Control over your life and control over your data

At Vitalmindz, your privacy comes first. When using the Vitalmindz App, you share personal data with us (“data”). We use your data to ensure you can use the Vitalmindz App in the most optimal way.

Invest in the mental health and vitality of your employees with the Vitalmindz App. Our app offers personal support, from individual coaching to chatting with a psychologist, and promotes mental growth with customized content. Strengthen the sustainable employability of your team by focusing on what goes well and increasing vitality and job satisfaction, leading to a healthier organization with less absenteeism and turnover.

We are Vitalmindz B.V., part of the Mental Care Group (including BeterCo B.V. and all its subsidiaries). We provide Services to Users. From our Shared Service Center (SSC B.V.), we ensure a high level of data protection across the entire group. Vitalmindz B.V. is, as part of the Mental Care Group, together with SSC B.V., responsible for processing your data in accordance with the General Data Protection Regulation (“GDPR”). This privacy statement aims to inform you about how we (Vitalmindz B.V. and SSC B.V.) process and protect your data.

Your contact person regarding the processing of your data is the Privacy Officer, who works for the entire Mental Care Group, reachable at privacy@mentalcaregroup.nl. Of course, you can also always ask your Coach first. If necessary, they will forward your question to the Privacy Officer.

This privacy statement is written for (former) Users of the Vitalmindz App.

Which data do we use from our (former) Users?

• Your contact details, such as your name, phone number, and email address;
• Your health data, such as the results from the Vitality Meter and information you share with us for the diary;
• Any other data you share with us, for example, if you ask us a question.

On what basis do we use your data?

We process your data based on one or more of the following grounds:

• If you have given (explicit) consent (in accordance with Article 6(1)(a) and Article 9(2)(a) GDPR). You give explicit consent when you log in to the Vitalmindz App for the first time. You can withdraw your consent at any time in the Vitalmindz App by deleting your account. Without your consent, we cannot process (most of) your data, meaning we cannot offer you the Services.
• The processing is necessary to comply with our legal obligations (in accordance with Article 6(1)(c) GDPR), or
• The processing is necessary for the legitimate interests of Vitalmindz, and your interests (such as your right to privacy) do not override these (in accordance with Article 6(1)(f) GDPR).

For what purposes do we use your data?

• To provide our Services to you.
• To stay in contact with you, for example, to send you appointment confirmations. You cannot opt out of this type of contact. Sometimes, we also want to contact you to send newsletters or satisfaction surveys. You can sign up for this type of contact via the website and always opt out via the unsubscribe button in the email.
• To handle questions, complaints, and disputes. If you file a complaint with us, it will be reviewed by our Complaints Officer, who will then contact you and, if necessary, request your explicit consent to view and discuss your health data with your Coach. If you do not give this consent, we may not be able to handle your complaint.
• Scientific and statistical research. Sometimes, we use part of your data to see, among other things, how many Users have signed up and how many appointments have been scheduled. We cannot directly see that the data is about you but use it to perform an analysis.
• To measure the effectiveness of our Services and improve quality. We are always working to improve our Services. Therefore, we also use the outcomes of the Services to learn from. We do this as anonymously as possible, but if there is still personal data processing, we have a legitimate interest in doing so.
• To comply with laws and regulations, or orders and rulings from competent authorities (such as the court).

With whom do we share data?

All your data is confidential, but this does not mean we never share data with other parties. Below we explain why we share data with certain parties and for what reason we are allowed to do so. We never sell your data. To anyone.

We may share data with:

• Parent, sister, and/or subsidiary companies of Vitalmindz B.V., for the purpose of managing and developing the Vitalmindz App software, administering the Services, and conducting research to improve our Services. We have made clear agreements about this within the form of an intragroup data processing agreement.
• Our processors. To process your personal data, we may engage other service providers, called Processors. These include hosting providers and IT service providers who assist us with our Services. We make good agreements with our processors that comply with GDPR requirements.

No international data transfer

We do not transfer data outside the European Economic Area (EEA).

No profiling or automated decision-making

We do not profile you based on your data and do not use automated decision-making.

Data retention

We do not retain your data longer than necessary. How long this is depends on the purpose of the processing. All data in your account is retained for up to one year after your last use unless there are reasons to retain the data in your account longer. This may be because there is a complaint or lawsuit ongoing, and if required by law. Afterward, we delete your data or anonymize it.

If we anonymize your data, we delete all data that refers to you. The data can no longer be linked to you. Using this anonymous data, we conduct scientific and statistical (market) research, for example, to develop Services or better tailor our offerings and Services to the needs of our Users.

How do we ensure your data is secure with us?

We do everything to ensure your data is secure with us. This includes:

• Screening employees and ensuring every employee is bound to confidentiality by law, professional codes, or contract.
• Securely protecting our systems, for example, by securing internet connections, using two-factor authentication, and logging activities in our systems.
• Having ourselves audited by an external party, resulting in a NEN 7510 certificate. This certificate shows that we securely protect our information.
• Continuously and periodically focusing on training and awareness in this area.

Despite all the measures we have taken, have you found a (security) problem? Please report it to us via security@mentalcaregroup.nl.

Your privacy rights

Below is an overview of the rights you have regarding our use of your data. These rights are not absolute: this means that we will always consider whether we should comply with a request to exercise your rights.

Withdraw consent

You can withdraw your consent at any time in the Vitalmindz App by deleting your account. You do not need to provide a reason. Without your consent, we cannot process much of your data and cannot continue to offer you the Services. If you wish, you can create a new account at any time after withdrawing your consent.

Correction

If you see factual inaccuracies in your data, you may ask us to correct them. You can also do this yourself as much as possible in the Vitalmindz App.

Access and copy

As a User, you can view your data as much as possible through the Vitalmindz App. Additionally, you can ask us to provide you with a copy of your data.

Deletion / destruction

You can ask us to delete your data. Usually, we can do this for you, but sometimes this is not possible (completely), for example, because we need to retain certain data by law or because we otherwise cannot provide you with good Services. If we cannot delete your data, we will always explain why not.

Restriction / temporary halt

You can also ask us to temporarily stop using your data. For example, because you have informed us that you think your data is incorrect or should no longer be processed and we are still investigating this. In the meantime, you can ask us not to use your data.

Objection

Sometimes, we use your data for our legitimate interests. If we do this, you can object if you think this is particularly disadvantageous for you personally. We will then carefully consider whether we should stop using your data because of your specific situation.

Portability

Additionally, you can request that we transfer your data to another party. You only have this right concerning data about you that you have provided to us and that we process based on your consent.

Want to know more about your rights? Check here on the website of the Dutch Data Protection Authority.

How can i exercise my rights

You can exercise your privacy request as much as possible in the Vitalmindz App or by submitting a direct request via email: support@vitalmindz.nl.

In most cases, we can fully handle your request within a week. Sometimes this is not possible, but you will always receive an initial response within four weeks and a final response within three months. You will also receive a response if we believe we cannot comply with your request.

A Coach always has the option to make an independent decision and partially refuse a request if they believe it is necessary for the User's interests.

Changes to the privacy statement

If there is a change in how we process your data, we will update our privacy statement accordingly. For major changes or changes that significantly impact your privacy, you will be notified. You can always find the latest version of our privacy statement on this website.

This latest version of the privacy statement was created on April 15, 2024.

Do you have a complaint or want to report something?

Do you have a privacy complaint or want to report something to the internal supervisor of the Mental Care Group? Send an email to the Data Protection Officer at fg@mentalcaregroup.nl. You can also send a letter to:

VitalMindz B.V.
Attn: Data Protection Officer
Steijnlaan 12
1217 JS Hilversum

If we cannot resolve the issue together, you can submit your complaint to the Dutch Data Protection Authority.