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Privacy Policy

5 Step Therapy invites its customers to take the time to carefully read the options in this Privacy Policy, together with the Terms and Conditions and any other conditions that may apply to its products and services.

 

1. General

5 Step Therapy is located at Rijnstraat 170, 1079 HS Amsterdam and registered with the Chamber of Commerce number 69065039 (hereinafter "5 Step Therapy"). 5 Step Therapy considers the protection of privacy extremely important and wants to inform, respect and give control over what happens with their data as much as possible to its customers and the users of its services. 5 Step Therapy wants to manage and use its customer data securely, respectfully and in order to better serve its customers and provide the best possible experience. 5 Step Therapy therefore departs from the principle that everyone should have control over his or her personal data. Below you will find information about what data 5 Step Therapy collects, why, for how long and how you have control over this.

 

2. Application

This Privacy Policy applies to all our customers (current, former and future) and to all visitors to the 5 Step Therapy website www.5-step-therapy.nl.

 

The European General Data Protection Regulation 2016/679 of 27 April 2016 ("General Data Protection Regulation") regulates the protection of your personal data.

 

5 Step Therapy strives to comply with its obligations and to respect the rights of the customer whenever 5 Step Therapy processes your personal data.

 

3. Processing of personal data and responsibilities

"Personal data" means any information relating to an identified or identifiable natural person ("the data subject"), it being understood that identifiable is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, location data, an online identifier or of one or more elements characteristic of a natural person.

The personal data that 5 Step Therapy collects and processes primarily concerns the data that a subscriber to our blog or the customer enters through the various pages of our website and that 5 Step Therapy obtains through your use of our website(s). and/or our products and/or services.

 

5 Step Therapy acts as responsible for the processing of personal data of its customers for the purposes described in this Privacy Policy.

 

This does not alter the fact that the customer has a number of obligations in connection with the processing of personal data that allows the customer to use 5 Step Therapy's products and services. In that capacity, the customer must always obtain the legally required permissions from the end users where necessary for the processing of their personal data by 5 Step Therapy to the extent necessary in the context of the products and services of 5 Step Therapy.

 

We may collect some or all of the following information:

  1. Name

  2. Contact details: email address, telephone number 

  3. Demographic information: address, zip code

  4. IP address (automatically collected)

  5. Web browser type and version (automatically collected)

  6. Operating System (automatically collected)

  7. A list of URLs of your activity on our website

 

4. Purposes

5 Step Therapy processes personal data for various purposes, whereby only those data are processed that are necessary to realize the intended purpose.

This is how we use personal data:

  • When we have received permission;

  • In the context of the preparation or execution of our contract or project;

  • To comply with legal or regulatory provisions to which we are subject; and

  • When 5 Step Therapy has a legitimate interest in this, such as, for example, as the case may be, conducting direct marketing, preventing fraud, managing internal administration or monitoring appropriate network and information security, in which case we will always strive for a balance between that interest and respect for the privacy of the data subject.

 

Subject to permission, insofar as required, 5 Step Therapy collects personal data for the following concrete purposes:

 

To process the request for services.

If you visit our website to collect and/or request information about our services or, for example, when you register for 5 Step Therapy's blog, 5 Step Therapy will in any case need your address details. All information that 5 Step Therapy receives about you in this pre-contractual phase will only be used by 5 Step Therapy to provide you with the requested information, in the way you want it. Even when you finally decide to become a customer of 5 Step Therapy, 5 Step Therapy will ask you for a number of personal data such as name, address, telephone number, e-mail address and customer number.

 

To offer the best service and inform about usage possibilities.

5 Step Therapy uses personal data to set up, maintain and support services and for administrative purposes.

 

To send information about a new blog. 

We collect your personal data to offer you an optimal, safe and personal user experience. If you have subscribed to our blog yourself, we will also collect more personal data and your personal data will be used to send marketing communications that we deem relevant or interesting to you via email. If you no longer wish to receive these messages, you can use the opt-out and from that moment on you will no longer be contacted regarding this matter.

 

To inform about (new) services of 5 Step Therapy.

5 Step Therapy may use personal data to offer (in writing, by telephone or electronically) new products, services or special promotions that 5 Step Therapy believes may be of interest to you. You can unsubscribe from these kinds of messages, see below.

 

To track performance.

5 Step Therapy may use personal data and consumer profiles to evaluate its products and services. This includes, among other things: requesting feedback about services (for example through market research), data we obtain during answers to customer questions, detecting fraud and quality assurance.

 

To comply with legal obligations.

In many cases, 5 Step Therapy is legally obliged to keep certain personal data and/or to communicate it to government authorities, for example in the light of general tax and accounting obligations. In the context of a judicial investigation, 5 Step Therapy may be obliged to provide certain information in a confidential manner to the necessary authorities.

 

To keep track of studies, tests and statistics, for example for trend analysis.

5 Step Therapy may use anonymous, aggregated data to, for example, report internally and externally on the use of its services. The data used for this cannot be traced back to a specific individual. The information 5 Step Therapy extracts from these analyzes is used to evaluate the current portfolio of services and 5 Step Therapy's processes and adapt them to new developments.

 

5. Security

5 Step Therapy strives at all times to protect personal data and privacy, both in the physical office and on the network of 5 Step Therapy. 5 Step Therapy takes care of appropriate organizational and technical measures to protect personal data.

5 Step Therapy's employees or freelancers are trained to handle confidential data correctly. For privacy-sensitive projects, an assessment is also made in terms of security and the protection of personal data. 5 Step Therapy also employs specialists who are responsible for the security of the network, infrastructure and information systems. In addition, 5 Step Therapy uses technical measures to protect personal data.

 

If a data breach should occur with adverse consequences for personal data, the customer will be notified personally in the circumstances provided for by law.

The number of 5 Step Therapy employees who have access to personal information is limited and carefully selected. These employees are granted access to personal information to the extent that they need that information to properly perform their duties.

 

The existence and content of the personal communication that takes place via the network of 5 Step Therapy (for example: e-mail traffic, hosting, ...) is protected by the provisions on telecommunications secrecy. This means that 5 Step Therapy and its employees are not allowed to take cognizance of the existence or content of such communications outside the exceptions listed by law.

 

5 Step Therapy's websites sometimes contain links to third party sites (social media, organizers of 5 Step Therapy sponsored events) whose terms of use do not fall under the scope of this Privacy Policy. Please read their policy on the protection of personal data carefully.

 

6. Disclosure of data to third parties

5 Step Therapy does not sell personal data to third parties nor is it passed on to third parties unless:

 

This is necessary for our services.

For some aspects of our services, we work with third parties or engage subcontractors. These third parties are always carefully selected and there is always an agreement between 5 Step Therapy and this third party in accordance with the applicable legislation. For example, 5 Step Therapy uses service providers of domain name registrations, providers of email services, providers of SSL certificates, providers of cloud connect services and providers of site builder services. For more information about our subcontractors, you can always contact us via the contact details under point 10.

 

When a person refuses that his data be passed on, it is possible that some services can no longer be offered by 5 Step Therapy.

 

There is a legal obligation.

5 Step Therapy refers to point 4 of this Privacy Policy.

 

There is a legitimate interest for 5 Step Therapy or the third party involved.

This only happens if the interests or the fundamental rights and freedoms of the data subject do not prevail.

 

5 Step Therapy has received authorization from the person concerned.

If 5 Step Therapy would otherwise provide personal data to third parties, this will be done with an explicit communication, in which an explanation is given about the third party, the purposes of the transfer and processing. Where required by law, 5 Step Therapy obtains explicit and unambiguous consent from the data subject. The data subject also always has the option of objecting (see below).

 

7. Rights of the data subject

You can exercise a number of rights regarding the processing of your personal data with regard to 5 Step Therapy, insofar as you have those rights under applicable law.

 

You can exercise these rights by using the contact details stated under point 10 of this Privacy Policy. 5 Step Therapy will answer such requests and may or may not comply with such requests in accordance with applicable law and in principle within a period of one (1) month, also in accordance with applicable law.

 

Right to object

You have the right at any time, for reasons related to your specific situation, to object to the processing of your personal data that is based on the legitimate interest of 5 Step Therapy. If you object, 5 Step Therapy will stop processing those personal data unless 5 Step Therapy invokes compelling legitimate grounds for the processing that outweigh your interests, rights and freedoms, or that are related to the establishment, exercise or substantiation of a legal claim.

 

Right of access and transparency

You have the right to (free) access to the data concerning yourself and to obtain a copy of this personal data. You can also ask us:

• Whether we process your personal data;

• For what purposes we process it;

• Which categories of personal data we process;

• Which categories of third parties we share your personal data with;

• What is the origin of the processed data;

• What rights you have.

 

Right to rectification and data erasure

As a data subject, you have the right to have incomplete, incorrect, inappropriate or outdated personal data corrected or supplemented. For this you can contact us from a registered e-mail address or your details can be adjusted vianikischalken@outlook.com. In any case, in order to keep your data up-to-date, we request that you notify us of any changes, such as in the event of a move.

 

You also have the right, without undue delay, to obtain erasure of your personal data if and to the extent that:

  1. the personal data are no longer necessary for the purposes;

  2. there is no longer a legal basis;

  3. you object to the processing, and there are no overriding legitimate grounds for the processing by 5 Step Therapy;

  4. the personal data has been unlawfully processed; or

  5. the personal data must be deleted to comply with a legal obligation that rests on 5 Step Therapy.

 

5 Step Therapy will send you a confirmation message upon execution of a removal request. In the event of partial removal, 5 Step Therapy will also explain why the request could not be fully met.

 

It is possible that, depending on the nature of the request, some services can no longer be offered by 5 Step Therapy. 5 Step Therapy cannot always delete all requested data, for example to comply with legal obligations.

 

Right to restriction of processing

As a data subject, you also have the right to obtain from 5 Step Therapy the restriction of the processing of your personal data, if and insofar as one of the following elements applies:

  1. you contest the accuracy of the personal data, in which case the processing will be restricted for a period that allows 5 Step Therapy to verify its accuracy;

  2. the processing is unlawful and you oppose the erasure of the personal data and request that its use be restricted instead;

  3. 5 Step Therapy no longer needs the personal data for the processing purposes, but you need it for the establishment, exercise or substantiation of a legal claim;

  4. you have objected to the processing, pending the answer to the question whether the legitimate grounds of 5 Step Therapy outweigh those of the data subject.

 

In case of limitation of the processing, the data may still be stored by 5 Step Therapy.

 

Right to data portability

For personal data that are (i) processed in the context of the execution of the agreement, (ii) provided by yourself and (iii) processed via automated processes, you as the data subject have the right to obtain this data from 5 Step Therapy in a structured, commonly used and machine-readable form, as well as to request 5 Step Therapy to transfer that data directly to another party, if this is technically possible, if you wish to switch to another provider.

 

8. Retention periods

5 Step Therapy stores and processes your personal data for as long as is necessary to achieve the purposes described in point 4.

The retention period can therefore differ per purpose, for example to comply with legal obligations or due to the legal necessity to retain certain data as evidence in case of disputes, up to a maximum of 10 years after termination of your contract. This archived data is, of course, only accessible to a limited extent.

 

9. Cookies & the website

In addition to the data that you voluntarily share with 5 Step Therapy when using our websites, 5 Step Therapy also uses cookies and other technological means to collect data.

 

Website

All information, in the form of text, files, images and any other form is made available by 5 Step Therapy for information purposes only.

Any interested person may take cognizance of this information, but 5 Step Therapy reserves the right to change the rules and conditions regarding access to the use of the website at the time it deems appropriate, without any prior warning, or to restrict all or parts of the website.

 

Access to such private areas of the website may be made subject to the provision of information by the visitor/user of the website. The visitor/user who provides this information expressly agrees that this information becomes the property of 5 Step Therapy and that by the mere communication of information to 5 Step Therapy, the latter receives explicit permission to use information in accordance with the Privacy Policy.

 

Providing access to the private part of the 5 Step Therapy website through the use of usernames and passwords can be changed or refused at any time by 5 Step Therapy without this leading to any compensation.

 

Cookies

Our website only uses functional cookies. These are cookies that are necessary for the functioning of the website. These may therefore be placed without the permission of the visitor. We do not use cookies to collect statistical information about website visits or marketing information.

 

10. Contact Details

A question or request in connection with personal data or this Privacy Policy can be addressed at any time to:

 

5 Step Therapy
Niki Schalken
Attn: Privacy Policy
Postal address: Rijnstraat 170, 1079 HS Amsterdam
E-mail address:nikischalken@outlook.com

 

11. Changes

5 Step Therapy reserves the right to change this Privacy Policy. Changes will always be published on this website prior to their coming into effect. It is recommended that you regularly review this Policy so that you are aware of these changes.

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