Privacy Statement

Introduction
Welcome to Miranda, Psychology Practice, Consultancy & Training Agency.

Miranda, Psychology Practice, Consultancy & Training Agency respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or engage with our services and tell you about your privacy rights and how the law protects you.
This privacy statement relates to the processing of personal data of:

  • Visitors to the website miranda.veltman.com
  • Potential clients and other interested parties.
  • clients.

This privacy notice is provided in a layered format, please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY

 

  1. Important information and who we are
    Purpose of this privacy notice:
    This privacy notice aims to give you information on how Miranda, Psychology Practice, Consultancy & Training Agency collects and processes your personal data through your use of this website. This website is not intended for children and we only collect data relating to children with the guardian’s permission.

    It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
    This privacy notice supplements the other notices and is not intended to override them.

    Rights regarding your data 

  • You have the right to inspect, rectify or delete your personal data.
  • You have the right to withdraw previously given permission to process data.
  • You can also object to the processing of your personal data (or part thereof) by me or by one of my processors.
  • You also have the right to have the data provided by you transferred by me to yourself or directly to another party on your instructions.
  • I can ask you to identify yourself before I can comply with the requests.

 

Change of privacy statement
I am entitled to change the content of this privacy statement without notifying you. If you want to be kept informed of changes, it is recommended that you consult the privacy statement regularly.

Questions and complaints
If you have any questions or complaints about the processing of your personal data, please contact me. If this does not lead to your satisfaction, you have the right to file a complaint with the Dutch Data Protection Authority.

Contact details
Our full details are:
Full name of legal entity: Miranda, Psychology Practice, Consultancy & Training Agency
Name of data privacy manager: Miranda Veltman
Email address: info@mirandaveltman.com
Postal address: 2 Pelican Road 9, Point Blanche Sint Maarten

Changes to the privacy notice and your duty to inform us of changes.
This version was last updated on 12-10-2022. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. The data we collect about you
    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
    Miranda, Psychology Practice, Consultancy & Training Agency reserves the right to make changes to this statement. We recommend that you consult these regularly, so that you are always aware of the content.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
-Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
– Contact Data email address, home address and telephone numbers.
– Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
– Usage Data includes information about how you use our website, products and services.
– Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
– We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel the service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?
We use different methods to collect data from and about you including through:

– Direct interactions. You may give us data by filling in forms or by corresponding with us by  post, phone, email or otherwise. This includes personal data you provide when you:
– Request services from the site mirandaveltman.com;
– Sign up to a newsletter or blog;
– Register for access or create an account on our website;
– Request marketing to be sent to you;
– Enter a competition, promotion or survey;
– Give us some feedback.
– Automated technologies or interactions.
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
– Third parties or publicly available sources.
– We may receive personal data about you from various third parties and public sources as set out below:
– Technical Data from the following parties: analytics providers such as Google, based outside the EU;

  1. How we use your personal data
    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
    – Where we need to perform the contract we are about to enter into or have entered into with you. Note that, in this context, a contract does not have to be a formal signed document, or even written down, as long as there is an agreement which meets the requirements of contract law. Broadly speaking, this refers to your request to access therapy services via our platform and need to be contacted as part of this service that you require and for which there is a fee payable.
    – Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    – Where we need to comply with a legal or regulatory obligation.
    – Generally, we do not rely on consent as a legal basis for processing your personal. You have the right to withdraw consent to marketing at any time by contacting us.

    Retention period personal data

Your data will not be kept longer than permitted by law. How long data is kept depends on the nature of the data and the purposes for which it is processed. The retention period can therefore differ per purpose.

Purposes for which we will use your personal data
We process this data for the purpose of being able to contact you, to provide the information you have requested or to make an appointment.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity:
-Type of Data
-Lawful basis for processing
-To register you as a new customer
-Identity
-Contact
-Performance of a contract with you
-To process your request to connect with a therapist
– Identity
-Contact
– Medical
-Demographic
– Legal and payment information
– Performance of a contract with you, your employer or community manager.
– Necessary for our legitimate interest (to support our business model)
-To manage our relationship with you which include:
– Notifying you about changes to our terms and conditions, services or subscription.
– Marketing and communications
– Performance of a contract with you, your employer or community manager.
– Necessary to comply with a legal obligation
-To enable you to complete a survey
– Profile
– Usage
– Marketing communications
– Necessary for our legitimate interest (to study how customers use our products/services, to develop them, improve them and grow our business)
– To enble you to upload, update or create a profile on our platform.
– To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data)
– Technical
– Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
– To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
– Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
– To make suggestions and recommendations to you about goods or services that may be of interest to you
– Promotional offers from us
– We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you in our marketing activities.

You will receive marketing communications from us if you have requested information from us or purchased services from us.

Opting out
You can ask us to stop sending you marketing by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, even registration, product/service experience or other transactions as we may still need to communicate with you about these products or services.

Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see here.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so, of course you entitled to object to this new use of your data.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

∙ Internal Third Parties:
∙ External Third Parties: Our approved therapists.
∙ Specific third parties listed in section 3 above.

∙ Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

∙ Service providers acting as processors based in the EEA who provide IT and system administration, accounting, invoicing and shipping services.
∙ Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.

∙ HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention
How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for 7 years after they cease being customers, for tax purposes.

In some circumstances you can ask us to delete your data: see “Request erasure” below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

[Request access to your personal data].

[Request correction of your personal data].
[Request erasure of your personal data].
[Object to processing of your personal data].
[Request restriction of processing your personal data].
[Request transfer of your personal data].
[Right to withdraw consent].

If you wish to exercise any of the rights set out above, please contact us at: info@mirandaveltman.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Clients
This data is processed for the purpose of:

  • To be able to carry out a treatment, coaching or psychological examination;
  • To be able to maintain contact with you;
  • To keep a (financial) administration.

Legal basis
Your personal data is processed based on one of the following legal grounds:

  • You have given your consent for the processing.
  • An agreement or order will be executed at your request.
  • I have to comply with a legal obligation.
  • Data processing is necessary in connection with a vital interest of you as a data subject.
  • Data processing is necessary with a view to an interest of me as a controller or of a third party, unless that interest conflicts with the interest of the person whose data is processed, and that interest takes precedence.

 

Retention period
I do not store personal data of clients for longer (in a form that makes it possible to identify the data subject) than is necessary for the realization of the purposes for which they were collected.

In principle, I use the following retention periods:

  • Medical data, health care data and psychological reports with data of a medical nature: fifteen years from the time they were produced, or so much longer as reasonably ensues from the care of a good care provider or responsible person;
  • Psychological reports using only data of a non-medical nature: one year
  • Administrative and financial data: seven years.
  • If the retention period of the personal data has expired or if you request destruction before the expiry of the retention period, the relevant medical data, healthcare data or psychological reports will be destroyed within a period of three months.

Destruction is omitted if it can reasonably be assumed that:

  • Storage is of great importance to someone other than you as a data subject;
  • Retention is required by law, or;
  • If there is an agreement between you as the data subject and me as the controller.