Privacy Policy and Imprint

Privacy Policy

 

We value openness and transparency at OpenUp, and we are also open and transparent about how we manage your personal data. Your privacy is always our top priority. Your data is safe with us and we will use it appropriately. 

 

When you visit our website, call us or send a question through the chat, have a consultation with one of our psychologists (coaches), or apply for a job with us, you are sharing your personal data with us. We use this to provide you with the best possible service. We think it’s important that you know what happens to your data. Naturally, we handle it with the utmost care.

 

We’re happy to explain how exactly we use and protect your personal data through this privacy policy. If you still have any questions after reading it, then feel free to let us know by emailing us at privacy@openup.com. Our door is always open for any questions you have.

 

On this page, you will always find the latest version of our privacy policy. It might be that the policy changes from time to time, if new developments and activities within OpenUp warrant it or if privacy laws change. Not sure you’re looking at the most up-to-date version of the privacy policy? Then always check this page to make sure that you’ve got the correct one.

 

The latest changes were made on 16 February 2023.

 

Who is responsible for processing your personal data?

 

OpenUp B.V. (“OpenUp”), based in Amsterdam and registered with the Chamber of Commerce under the number 77340159, is responsible for processing your personal data.

 

To what does this privacy policy apply?

 

This privacy policy applies to all products and services that OpenUp offers and relates to the processing of the personal data of anybody who contacts us in any capacity.

 

This could include (potential) users of our services, visitors to the website, job applicants and all other people who contact us or whose personal data we process, with the exception of OpenUp employees.

 

What is personal data?

 

Personal data is any data that can be traced back to you as an individual. The most basic personal data is your name, telephone number, address and/or email address. Additionally, it relates to all the other data you share with us that can be traced back to you and is related to your contact with OpenUp. This includes your query, information about your personal situation or the results of your health check. In addition, your IP address and surfing behaviour, for example, might also fall under personal data.

 

What personal data do we process?

 

At OpenUp, we process a variety of personal data for a variety of purposes.

 

We might process the following data about you:

  • Your first name and last name
  • Email address
  • Telephone number
  • Address and place of residence
  • Information about your personal situation and health, including your query
  • The results of your health check
  • Any other personal data that you share with us

 

For what purpose and on what basis do we process your personal data?

 

The table below lists the personal data we process, for what purpose and on what basis. In addition, you can see how we obtained this data.

Data type Source Processing purpose Lawful basis
  • First name and surname
  • E-mail address
  • Telephone number
  • Address and city
  • Any other personal data you share with us (except data about your health)

Provided by you as a user of the OpenUp services:

  • if you – during a conversation, meeting or by phone – share these personal data with us
  • if you digitally – during an online consultation or via e-mail, chat or web forms on the website – share these personal data with us
 These data are used to offer our services to you as a user of the OpenUp platform in the best possible way The processing is necessary for the performance of the agreement between you and OpenUp (in accordance with Article 6(1)(b) of the General Data Protection Regulation “GDPR”). This agreement comes about when you ask us a question for help or make an appointment with us by chat, phone or video call
  • Information about your personal situation and health
  • The results of your check-in*

*We call this data well-being data

Provided by you as a user of the OpenUp services:

  • if you – during a conversation, meeting or by telephone – share these personal data with us
  • if you digitally – during an online consultation or via e-mail, chat or web forms on the website – share these personal data with us
 These data will be processed in order to be able to offer our services to you as a user of the OpenUp platform in the best possible way This data will only be processed if you have given your express consent (in accordance with Article 6(1)(a) or Article 9(2)(a) of the General Data Protection Act). You give this consent when making an appointment online
  • First name and surname
  • E-mail address
 Provided by you when you subscribe to our (e-mail) newsletters on the website These data will be processed to keep in touch with you and provide you with information, for example through our (email) newsletters and blogs We have received your consent to process personal data (in accordance with Article 6, paragraph 1 under (a) GDPR). You give this consent online when you subscribe to our newsletters. You can always unsubscribe via the ‘unsubscribe’ link at the bottom of these (e-mail) newsletters.
Data about our services and their outcomes Obtained by us through your use of our services To be able to research the effectiveness of our services, to improve them and to draw up reports (that cannot be traced back to a natural person) for the employer. We will pseudonymise or, if possible, anonymise this data. Insofar as this nevertheless involves the processing of personal data, this will only take place if you have given your express consent (in accordance with Article 6(1)(a) or Article 9(2)(a) of the GDPR). You give this consent when making an appointment online.
User statistics of our website, such as number of visitors, length of visit, which parts of the website are viewed and how clicks are made Obtained by us during your visit to the OpenUp website. This includes your browsing behaviour, including data about your first, previous and current visit, which pages you view, how you navigate through the site and which parts you click on To optimise our website and make it more user-friendly

These are generic reports, which cannot be traced back to you as an individual visitor.

Insofar as this does involve the processing of personal data, we have a legitimate interest in doing so (in accordance with Article 6(1)(f) of the GDPR).

You can apply for a position with us. We then process the following personal data:

  • First and last name
  • E-mail address
  • Telephone number
  • Motivation
  • Curriculum vitae (CV)
 Provided by you when you fill out the online application form We use this data to assess your suitability for the position and to contact you We have a legitimate interest in processing this data (in accordance with Article 6(1)(f) of the GDPR). This is because otherwise we will not be able to assess your suitability for the position and/or we will not be able to contact you

 

How do we protect your personal data?

 

OpenUp takes many measures to protect your personal data, both on a technical and organisational level. We are ever vigilant about this to ensure that your data is processed in a careful manner. We do this by:

 

  • Taking appropriate measures so that your personal data is safe, given the possible risks. For example, we have an external audit carried out annually to assess if our measures comply with the latest information security standards.
  • Making sure that the OpenUp employees who can view your personal data are obligated to maintain confidentiality. It is good to note that all our psychologists (coaches) are held to strict standards of professional secrecy. In addition, they and the other OpenUp employees are also contractually bound to confidentiality.
  • Setting up user names and passwords on all of our systems. We test these systems regularly, with the help of professional experts, to make sure that they are working and robust.
  • Anonymising or pseudonymising your personal data, where possible, to ensure your privacy in the event of possible breaches.

 

With whom is your data shared?

 

OpenUp might share your personal data with the following parties:

 

  • With you as a user.
  • OpenUp employees who are directly involved with coaching you as a user, but only to the extent that the data is necessary for them to carry out their work.
  • OpenUp employees who are engaged in administration and conducting research to improve our services. These employees only have access to personal data that has been anonymized or is under pseudonyms.
  • Some mother, sister and/or daughter companies of OpenUp. These are OpenUp Technologies B.V. (this entity manages and develops the software that is used to carry out our services) and OpenUp Medical B.V. (only if you are also making use of the OpenUp Medical B.V. services).

 

In addition, we may engage other service providers (“processors”) to process your personal data. In these cases, they will work exclusively according to the OpenUp instructions and guidelines. We have entered into a processing agreement with these processors that fulfils the requirements set out in the GDPR. An overview of processors can be found below:

 

Processor Goal
24sessions Video calls with our coaches
Microsoft Azure Hosting data from files
Google For email contact and analysis website usage
Sendgrid Sending emails from our platform
ActiveCampaign Sending OpenUp updates and newsletters
Livestorm Participating in OpenUp Spaces
Voys Telephone contact (only when calling one of our local numbers)
Mollie Payment for our services (only when you pay for OpenUp yourself and not your employer)
Greenhouse Support with your job application (only when you apply for a job at OpenUp)

 

Your personal data will only be shared with other parties if there is grounds for this. We will never share your personal data with your employer. We will also never share your data with third parties for commercial purposes without first asking your permission. In this case, only the necessary contact information will be shared.

We recommend that you also read the privacy policies for the above-mentioned companies.

 

Where do we store your data?

 

We store your well-being data on servers located within the European Union.

 

How long will your data be stored?

 

We like getting to know you, but we will never store your personal data for longer than necessary. For this purpose, we observe the following retention periods:

 

1- Data about your personal situation and health


We store this for three years after you stop using the OpenUp services unless you give us permission to keep the data beyond this period.

 

2- Financial and administrative data

 

We keep this for seven years after collecting the data.

 

3- Data from employees and freelancers, excluding (financial and) administrative data
This is kept for seven years after leaving employment or after the end of the assignment contract. A copy of your passport is kept for five years and other data from your personnel file is kept for two years.

 

4- Data from applicants


These are kept for a maximum of four weeks after completion of the application process unless we have obtained your consent to keep them longer. If so, this is for the maximum duration of one year.

 

5- Visitors to the website


These are stored for a maximum of two years after the last visit to the website unless an objection is made earlier. In this case, we will proceed to delete this data.

 

What about cookies and other technology on the website?

 

First and foremost, we are a mental health platform. We mainly use our website to share information and to engage you as a (prospective) user.

 

On our website, we use cookies and similar technologies. We use automatically collected information and other information collected on the website to: (i) personalise our services, for example by remembering information so that you don’t have to keep re-entering it during your visit or subsequent visits; (ii) offer customised content and information; (iii) monitoring and analysing the effectiveness of our services; (iv) monitoring aggregate statistics related to the usage of the site, for example, the total number of visitors and pages viewed. When you first visit our website, we will ask for consent to set up various cookies. You can change your choice at any time or revoke consent via the “cookie preferences” in the footer of the website.

 

For more information about cookies, visit http://www.allaboutcookies.org.

 

What if you want to view, change or delete your personal data?

 

If you have questions or want to know what personal data we hold of yours, then you can always contact us via privacy@openup.com

 

Amongst other things, you can: 

  • Find out exactly what personal data we have of yours and how we are using it
  • Exercise your right to obtain data from us, so that you can transfer it (data portability)
  • Have mistakes corrected
  • Have outdated personal data deleted
  • Withdraw your consent to have your personal data processed
  • Object to a particular usage of your personal data

 

More specifically, your coach can always show you the data contained in your file, if requested. Your coach can also share a copy of your file with you. If you want to view your file or receive a copy from us, please send this request via email to privacy@openup.com. If you believe that the personal data in your file is factually incorrect, then you can ask your coach to correct this data.

 

If you want to have your personal data deleted before the expiration of the retention period specified by us, then you can also send a request for this by email (privacy@openup.com). In most cases, we will respond to your request as quickly as possible and delete your personal data.

 

The right to lodge a complaint

 

If you have a complaint about the manner in which we process your personal data, please email us at privacy@openup.com, or discuss it directly with your coach. We are happy to help and will, of course, endeavour to solve any complaints to your satisfaction. It is also possible to lodge a complaint with a supervisory authority (such as the ICO in the UK).

 

Any further questions?

 

If anything is troubling you, by all means, ask. You can email your questions to us at privacy@openup.com, or ask your coach directly. Whatever your question, we are happy to help!

 

 

Imprint

 

Operator & Responsible:

OpenUp BV

Nieuwe Herengracht 47, 1011 RN, Amsterdam, The Netherlands

Legal representatives: Gijs Coppens & Rik Plender

Chamber of commerce ID: 77340159

VAT ID: NL860976993B01

 

Contact:

Tel.: +31 20 2444 888 (Netherlands) +49 30 30808172 (Germany)

E-Mail: team@openup.com

Website: www.openup.com

 

Information regarding professional liability insurance:

Name and registered office of the insurer:

Nationale Nederlanden

Princess Beatrixlaan 35

2509AV The Hague

Scope of insurance: International

 

EU dispute resolution and consumer arbitration board:

The European Commission provides a platform for online dispute resolution (ODR), for more information on this platform click here: https://ec.europa.eu/consumers/odr/. OpenUp is not obliged to participate in dispute resolution proceedings in front of a consumer arbitration board. In case there is a (potential) dispute please contact our team through team@openup.com