Question 1

1. Who is responsible for your personal data?

Accepted Answer

Astramía Counselling is responsible for the processing of personal data described in this Privacy Policy.Practice: Astramía CounsellingPractitioner: Lina GabbaoanLocation: Groningen, the NetherlandsChamber of Commerce (KvK): 96940719VAT ID: NL005238416B15Website: astramiacounselling.comPrivacy contact: contact@linagabbaoan.comAstramía provides preventive and psychosocial counselling and emotional support. The nature and professional scope of these services are explained further on the Professional Registration & Ethics page.

Question 2

2. What information may be collected?

Accepted Answer

The information collected depends on how you interact with Astramía.When you visit the websiteTechnical information may be processed where necessary for the website to function securely and correctly. Depending on the website features in use and your cookie preferences, additional functional or analytical information may also be processed.When you contact AstramíaThis may include your:name;email address;telephone number, where provided;preferred method of contact;content of your enquiry; andother information you voluntarily provide.When you book an introductory call or sessionThis may include your:name and contact information;appointment date and time;booking information;information you voluntarily provide when making the appointment; andinformation necessary for communication concerning your appointment.When you become a clientAdditional information may be processed where reasonably necessary for counselling and professional administration. This may include:identifying and contact information;intake information;information you voluntarily share about your circumstances and support needs;relevant session records or professional notes;agreed goals or support plans;correspondence relating to your counselling;consent and agreement records; andinvoicing and payment information.Counselling may involve information about emotional wellbeing, relationships, family circumstances or other private matters. Such information may constitute sensitive personal data and is handled with additional care.

Question 3

3. Why is your information processed?

Accepted Answer

Personal data is processed only where there is an appropriate purpose and legal basis.Information may be processed to:respond to enquiries;arrange an introductory call;assess whether Astramía is an appropriate service for your needs;arrange and provide counselling;communicate with you about appointments;maintain appropriate professional records;administer invoices and payments;meet accounting, tax, professional or other legal obligations;maintain the security and functionality of the website and practice systems; andrespond appropriately where safety or legal obligations require action.Your counselling information is not sold or used for commercial profiling.Marketing communications will only be sent where an appropriate legal basis exists and, where required, you have provided consent.

Question 4

4. Legal bases for processing

Accepted Answer

Depending on the circumstances, Astramía may process personal data on one or more of the following GDPR legal bases:Contract or steps before entering into a contract For example, when you enquire about counselling, request services, book a session or communicate about your counselling.Legal obligation Where information must be processed or retained to comply with applicable legal requirements, such as financial and tax administration.Legitimate interests Where processing is reasonably necessary for the responsible and secure administration of the practice and those interests do not override your rights and freedoms.Consent Where consent is the appropriate legal basis, including certain optional communications or processing activities.Where special categories of personal data are processed, an appropriate additional legal basis under the GDPR will also apply.

Question 5

5. Counselling confidentiality

Accepted Answer

Information shared during counselling is treated confidentially and with respect for your privacy.Information is not ordinarily disclosed to other people or organisations without your permission.Confidentiality cannot, however, be absolute in every circumstance. There may be exceptional situations involving serious safety concerns or circumstances in which disclosure is required or permitted by law.Where circumstances allow, I will aim to discuss the situation with you before information is disclosed.Further information about confidentiality, professional boundaries and ethical practice is provided within relevant client agreements and on the Professional Registration & Ethics page.

Question 6

6. Client records and ECD systems

Accepted Answer

Astramía maintains appropriate professional records relating to counselling services.Client and counselling records may be maintained within the Astramía Digital ECD System and the CAT ECD, as applicable to professional record keeping and practice requirements.Access to client information is restricted and information is handled according to its sensitivity and purpose.Administrative or financial records are kept separate from detailed counselling information where reasonably practical, and no more sensitive information than necessary is included in financial administration.

Question 7

7. Information about children and other people

Accepted Answer

During counselling, you may sometimes discuss partners, former partners, children, family members or other people who form part of your experience.Information concerning other people is recorded only where it is reasonably relevant to your counselling or professional record keeping.Please avoid providing unnecessary identifying or sensitive information about other people through website contact or booking forms.Astramía does not intentionally collect personal information directly from children through the website unless this has been specifically agreed and an appropriate legal basis and safeguards are in place.

Question 8

8. Appointment scheduling

Accepted Answer

Astramía uses TidyCal for online appointment scheduling.When you choose to use TidyCal, information you provide through the booking service may also be processed by TidyCal and its relevant service providers according to their applicable privacy practices.Astramía aims to request only information reasonably necessary for arranging and administering an appointment through the booking system.You should avoid entering extensive or unnecessary sensitive counselling information into the booking form. More detailed information can be discussed through appropriate counselling and intake processes.

Question 9

9. Website and technical services

Accepted Answer

The Astramía website is created and hosted using Wix.Website and technology providers may process limited personal or technical information where necessary to host, secure, maintain or provide functionality for the website.Other external technology providers may also be used where reasonably necessary for communication, scheduling, administration or other practice functions.Where third parties process personal data on behalf of Astramía, appropriate data-protection arrangements are used where required.

Question 10

10. Administration, invoicing and financial information

Accepted Answer

Information required for invoicing, bookkeeping, taxation and financial administration is processed separately from counselling content where reasonably practical.Financial records may include:your name;billing information;invoice information;payment information or payment status; andinformation required to comply with Dutch accounting or tax requirements.Detailed counselling content is not included in financial administration unless there is a specific and lawful reason for doing so.

Question 11

11. How long is information kept?

Accepted Answer

Personal information is retained only for as long as necessary for its purpose and in accordance with applicable legal and professional requirements.Client and counselling recordsProfessional client and counselling records are generally retained for 20 years, consistent with the retention framework applicable to the CAT ECD and relevant professional record-keeping requirements.Where another legal or professional retention requirement applies to particular information or circumstances, that requirement may take precedence.Enquiries and introductory contactsInformation relating to general enquiries or introductory contacts that do not result in an ongoing counselling relationship will not be retained longer than reasonably necessary for handling the enquiry and related administration, unless another lawful reason requires further retention.Financial and tax administrationRecords forming part of Astramía's fiscal administration are generally retained for 7 years, in accordance with Dutch tax administration requirements. Certain records may be subject to a different statutory retention period.End of the retention periodWhen information reaches the end of its applicable retention period and there is no other lawful reason to retain it, it will be securely deleted, anonymised or otherwise disposed of as appropriate.

Question 12

12. How is your information protected?

Accepted Answer

Astramía takes reasonable technical and organisational measures appropriate to the nature and sensitivity of the information being processed.These measures may include:password-protected systems and accounts;appropriate access controls;restricted access to client information;secure devices and accounts;professional electronic client record systems;separation of counselling information from unnecessary administrative information where reasonably practical; andperiodic review of how information is stored and accessed.No digital system can guarantee absolute security. Personal information is nevertheless handled with care proportionate to its sensitivity.

Question 13

13. Sharing information with third parties

Accepted Answer

Astramía does not sell your personal information.Information may be processed by or shared with third parties where reasonably necessary for operating the practice, where you have authorised this, where another lawful basis applies or where disclosure is required by law.Depending on the services in use, this may include providers involved in:website hosting and technical services;appointment scheduling;email and communication;professional electronic client records;bookkeeping and financial administration;payment processing; orprofessional, regulatory or legal requirements.Only information reasonably necessary for the relevant purpose should be shared.Counselling content is not routinely shared with administrative or technology providers simply because they provide another service to the practice.

Question 14

14. International processing

Accepted Answer

Some technology providers used for website hosting, appointment scheduling, communication or other digital services may process information outside the Netherlands or the European Economic Area.Where the GDPR requires safeguards for international transfers of personal data, appropriate legal transfer mechanisms or safeguards must apply.

Question 15

15. Cookies and similar technologies

Accepted Answer

The Astramía website may use cookies and similar technologies to operate securely and provide website functionality.Some cookies are essential for the website to function and may therefore be used without optional consent.Depending on the website functionality and services enabled at a particular time, other technologies may be used for functional, analytical or marketing purposes.Where consent is legally required, non-essential cookies or similar technologies should only be activated after the appropriate consent has been provided.Cookie categories may include:Essential cookies Necessary for security, network management and core website functionality.Functional cookies Used for optional functionality or to remember certain visitor preferences.Analytics cookies Where enabled, these may be used to understand how visitors interact with the website and to improve website performance.Marketing cookies Where enabled, these may be used in connection with marketing or advertising functionality and are subject to applicable consent requirements.Available cookie choices can be managed through the website's cookie consent or settings functionality where provided.Because website technologies and integrations may change over time, the particular cookies used may also change.

Question 16

16. Your GDPR rights

Accepted Answer

Depending on the circumstances, you may have the right to:request access to personal data held about you;request correction of inaccurate or incomplete personal data;request deletion of personal data where applicable;request restriction of processing;object to certain processing;withdraw consent where processing is based on consent; andrequest data portability where applicable.These rights are not absolute in every circumstance. For example, information may need to be retained where Astramía has a legal or professional obligation to keep it.Withdrawing consent does not affect the lawfulness of processing that occurred before consent was withdrawn.Requests concerning your personal data can be submitted to:contact@linagabbaoan.comIdentity verification may be requested where reasonably necessary to ensure personal information is not disclosed to the wrong person.

Question 17

17. Privacy concerns and complaints

Accepted Answer

If you have concerns about how your personal information has been handled, you are welcome to contact Astramía so that the matter can first be considered directly.Email: contact@linagabbaoan.comYou also have the right to lodge a complaint concerning the processing of personal data with the Dutch data protection supervisory authority, the Autoriteit Persoonsgegevens.The privacy complaints process is separate from the professional complaints procedure applicable to counselling services.Information about professional standards and complaints relating to counselling practice is available through Astramía's Professional Registration & Ethics information and relevant client documentation.

Question 18

18. Changes to this Privacy Policy

Accepted Answer

Astramía may update this Privacy Policy when services, systems, professional requirements, legal obligations or privacy practices change.The current version will be published on this website together with its latest revision date.Where a change materially affects how existing client information is processed, additional communication may be provided where appropriate.

Question 19

19. Contact

Accepted Answer

For questions about this Privacy Policy, requests concerning your personal data or concerns about how your information has been handled, please contact:Astramía Counselling Groningen, the NetherlandsPrivacy contact:contact@linagabbaoan.comWebsite: astramiacounselling.comChamber of Commerce (KvK): 96940719VAT ID: NL005238416B15