Privacy Policy & Cookie Statement
Art. 1 Who We Are — The Data Controller
- Name
- Van Hove, Tuur — doing business under the name Puur na Tuur
- CBE number
- BE 0500.470.609
- Address
- Rue de Linsmeau 8, B-4287 Racour, Belgium
- tuur@puur-na-tuur.be
- Phone
- +32 486 23 55 53
- Website
- pure-after-hours.com
Puur na Tuur performs as data controller for the processing of personal data collected through the website, during registration, in the context of counseling, or by other means.
Art. 2 What personal data do we process?
We process only the data necessary for the purposes described below. Depending on the context, this may include:
Identification and Contact Information
- Last Name and First Name
- Email address and phone number
- Home or temporary address
- VAT number (for business clients)
Information Related to Counseling
- Information about your health, mental well-being, and personal circumstances that you share during the intake or sessions
- Meeting Notes and Process Reports (for internal use only)
- Appointments, Invoice History, and Payment Information
Website Use
- IP address and browser data (via cookies—see Article 10)
- Pages visited, time of visit, referring URL
- Data entered via contact forms or registration forms
Email Marketing
- Email address and first name (when signing up for the newsletter or free challenge)
- Behavioral data: opens, clicks (via MailerLite)
Art. 3 Why is data processed, and how long is it retained?
We process personal data only for specific, explicit, and legitimate purposes based on a valid legal basis.
| Purpose | Legal Basis | Retention Period |
|---|---|---|
| Implementation of the coaching agreement (sessions, programs, training courses) | Performance of a Contract — Art. 6(1)(b) of the GDPR | 10 years after the last session (therapists' professional obligation) |
| Billing and Accounting | Legal obligation — Art. 6(1)(c) of the GDPR | 7 years (Belgian accounting laws) |
| Responding to Questions and Contact Requests | Legitimate Interest — Art. 6(1)(f) of the GDPR | 2 years since the last contact |
| Sending newsletters and marketing communications | Consent — Art. 6(1)(a) of the GDPR | Until consent is revoked + 1-year retention period |
| Analysis of Website Usage Using Google Analytics | Consent — Art. 6(1)(a) of the GDPR | 26 months (standard Google Analytics retention period) |
| Website Security and Prevention of Abuse | Legitimate Interest — Art. 6(1)(f) of the GDPR | 90 days (log files) |
Once the retention period has expired, data is securely destroyed or anonymized, unless a legal obligation requires longer retention.
Art. 4 Special Categories of Personal Data
As part of its body-oriented counseling services, Puur na Tuur processes data regarding health and mental well-being — these are special categories within the meaning of Article 9 of the GDPR.
This data is processed solely for the following purposes:
- based on your express consent (Art. 9(2)(a) of the GDPR), provided during the intake or through the client agreement, or
- to the extent that this is necessary for the provision of preventive or curative health care or the provision of health services (Art. 9(2)(h) of the GDPR).
This information is never shared with third parties outside the immediate counseling context, unless you have given your explicit consent or a legal obligation requires it.
Art. 5 Sharing with Third Parties
Puur na Tuur does not sell personal data or disclose it to third parties for commercial purposes. Data may be shared with:
- Processors that provide services on behalf of Puur na Tuur and are bound by a data processing agreement in accordance with Article 28 of the GDPR:
| Processor | Service | Location |
|---|---|---|
| MailerLite | Email Marketing and Newsletters | EU (GDPR-compliant) |
| Google LLC | Google Analytics, reCAPTCHA, Google Tag Manager | U.S. — see Art. 6 |
| SYS Platform | Website Hosting and Management | Netherlands (EU) |
| Clientomgeving.nl | Online Calendar Management and Bookings | Netherlands (EU) |
| WooCommerce / Automattic | Online Store and Payment Processing | U.S. — see Art. 6 |
- Co-facilitators for group programs (e.g., Gerda van den Top at Je Ware Aard), solely to the extent necessary for the program’s implementation and based on a confidentiality agreement.
- Competent Authorities, when Puur na Tuur is legally required to do so.
Art. 6 Transfer of Data Outside the European Economic Area
Some processors (Google, WooCommerce/Automattic) are based in the United States. The transfer of personal data to these processors is based on:
- the EU-U.S. Data Privacy Framework (European Commission Adequacy Decision of July 10, 2023), to the extent that the processor is certified under it, and/or
- Standard Contractual Clauses (SCCs) Approved by the European Commission (Implementing Decision 2021/914).
Art. 7 Protection of Personal Data
Puur na Tuur takes appropriate technical and organizational measures to protect personal data against loss, unauthorized access, disclosure, or destruction, including:
- Encrypted connection (HTTPS/TLS) for the website
- Access to client data is limited to Puur na Tuur itself
- Use of Secure and GDPR-Compliant Processors
- Regular updates to software and security components
- Strong password security and two-factor authentication wherever possible
In the event of a data breach that poses a risk to your rights and freedoms, Puur na Tuur will notify the competent supervisory authority (GBA) within 72 hours and inform you as soon as possible.
Art. 8 Your Rights as a Data Subject
Under the GDPR, you have the following rights regarding your personal data:
You have the right to request information about the data we process about you and to receive a copy of it.
You can have incorrect or incomplete information corrected or supplemented.
You may request that your data be deleted, unless a legal obligation requires that it be retained.
You can have the processing restricted while a request is being processed.
You can request data that you have provided yourself in a readable format.
You may object to processing based on legitimate interests.
Consent may be withdrawn at any time, without providing a reason.
By clicking the unsubscribe link in each email or by contacting us directly.
Please send your request by email to tuur@puur-na-tuur.be, including your name and a copy of your ID for verification. We will respond within 30 days. In the case of complex or numerous requests, this period may be extended by up to 2 months, provided that notice is given.
Art. 9 File a Complaint
If you believe that your personal data is being processed unlawfully, you have the right to file a complaint with the competent supervisory authority:
- Authority
- Data Protection Authority (GBA)
- Address
- 35 Drukpersstraat, 1000 Brussels
- contact@apd-gba.be
- Website
- data-protection-authority.be
- Phone
- +32 2 274 48 00
We would appreciate it if you would first give us the opportunity to address your concerns via tuur@puur-na-tuur.be.
Art. 10 Cookie Policy
What are cookies?
Cookies are small text files that are stored on a visitor's device when they visit a website. They are classified as follows:
- Duration: persistent cookies (remain after the browser is closed) vs. session cookies (disappear after the browser is closed)
- Origin: First-party cookies (set by this website) vs. third-party cookies (set by external services)
- Objective: functional, analytical, or marketing
What cookies does puur-na-tuur.be use?
| Cookie / Service | Type | Purpose | Retention Period | Is permission required? |
|---|---|---|---|---|
| Preference cookies (language, session) | Functional | Saving user settings to improve the website's performance | Session or up to 1 year | No — absolutely necessary |
| WordPress / WooCommerce Session Cookies | Functional | Login status, shopping cart, security tokens | Session of up to 14 days | No — absolutely necessary |
| Google Analytics (_ga, _gid, _gat) | Analytical | Anonymous analysis of website visits (pages, duration, source) | Up to 26 months | Yes — requires consent |
| Google Tag Manager | Analytical | Managing tracking scripts without code changes | Session | Yes — requires consent |
| Facebook Pixel | Marketing | Measuring ad performance, retargeting | Up to 180 days | Yes — requires consent |
| Google reCAPTCHA | Functional | Protecting Forms from Spam and Bot Requests | Session / 6 months | In part — see Art. 11 |
Manage and Delete Cookies
You can manage cookies using the cookie banner when you first visit the website. You can withdraw any consent you have previously given at any time through the cookie management settings at the bottom of the website.
You can also delete or block cookies directly through your browser. Please refer to your browser's help section:
Please note: Disabling certain cookies may affect the website's functionality.
Google Analytics and Opt-Out
Google Analytics processes anonymous statistics regarding the use of this website. IP addresses are automatically anonymized (IP masking enabled). Data is not linked to personally identifiable information.
Do you want to completely opt out of Google Analytics? If so, install the Google Analytics Opt-out Browser Add-on.
More information: Google Privacy Policy.
Art. 11 Google reCAPTCHA
Puur na Tuur uses Google reCAPTCHA (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to protect contact forms from automated bots and spam.
When using reCAPTCHA, the IP address and possibly other data (browser type, screen resolution, mouse movements) are sent to Google. Within the EEA, the IP address is truncated before being stored (IP masking). In exceptional cases, a full IP address is sent to a Google server in the U.S. and is truncated there.
Google uses this data solely to determine whether the interaction with the form is being carried out by a human. The results are reported back to Puur na Tuur in the form of a score.
Legal basis: legitimate interests (Art. 6(1)(f) of the GDPR) — protection of the website against misuse. More information: Google Privacy Policy and Terms of Service.
Art. 12 Changes to This Policy
Puur na Tuur reserves the right to amend this privacy policy and this cookie statement at any time—for example, in the event of changes to our services, legislation, or the technologies we use.
In the event of significant changes, you will be notified via the website or by email. The date of the most recent version is always listed at the top of this document. We recommend that you review this policy periodically.
Art. 13 Contact and Questions
If you have any questions about this privacy policy, exercising your rights, or withdrawing your consent, please contact us at:
- tuur@puur-na-tuur.be
- Post
- Puur na Tuur - Tuur Van Hove - Rue de Linsmeau 8 - B-4287 Racour
- Phone
- +32 486 23 55 53
We will respond within 30 days to every request or question.