Privacy Policy
Privacy Policy
Vosburg Counseling
Last updated: 31 August 2026
1. Introduction
Vosburg Counseling (“Vosburg Counseling”, “I”, “me”, or “my”) respects your privacy and is committed to protecting your personal data.
This Privacy Policy explains how I collect, use, store, and protect your personal data when you contact me, book an appointment, participate in online counseling, receive services from me, or otherwise interact with Vosburg Counseling.
Vosburg Counseling operates in the Netherlands and processes personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR” or “AVG”) and applicable Dutch data protection law.
Because counseling may involve sensitive information concerning your mental or physical health, particular care is taken when processing this information.
2. Who is responsible for your personal data?
The data controller responsible for your personal data is:
Vosburg Counseling - Eleanora Vosburg
For privacy-related questions or requests, you can contact me at:
3. What personal data do I process?
Depending on your interaction with Vosburg Counseling, I may process the following categories of personal data.
Identification and contact information
This may include:
Name
Email address
Telephone number, where provided
Other contact information you provide
Appointment information
When you book a counseling appointment, I may process:
Appointment date and time
Time zone
Booking and cancellation information
Information provided through the appointment-booking process
Communications relating to your appointment
Appointments are booked using Cal.com.
Cal.com states that, when someone books an appointment through a practitioner's Cal.com booking page, the practitioner is the controller and Cal.com acts as a processor for the booking data.
Cal.com privacy policy https://cal.com/privacy
Counseling information
When you receive counseling, I may process information that you voluntarily provide during the counseling relationship, including information concerning:
Your mental or physical health
Your emotional wellbeing
Personal circumstances
Relationships and family circumstances
Experiences and events discussed during counseling
Other information relevant to providing counseling services
Some of this information constitutes special-category personal data, particularly data concerning health within the meaning of Article 9 GDPR.
Administrative and financial information
Because services are invoiced rather than paid through an online payment system, I may process:
Billing name and address
Invoice details
Payment status
Bank/payment transaction information where relevant
Accounting and tax records
I do not need to process your payment-card details in order to invoice you.
Technical information
When you access a website or online service associated with Vosburg Counseling, technical information may be processed, depending on the technologies used. This can include information such as IP address, browser type, device information, timestamps, and website usage information.
4. Why do I process your personal data?
I process personal data only for specific and legitimate purposes, including:
Responding to inquiries and requests
Arranging and managing counseling appointments
Providing online counseling services
Maintaining appropriate client and counseling records
Communicating with you about appointments and services
Sending invoices and administering payments
Meeting accounting, tax, legal, professional, and regulatory obligations
Protecting the security of my systems and services
Establishing, exercising, or defending legal claims where necessary
Managing and administering my business
Complying with requests from competent authorities where legally required
I will not use confidential counseling information for unrelated purposes merely because I have access to it.
5. Legal bases for processing
Under the GDPR, I process personal data only where a lawful basis applies.
Depending on the circumstances, this may include:
Performance of a contract: I may process personal data where this is necessary to provide counseling services or to take steps at your request before entering into an agreement.
Legal obligation: I may process personal data where necessary to comply with legal obligations, including applicable accounting, tax, administrative, or regulatory requirements.
Legitimate interests: I may process personal data where necessary for legitimate interests pursued by Vosburg Counseling, provided that those interests are not overridden by your fundamental rights and freedoms. Examples may include maintaining the security of my systems, managing my business, preventing misuse, and establishing or defending legal claims.
Consent
Where consent is the appropriate legal basis, I will request your consent for the relevant processing activity. You may withdraw consent at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
6. Processing of health data and other special-category data
Counseling can involve information concerning your mental or physical health. Under Article 9 GDPR, health data is special-category personal data and receives additional protection.
I will only process special-category personal data where an applicable Article 9 GDPR condition permits me to do so, in addition to an applicable Article 6 GDPR lawful basis.
Pre-contractual steps (Article 6(1)(b)) — when you make an enquiry or book a call, processing your contact details is necessary to respond to you and take steps prior to entering into an agreement.
Legitimate interests (Article 6(1)(f)) — I have a legitimate interest in being able to communicate with people who contact me through this website, provided this does not override your rights.
Consent (Article 6(1)(a)) — where you voluntarily submit personal information through the contact form, your submission constitutes consent. You may withdraw this consent at any time by contacting me.
I will limit the collection and use of sensitive information to what is reasonably necessary for providing counseling and fulfilling applicable legal or professional obligations.
7. Confidentiality
Information shared during counseling is treated as confidential.
I will not disclose information from the counseling relationship to third parties unless there is a lawful basis for doing so.
Depending on the circumstances and applicable law, disclosure may occur where:
You have requested or authorized disclosure;
Disclosure is necessary to provide a service you have requested;
I am legally required or permitted to disclose information;
Disclosure is necessary to protect someone's vital interests where the applicable legal requirements are satisfied;
Disclosure is necessary to establish, exercise, or defend legal claims; or
Another applicable legal basis permits disclosure.
This Privacy Policy does not replace or limit any professional confidentiality obligations or applicable exceptions to those obligations.
8. Online counseling
All counseling sessions provided by Vosburg Counseling take place online.
The specific video-conferencing or communication platform used for counseling may process certain personal data in order to provide the service.
Here are the privacy policies for these following providers:
Cal.com https://cal.com/privacy
Squarespace https://www.squarespace.com/privacy
Google https://policies.google.com/privacy
Zoom https://www.zoom.com/en/trust/privacy/privacy-statement/
I recommend that you participate in sessions from a private location and use a secure internet connection and device where reasonably possible.
Unless expressly agreed otherwise and where legally permissible, counseling sessions are not audio- or video-recorded.
9. Appointment booking through Cal.com
Appointments are booked through Cal.com.
Cal.com states that it processes booking information on behalf of the practitioner and identifies the practitioner as the controller for attendee booking data. Cal.com also publishes information concerning its subprocessors, security measures, international data transfers, and Data Processing Agreement.
Information processed through the booking system may include your name, email address, appointment information, and answers to booking questions.
I will avoid requesting unnecessary health or other sensitive information through the Cal.com booking form.
If Cal.com or another service provider processes personal data on my behalf, I will take appropriate steps to ensure that the processing is governed by an appropriate data-processing arrangement and applicable GDPR safeguards.
10. Invoicing and payment
Vosburg Counseling uses invoices rather than an online payment processor for payment of counseling services.
I may therefore process the information necessary to:
Prepare and send invoices;
Record payments;
Follow up on unpaid invoices;
Maintain accounting records; and
Comply with applicable tax and accounting obligations.
Where payment is made by bank transfer, the relevant transaction information may appear in my business banking records.
11. Who may receive your personal data?
I may disclose personal data to third parties where this is necessary and lawful.
These may include:
Cal.com, for appointment scheduling;
The provider of the online counseling/video-conferencing platform;
Email and hosting providers;
IT and cloud-storage providers;
Accountants or bookkeepers;
Professional advisers, such as lawyers or insurers;
Banks and financial service providers, where necessary for invoicing or payment;
Government authorities, regulators, courts, or law-enforcement bodies where legally required or permitted.
Where a service provider processes personal data on my behalf, I will take appropriate steps to ensure that suitable data-processing and confidentiality arrangements are in place.
12. International transfers
Some technology and service providers used by Vosburg Counseling may process personal data outside the European Economic Area (EEA).
Where personal data is transferred outside the EEA, I will ensure that the transfer is made in accordance with applicable GDPR requirements, using an appropriate mechanism such as an adequacy decision or appropriate safeguards where required.
Cal.com currently states that its services involve processing in the United States and that transfers outside the EEA may rely on mechanisms including Standard Contractual Clauses or an adequacy mechanism such as the EU-US Data Privacy Framework.
13. How long do I retain your personal data?
I retain personal data only for as long as necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.
Different categories of information may therefore be retained for different periods.
In particular, financial and tax records may need to be retained for periods prescribed by Dutch law.
For counseling records, Vosburg Counseling will apply an appropriate retention period based on applicable Dutch law, professional requirements, and the circumstances of the counseling relationship.
The Dutch Data Protection Authority (Autoriteit Persoonsgegevens) states that the GDPR itself does not prescribe one universal retention period and that organisations should determine appropriate periods based on necessity and other applicable legal requirements.
Dutch Data Protection Authority
When personal data is no longer required, it will be securely deleted or anonymized, unless a legal obligation requires continued retention.
14. Security
I take appropriate technical and organizational measures to protect personal data against unauthorized access, loss, alteration, disclosure, or other unlawful processing.
Depending on the circumstances, these measures may include:
Strong passwords and access controls;
Multi-factor authentication where available and appropriate;
Encryption where appropriate;
Secure cloud services;
Restricted access to client information;
Secure devices and software;
Regular security updates;
Confidentiality obligations; and
Secure deletion of information when it is no longer required.
No electronic system can be guaranteed to be completely secure, but I take reasonable and appropriate measures to protect your personal data.
15. Your rights under the GDPR
Subject to applicable legal conditions and exceptions, you have rights including:
Right of access: to request access to personal data I hold about you.
Right to rectification: to request correction of inaccurate or incomplete personal data.
Right to erasure: to request deletion of personal data in certain circumstances.
Right to restriction: to request restriction of processing in certain circumstances.
Right to data portability: where applicable, to receive certain personal data in a structured, commonly used, machine-readable format.
Right to object: to object to certain types of processing where the GDPR provides this right.
Right to withdraw consent: where processing is based on consent.
These rights are subject to conditions and exceptions under the GDPR and other applicable law.
To exercise your rights, contact: vosburgscounseling@gmail.com
I may need to verify your identity before responding to a request.
16. Right to lodge a complaint
If you believe that your personal data has been processed unlawfully or that your privacy rights have not been respected, you have the right to lodge a complaint with the Dutch supervisory authority:
Autoriteit Persoonsgegevens (Dutch Data Protection Authority), The Netherlands
You can find information about contacting the Autoriteit Persoonsgegevens through its official website.
You are also welcome to contact Vosburg Counseling first so that I can try to address your concern.
17. Cookies and website technologies
If the Vosburg Counseling website uses cookies or similar technologies, these may process information such as device, browser, or website usage information.
Necessary cookies may be used where required for the operation and security of the website.
Non-essential analytics, advertising, or similar cookies will be used only where permitted under applicable law and, where required, after obtaining your consent.
18. Marketing
Vosburg Counseling does not use confidential counseling information for marketing purposes.
If I send marketing communications, I will do so in accordance with applicable GDPR and electronic-communications requirements.
You can object to direct marketing or unsubscribe from marketing communications at any time.
19. Adults only
Vosburg Counseling provides counseling services to adults.
I do not intentionally provide counseling services to children under the age of 18.
20. Automated decision-making
Vosburg Counseling does not make decisions concerning clients based solely on automated processing that produce legal or similarly significant effects.
21. Changes to this Privacy Policy
I may update this Privacy Policy from time to time to reflect changes in my services, technology, legal requirements, or data-processing practices.
The latest version will be published with an updated “Last updated” date.
22. Contact
If you have questions about this Privacy Policy or how Vosburg Counseling processes your personal data, please contact:
Last updated: 31 August 2026