Privacy Policy 
Nurturing Minds Health Consultancies FZE-LLC

1. Introduction
   
   This Privacy Policy explains how Nurturing Minds Health Consultancies FZE-LLC ('Nurturing Minds', 'we', 'our', 'us') collects, uses, stores, and protects personal data in accordance with the EU General Data Protection Regulation (GDPR), the Dutch UAVG, and the UAE Federal Decree-Law No. 45 of 2021 (PDPL).

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1.  Data Controller:   Nurturing Minds Health Consultancies FZE-LLC is the data controller responsible for your personal data.
 
 Address: 19 Dedicated Desk #73-DARTX, Sheikh Rashid Tower, Dubai, UAE
 License: L-3938 | Dubai World Trade Centre Authority
 
 EU Representative (Article 27 GDPR): [To be appointed – name, address, and contact details will be provided once designated].

2. Scope and Legal Framework:   

• This policy complies with:

•  EU General Data Protection Regulation (Regulation (EU) 2016/679)


•  Dutch Implementation Act (UAVG)


•  UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and its Executive Regulations (Cabinet Decision No. 34/2022)


•  WGBO and relevant healthcare confidentiality laws applicable to psychological services in the Netherlands.

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1. Scope and Legal Framework: This policy complies with:


•  EU General Data Protection Regulation (Regulation (EU) 2016/679)


•  Dutch Implementation Act (UAVG)


•  UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and its Executive Regulations (Cabinet Decision No. 34/2022)


•  WGBO and relevant healthcare confidentiality laws applicable to psychological services in the Netherlands.

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4. Categories of Data Collected:  We collect and process personal data necessary for providing psychological and mental health services, including:
 

• Identification details (name, contact information, date of birth)

• Health and mental health information (intake forms, session notes, treatment plans)


• Payment and administrative details


• Communication records
 
 Special category data are processed under Article 9(2)(h) GDPR for healthcare purposes or Article 9(2)(a) GDPR with explicit consent.

5. Purposes and Legal Bases for Processing:  We process personal data for the following purposes:


• Providing psychological assessments and treatment – Art. 6(1)(b) GDPR, Art. 9(2)(h) GDPR


• Managing appointments and communication – Art. 6(1)(b)


• Invoicing and financial administration – Art. 6(1)(c)


• Compliance with legal obligations (healthcare documentation) – Art. 6(1)(c)


• Consent-based processing (e.g., testimonials, mailing list) – Art. 6(1)(a)
 Under the UAE PDPL, processing is lawful when necessary for contract execution, consent, or legal obligation.

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6. Data Storage and Retention:  Personal data are securely stored in systems hosted in the Netherlands (EPOS-ZILOS, ISO-certified clinical data service). Retention follows Dutch healthcare record requirements (minimum 15 years for health data, unless otherwise required).

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7. International Data Transfers: Data may be transferred between the EU/EEA and the UAE to facilitate service provision. All such transfers comply with Chapter V of the GDPR using EU Standard Contractual Clauses (SCCs) and risk assessments. Under the UAE PDPL, transfers occur where adequate protection is ensured or consent obtained.

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8. Data Security: We implement organisational and technical safeguards to protect personal data, including encryption, access controls, and secure data hosting. Only authorised personnel bound by confidentiality have access to client data.

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9. Data Subject Rights: Under GDPR and PDPL, individuals have rights to:


• Access their data


• Rectify inaccuracies


• Erase data (where applicable)


• Restrict or object to processing


• Data portability


• Withdraw consent at any time
 


Requests may be sent to: contact@nurturingmindshc.com

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10. Sharing of Data: Personal data is shared only with authorised professionals involved in care delivery and administrative management. We do not sell or disclose personal data to third parties for marketing purposes.

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11. Cookies and Website Tracking: Our website uses only essential cookies necessary for its proper functioning. We do not use profiling or advertising cookies without explicit consent.

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12. Contact and Complaints: If you have any questions or concerns about data protection, please contact us at:
 Email: contact@nurturingmindshc.com 

For EU residents, you may also contact the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). In the UAE, you may contact the UAE Data Office.

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13. Updates to this Policy: We may update this Privacy Policy to reflect changes in law or practice. The updated version will be published on our website with the revised date.

14. Acknowledgement: By using our services, you acknowledge that you have read and understood this Privacy Policy.