Privacy policyHAMAE & POLYWIJS

1. About this policy

At HAMAE and PolyWijs, we work with personal stories, questions and experiences. We treat this information carefully and confidentially. This privacy policy explains which personal data we use, why we use it and what rights you have.

This policy applies to our websites, enquiries and introductory meetings, coaching, relationship guidance, programmes, workshops, group meetings and online activities.

2. Who is responsible

HAMAE is the business of Elisabeth de Charon de Saint Germain, based at Madeweg 3, 8386 XA Doldersum, the Netherlands, and registered with the Dutch Chamber of Commerce under number 96524111. For privacy enquiries, please write to elisabeth@hamae.org.

PolyWijs is a collaboration between HAMAE and Schaeffer-Mediation, the business of Herman Schaeffer. Each business is responsible for the personal data it processes in the course of its own activities. Where we jointly determine the purposes and means of processing personal data, we share responsibility for that processing and coordinate how it is carried out.

In his work as a certified mediator, Herman Schaeffer is also bound by the applicable legal and professional obligations. Guidance provided through PolyWijs constitutes mediation only when this has been expressly agreed.

For privacy enquiries about PolyWijs, you can contact either Elisabeth or Herman. You do not need to work out who should handle your request.

3. Which data we use and why

We process data needed to communicate with you, deliver our services with care and maintain our administration. This may include your name, contact details, appointments, registrations, payments, correspondence and relevant information about the support you are seeking.

During a programme, we may keep brief notes to help us tailor the guidance appropriately. Online programmes may also involve processing account and participation data. Our websites may process technical data needed for their operation and security.

We use this data to prepare or perform a contract, comply with legal obligations or pursue a legitimate interest, such as security and sound business administration. In doing so, we take your privacy interests into account. Where consent is required, we request it separately.

If certain data is necessary to provide a service, we explain this. Without that data, it may not be possible to provide the relevant part of the service.

4. Personal and sensitive information

During guidance, you may share information about matters such as your health, relationships, sexuality or beliefs. We only request and retain what is needed for the agreed purpose.

Additional legal requirements apply to special categories of personal data. Where we process this data on the basis of consent, we request your explicit consent. Sharing a personal story does not mean that you agree to its publication, use for marketing or other use outside the guidance.

You may withdraw your consent at any time. If this affects the guidance, we will discuss the implications with you.

5. Confidentiality and collaboration

Personal information is accessible only to those who need it for their work. Within PolyWijs, Elisabeth and Herman share information to the extent necessary and permitted for the guidance they provide together.

In relationship guidance, participation does not automatically give one partner access to all of the other partner’s individual information. We agree appropriate arrangements for confidentiality and feedback in advance.

During group activities, we ask participants to treat other people’s stories and personal data as confidential. We do not share contact details with other participants without an appropriate legal basis. We cannot fully control participants’ actions outside our meetings.

6. Recordings and artificial intelligence

We inform you in advance when a meeting will be recorded: what will be captured, why the recording is being made and who will be able to view it. Where required, we request separate consent to record or publish identifiable participants and personal contributions.

Consent to a recording is not general consent to publication, advertising or AI processing.

When using digital tools, including AI, we take the confidentiality of client data into account. Identifiable client information is processed only where there is a valid legal basis and appropriate agreements and security measures are in place. Additional requirements apply to special categories of personal data. Where necessary, we inform you in advance and request separate consent.

Removing a name alone does not always make a story anonymous. Its content and context may also make someone identifiable.

7. Service providers

We use external service providers for purposes such as email, scheduling, payments, video calls, administration and online programmes. They receive only the data needed for their function.

Where they process personal data on our behalf, we make appropriate arrangements concerning confidentiality, security and use. Where data is processed outside the European Economic Area, the safeguards required by law must be in place. You may ask us which safeguards apply and how to obtain a copy of them.

Some providers, such as payment or booking services, also have their own responsibility for certain data processing activities.

8. How long we retain data

We retain personal data no longer than necessary for the purpose for which it was collected.

In determining this, we consider the duration of the contact or programme, necessary follow-up, the nature and sensitivity of the information, and any legal or professional obligations. We retain financial records in accordance with statutory retention requirements. Those requirements do not automatically apply to substantive guidance notes.

For recordings and access to online programmes, we specify the applicable availability or retention period in the relevant offer or when the recording is made. Data that is no longer needed is deleted or effectively anonymised.

9. Newsletters and website use

We request consent for newsletters unless a statutory exception applies. You can unsubscribe easily. Necessary messages about a service you have booked are separate from this.

Our websites may use functional and analytical cookies. For tracking cookies and other technologies that require consent, we request that consent in advance. Where these technologies are used, you can find further information in the cookie settings and change your preferences there.

10. Security and your rights

We take appropriate measures to protect personal data against loss, unauthorised access and unlawful use.

You may ask us to access, correct or delete your data. Subject to the conditions of the GDPR, you may also request restriction of processing or data portability, and object to certain processing activities. You may withdraw consent at any time; this does not affect the lawfulness of processing carried out before withdrawal.

We normally respond within one month. If a legally permitted extension is necessary, we will inform you within that first month. When handling requests, we also protect the privacy of other individuals concerned.

For questions or requests, please contact elisabeth@hamae.org or, for PolyWijs, contact Herman and Elisabeth together directly at polywijs@gmail.com. You may also lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.

11. Changes

We may update this privacy policy when our activities or legal obligations change. The current version is published on our websites. Where necessary, we inform those concerned directly of significant changes.