date and time of access to the website, the web address of the website from which visitors were redirected to the Private Addiction Care website, the IP address of the Internet Service Provider, the operating system, the sections, information and pages of the website that have been visited and/or viewed, as well as the material that is transmitted or downloaded from the website. This technical information is used to manage the website and to optimise the Private Addiction Care website and services. In addition, this data may be used for historical, statistical or scientific purposes. This data is not retained for longer than is necessary for the purposes for which it was collected and is only disclosed to third parties where there is a lawful basis for doing so.
Article 12: Cookies and similar technologies
- Private Addiction Care uses functional cookies and, where applicable, analytical cookies and other similar technologies on its website to ensure the website functions properly, to guarantee the website's security, and to analyse and improve the use of the website.
- Where the placement of cookies requires consent under applicable laws and regulations, these cookies will only be placed once the visitor has given their consent via the cookie banner or a similar consent mechanism.
- Functional cookies that are necessary for the technical functioning of the website and for the provision of the requested services may be placed without prior consent.
- Where Private Addiction Care uses analytical cookies, these are configured to be as privacy-friendly as possible. Where personal data is processed, this is done in accordance with the GDPR and these privacy regulations.
- Visitors can change 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 technologies, the provisions of this privacy policy shall 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 resulting from the use of personal data by third party/parties to whom these data have been provided pursuant to this privacy regulation 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.