Privacy policy

COMES, based in Bilthoven and registered with the Dutch Chamber of Commerce under number 78468086, is responsible for the processing of personal data as described in this privacy policy. You can reach us at info@comes.nu.

Which data do we process and why?

Contact form. Through the contact form we process your name, email address, phone number (optional) and the content of your message. We use these details to respond to your message. The legal basis is your consent, which you give by submitting the form.

Stay informed. If you sign up for updates, we process your email address. We use it to inform you about new resources, the book and courses. The legal basis is your consent. You can unsubscribe at any time by sending an email to info@comes.nu.

Booking an appointment. You book an appointment through SimplyBook.me. We process your name, email address, phone number and whatever you fill in on the booking form. We use these details to schedule and confirm your appointment.

Guidance and courses. When you start working with COMES, we record details that you share yourself, such as contact details, your situation, your goals and our agreements. This may include information about your health, for example about your pain and capacity. This is special category personal data. We only process it with your explicit consent and use it solely for your guidance. For invoicing we keep the details that are needed for that purpose. We keep this data on paper and digitally.

Guidance through your employer. When your employer funds the guidance, the employer only receives information about the process and practical progress, such as that the programme has started, how many sessions have been agreed and whether the programme continues or ends. We only share the content of sessions if you explicitly agree.

Website security. To prevent misuse of the contact form, we briefly record the IP address and time of suspicious submissions. The legal basis is our legitimate interest in securing the website and our email. We keep this data for a maximum of two months.

Visiting the website. With Google Analytics we measure how the website is used, for example which pages are viewed. This only happens if you agree on the cookie banner. See the Cookies section for more.

Who do we share your data with?

We do not sell your data. We use parties that process data on our behalf. These are Hostinger (server for the website and email), SimplyBook.me (calendar and appointments) and, only after you agree on the cookie banner, Google (Analytics). We have made agreements with these parties about the processing and security of data. Google may process data outside the European Union and participates in the EU-US Data Privacy Framework.

We only provide data to others if the law requires it or if you give permission, for example for feedback to your GP, practitioner or employer.

How long do we keep your data?

• Messages through the contact form: up to twelve months after your question has been handled. We then delete them.
• Email address for updates: until you unsubscribe.
• Appointment details in SimplyBook.me: up to two years after your last appointment.
• Data about your guidance, such as intake and session notes: up to two years after the guidance has ended, unless a legal obligation requires a longer period.
• Details of a complaint and how it was handled: up to two years after it was resolved.
• Invoice data: seven years, because tax law requires it.
• Security data of the contact form: a maximum of two months.

Security

We process digital data on secured systems. The website and email run on our own server (VPS), which we rent from Hostinger and manage ourselves. Paper records are kept in a locked cabinet. We take appropriate technical and organisational measures to protect your data.

Cookies

This website uses analytical cookies from Google Analytics, only after you click Accept on the cookie banner. If you choose Decline, we do not load Google Analytics. We store your choice in your browser. If you want to change your choice, delete the site data for comes.nu in your browser. The banner will then appear again.

The SimplyBook.me calendar is an embedded part of the page. As a result, SimplyBook.me receives your IP address as soon as you reach the calendar, and may place cookies of its own that the calendar needs. We load the website fonts from our own server, so your visit does not go to Google for that purpose.

Your rights

You have the right to access, correct or delete your data. You can also have the processing restricted, object to the processing and ask for your data to be transferred. If you have given consent, you can withdraw it at any time. This does not affect processing that has already taken place. Please contact us at info@comes.nu. We respond within two weeks.

If you disagree with how we handle your data, please contact us first. You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). Is there something you are not satisfied with? Read our complaints procedure (in Dutch).

Questions?

Do you have questions about this privacy policy? Send an email to info@comes.nu.