Privacy Policy – Pijnvrij, Painfree and Reducept VR

Reducept B.V. takes your privacy seriously. This Privacy Policy explains which personal data we process when you use Pijnvrij, Painfree and Reducept VR, why we process this data, where it is stored and what rights you have.

An important principle in the development of our apps is privacy by design. Reducept stores only a limited amount of personal data centrally. Personal information you enter during the training, including answers to questions and writing exercises and conversations with the AI chatbot, remains stored exclusively locally on your own phone. Reducept does not receive this information and cannot access it.

1. Who is responsible for your personal data?

Reducept B.V. is responsible for the processing of personal data described in this Privacy Policy.

Reducept B.V.
Sophialaan 1A
8911 AE Leeuwarden
The Netherlands

Dutch Chamber of Commerce (KvK): 74239678
Email: info@reducept.com

2. Which services does this Privacy Policy apply to?

This Privacy Policy applies to consumers using:

the Pijnvrij app;
the Painfree app and all translated and localised versions of the Painfree app, regardless of the language or country in which they are made available;
Reducept VR and its translated and localised versions;
your Reducept/Pijnvrij/Painfree account; and
related digital services provided by Reducept.

Pijnvrij/Painfree and Reducept VR can be used together as one training programme. Where this Privacy Policy refers to the Services, it refers collectively to all versions and services listed above.

3. Which personal data does Reducept store centrally?

Reducept aims to minimise the amount of personal data stored centrally.

To provide the Services, we centrally store the following personal data:

your name;
your email address;
your wellbeing score; and
where applicable, the healthcare professional, practice or healthcare organisation to which your account is linked.

The wellbeing score is a single number that you can enter periodically to indicate how you feel about your wellbeing at that moment. Reducept does not calculate this score from your answers, writing exercises, AI chatbot conversations or other personal information.

Because this score may provide information about your wellbeing and potentially your health, we choose to treat the wellbeing score as health data and protect it accordingly.

You can use Pijnvrij/Painfree independently. A connection with a healthcare professional, practice or healthcare organisation is not required. Where your account is linked, we centrally store this connection so that, with your consent, your healthcare professional can follow your wellbeing score and support you in using the training.

If you have a paid subscription, we also process the limited information necessary to administer the status and duration of your subscription and confirmation of your payment.

If you contact us directly, for example by email for support, we also process the information that you choose to provide to us in that communication.

4. Which information remains exclusively on your phone?

During the training, you can enter personal information.

This applies in particular to:

answers to questions and exercises;
answers you enter during writing exercises;
personal notes and reflections within these exercises; and
the content of your conversations with the AI chatbot.

This information is stored exclusively locally on your own phone.

This information is not sent to Reducept or to our server. Neither Reducept nor our technical partner Alserda receives this information or can access it.

This locally stored information is also not used to calculate your wellbeing score. Your wellbeing score is the separate number that you choose to enter periodically.

Because Reducept does not have access to this locally stored information, we cannot retrieve it for you if you delete it, uninstall the app, or lose or replace your phone.

5. Use of the AI chatbot

Pijnvrij/Painfree includes an AI chatbot that can support you during the training.

The content of your conversations with the AI chatbot remains exclusively on your phone.

Reducept does not receive or store these conversations and cannot access them. No user data from these conversations is sent to an external AI provider.

The content of your conversations is not used by Reducept to train external AI models.

6. Why do we use the personal data stored centrally?

We use your personal data only insofar as necessary to:

create and manage your account;
provide you with access to Pijnvrij/Painfree and Reducept VR;
store the wellbeing scores you enter and make them available to you so that you can follow the development of your wellbeing score over time;
where you choose to link your account to a healthcare professional, practice or healthcare organisation, make your wellbeing score available to your linked healthcare professional with your explicit consent so that they can follow its development;
manage your subscription;
administer payments and their status;
where applicable, administer our cooperation with participating practices and any partner or affiliate fees;
provide support when you contact us;
send necessary communications about your account, subscription or the Services;
maintain the security and proper functioning of our Services; and
comply with legal obligations.

Because Reducept has no access to information stored exclusively on your phone, we do not use or share the content of your questions, answers, writing exercises, personal notes, reflections or AI chatbot conversations for these purposes.

7. What is our legal basis for processing your data?

We process your name, email address and the information necessary to manage your account and subscription because this processing is necessary for the performance of our agreement with you.

Where we are required to process personal data to comply with a legal obligation, we base that processing on the relevant legal obligation.

Because we choose to treat the wellbeing score as health data, we process this score on the basis of your explicit consent.

Before your wellbeing score is stored centrally, we ask you for this consent. Entering a wellbeing score is voluntary.

If you choose to link your account to a healthcare professional, practice or healthcare organisation, we additionally ask for your explicit consent to make your wellbeing score and its development available to your linked healthcare professional.

Linking your account to a healthcare professional is not required to use Pijnvrij/Painfree. Your wellbeing score will not be shared with a healthcare professional without your consent.

You may withdraw your consent to the processing of your wellbeing score and/or its sharing with your healthcare professional at any time. If you withdraw your consent to sharing, we will no longer make your wellbeing score available to that healthcare professional from that point onwards.

If you withdraw your consent to the central processing of your wellbeing score, we will no longer process the score on the basis of that consent and will delete the data unless we have a legal obligation to retain certain information.

Withdrawal of your consent does not affect the lawfulness of processing carried out before your consent was withdrawn.

8. Who do we share your personal data with?

Reducept does not sell your personal data.

To provide our Services, we use a limited number of specialised service providers.

Alserda – technology and hosting

Alserda is Reducept's technical partner and provides the technical infrastructure and hosting for the Reducept Services.

Personal data stored centrally by Reducept is stored on a server hosted by Alserda in the Netherlands.

This includes your name, email address and wellbeing score, any connection with a healthcare professional, practice or healthcare organisation, and the limited account information necessary to provide the Services.

Alserda does not receive the personal answers, writing exercises, notes, reflections or AI chatbot conversations that are stored exclusively locally on your phone.

Stripe – payments

We use Stripe to process and manage payments and subscriptions.

Stripe processes the payment information necessary to carry out your payment. Reducept receives from Stripe the information necessary to establish that a payment has been made and to manage your subscription.

Reducept does not store your full payment card details.

For certain processing activities, Stripe may act as an independent controller of personal data, for example where Stripe is required to process information to comply with its own legal obligations as a payment services provider.

Mailjet – email

We use Mailjet to send necessary emails concerning, for example, your account, subscription or our Services.

For this purpose, Mailjet receives the information necessary to send the relevant email, such as your email address.

Your linked healthcare professional or healthcare organisation

If you choose to link your account to a healthcare professional, practice or healthcare organisation and give your explicit consent, your wellbeing score and its development will be made available to your linked healthcare professional.

Your personal answers, writing exercises, notes, reflections and AI chatbot conversations are not shared with your healthcare professional or healthcare organisation.

Where a service provider processes personal data on behalf of Reducept, we put appropriate privacy and security arrangements in place.

9. Where is your data stored?

The personal data that Reducept itself stores centrally for Pijnvrij/Painfree and Reducept VR is hosted on a server in the Netherlands managed by our technical partner Alserda.

Personal answers, writing exercises, notes, reflections and AI chatbot conversations that are stored exclusively locally do not leave your phone.

For specific parts of our Services, such as payments through Stripe and sending emails through Mailjet, the necessary personal data is processed using the infrastructure of those service providers.

Where this involves processing personal data outside the European Economic Area, we ensure that the legally required safeguards for international transfers of personal data are in place.

10. How long do we retain your personal data?

We do not retain personal data for longer than necessary for the purpose for which it was collected or for as long as we are legally required to retain it.

Your account information and wellbeing scores are generally retained for as long as your account remains active and, where necessary, for a limited period afterwards for administration, support and the resolution of potential disputes.

Information forming part of our financial administration is retained for the applicable statutory retention period.

When personal data is no longer necessary, we delete or anonymise it.

Information stored exclusively locally on your phone is not managed by Reducept. You manage this information yourself through the app and your phone.

11. Security

Reducept takes appropriate technical and organisational measures to protect the personal data we process against loss, unauthorised access, unauthorised alteration and other forms of unlawful processing.

An important part of our security and privacy strategy is that personal information remains on the user's device wherever possible, rather than being stored centrally by Reducept.

You are responsible for adequately securing your phone and login credentials.

12. Your privacy rights

Depending on the circumstances, under the GDPR you have rights including the right to:

access your personal data;
have inaccurate personal data corrected;
have personal data deleted;
restrict processing;
object to certain processing;
receive or transfer your data; and
withdraw previously given consent.

You can exercise these rights by contacting us at info@reducept.com.

We may ask you to verify your identity before fulfilling a request.

Reducept cannot provide, modify, recover or delete information that is stored exclusively locally on your phone and to which we have no access.

13. Connection with a healthcare professional or healthcare organisation

You can use Pijnvrij/Painfree and Reducept VR independently. A connection with a healthcare professional, practice or healthcare organisation is not required.

If you use Pijnvrij/Painfree or Reducept VR through or in cooperation with a healthcare professional, practice or healthcare organisation, your account may be linked to that party.

When your account is linked and you have given your explicit consent, your healthcare professional can view your wellbeing score and its development over time. This enables your healthcare professional to follow your progress and support you in using the training.

Before your wellbeing score is made available to your healthcare professional, we ask for your explicit consent.

You can withdraw this consent at any time. From that point onwards, we will no longer make your wellbeing score available to the relevant healthcare professional.

Linking your account does not give your healthcare professional access to personal information that is stored exclusively locally on your phone. Your answers to questions and exercises, writing exercises, personal notes and reflections and the content of your AI chatbot conversations remain exclusively on your phone and are not shared with your healthcare professional, practice or healthcare organisation.

Reducept may also use the connection with a healthcare professional, practice or healthcare organisation to administer our cooperation with that party, including, where applicable, partner or affiliate fees.

14. Complaints

If you have a complaint about how we process your personal data, we encourage you to contact us first at info@reducept.com, so that we can try to resolve the issue.

You also have the right to lodge a complaint with the competent data protection authority. In the Netherlands, this is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

15. Changes to this Privacy Policy

We may update this Privacy Policy when our Services, technology or legal obligations change.

If a change has a material effect on how we process your personal data, we will inform you in an appropriate manner.

The most recent version is available through our website and/or apps.

16. Contact

For questions about this Privacy Policy or the processing of your personal data, please contact: