Your data. With care.

In short

ombra is an electronic patient record and practice software for psychologists and therapists. This statement is about what ombra itself does with data: your account, your connections, the website ombracare.com and your messages to us. What you keep about your clients, ombra processes only on your instructions. That is set out in the data processing agreement.

• We do not sell data and show no advertising.
• No analytics and no tracking cookies, on the website or in the app.
• Your data is stored in Microsoft Azure datacentres in Ireland, with a copy of the database backups in the Netherlands.
• We do not send your data or your clients’ data to AI services, and do not train AI models with it.
• Every time someone opens or changes a record, ombra records it.
• You export everything whenever you like, free of charge.

Who we are

ombra is established at Abeliaerf 37, 4125 WH Hoef en Haag, the Netherlands, registered with the Dutch Chamber of Commerce (Kamer van Koophandel, KVK) under number 88959945, with VAT number NL004674188B20. We make the software ombra, at app.ombracare.com, and the website ombracare.com. For the data in this statement we are the controller: we decide why and how we use it.

For the data of your clients, applicants and group participants, you as a psychologist or therapist are responsible, and ombra is the processor. Are you a client of a psychologist or therapist who works with ombra? Then read For clients.

You can reach us at privacy@ombracare.com for privacy and at support@ombracare.com for everything else.

Which data, for what and for how long

We ask only for what ombra needs. Your e-mail address is required for an account, and when you first use ombra we ask for the name we should call you by. You fill in other profile and practice details if you want to.

Contract means we need the data to make ombra work for you (article 6(1)(b) GDPR). Legitimate interest is always the same interest here: securing ombra, your account and your clients’ records, and answering your questions (article 6(1)(f)). You can object to that. You withdraw consent whenever you like (article 6(1)(a)). The legal obligation is the duty to keep accounting records (article 6(1)(c)).

If we have to deal with a dispute or the law requires data, we keep or give only what is needed for that. We make no decisions about you based solely on automated processing, and we do not build profiles.

Connecting your calendar and mail

Signing in with Google or Microsoft does not give ombra access to your calendar or mail. You connect those separately, if you want to. Google or Microsoft then first asks for your permission, and you see exactly which permissions.

• Calendar. ombra reads the calendars you choose and shows their appointments in your ombra calendar: title, location, time and participants. These may also contain data about others. ombra writes nothing in your calendar.
• Mail. With mail access, ombra reads your inbox and sent mail, to show messages from and to your clients. It sends the mails you write, and automatic messages to applicants and registrants, such as a confirmation of receipt. These are on by default; you switch them off per form.
• What we keep. ombra fetches the content of your mail live each time and does not store it. We do keep which messages have been read, answered or dealt with, your drafts, the imported appointments and, of every mail you send through ombra, a fingerprint and the status. We store your drafts and the keys of your connection encrypted.
• What you see. By default ombra shows only mail from and to your clients. That filter limits what you see, not the access you grant through Google or Microsoft.

We use what we receive through a connection only to make ombra work for you. Not for advertising, not to sell and not to train AI models. No one at ombra reads your mail, unless you ask us to, it is necessary for security or the law requires it. The use and transfer of information that ombra receives from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

You disconnect in your settings in ombra. That removes the connection, the keys, the imported appointments and your drafts. Revoke the access at Google or Microsoft too if you want. What you added to a record stays in that record.

Your clients’ data

What you keep about your clients, applicants and group participants, ombra processes on your instructions. You are the controller, ombra is the processor (article 28 GDPR). The arrangements are set out in the data processing agreement, which is part of the terms and conditions.

This covers identity and contact details, including the Belgian national register number (rijksregisternummer) or the Dutch citizen service number (BSN); referrer, general practitioner and contact person; reason for seeking help and goals; sessions, notes with all their versions, homework and documents; groups and attendance; applications and form answers. Minors can be clients too.

• We use that data only to make ombra work for your practice.
• We do not sell it, send your clients no advertising and do not train AI with it.
• The rijksregisternummer or BSN serves only to recognise your client in your record. ombra uses it for nothing else.
• ombra never e-mails your clients in its own name. Messages to applicants and registrants go from your connected mailbox.

You decide on which legal basis you process that data, including the exception that allows the processing of health data (article 9 GDPR). A place on a reserve list or a booking rule helps you plan; you make the decisions about admission and care.

If a client writes to us about their own record, we forward that question to the psychologist or therapist and let the client know.

Who else sees your data

We do not sell data and do not share it for advertising. These services process data for us, each only for its own task:

• Microsoft Azure: hosting ombra.
• Microsoft (Azure Communication Services): sign-in codes by e-mail, from account@notify.ombracare.com. No open or click tracking.
• Microsoft 365 (Exchange Online): our mailboxes: support@, privacy@, security@ and hello@ombracare.com.
• Cloudflare: the domain names (DNS) of ombracare.com. Sees no content.
• Brevo (Sendinblue SAS): sending updates about ombra and receiving your ideas.

Which services process your clients’ data, where and for what, you can read under Sub-processors.

An authority or court receives data only with a valid order that obliges us to provide it. If it concerns your clients’ records, we forward the request to you, unless the law forbids it. If ombra ever passes to another business, your data only goes along under the same arrangements, and you hear about it in advance.

Where your data is stored

Your data is stored in Microsoft Azure datacentres in Ireland (Microsoft Azure North Europe), spread over several buildings. A copy of the database backups is in the Netherlands (Microsoft Azure West Europe). Sign-in codes go through Azure Communication Services, with storage in Europe. Your connection to ombra arrives at the nearest point of presence of Microsoft’s network; from Belgium and the Netherlands, that is in Europe.

Microsoft is part of an American group. It keeps European customers’ data within the EU (the EU Data Boundary), with exceptions, for example for certain support and security. If data does leave the EU as a result, the European Commission’s standard contractual clauses or the EU-US Data Privacy Framework apply. If you connect Google or Microsoft, their own rules and locations apply as well. You receive a copy of the safeguards on request. More about requests from authorities under Security.

Security

Everything travels over the internet encrypted and is stored encrypted. Documents, mail drafts, notes on group sessions and the keys of your connections are encrypted once more by ombra itself. The database cannot be reached from the internet, each workspace is shielded from the others, and every record opened or changed goes into a log. You can read all about it under Security.

Cookies and storage in your browser

The website ombracare.com sets no cookies. If you choose a language on it yourself, your browser remembers that choice for six months. Nothing is sent to us. In the app we use cookies and storage in your browser to keep you signed in and secure and to remember your settings. No tracking and no advertising. Below you can see for what and for how long.

The forms and booking pages that practices put on their own website with ombra set no cookies either. That website itself may use cookies: that is a matter for the practice. You clear cookies and other site data in your browser’s settings. You then lose your preferences and are signed out; your records simply remain.

The website

On ombracare.com we measure nothing: no analytics, no advertising trackers and no recordings of your visit. The fonts and illustrations come from the website itself. As with any website, the server receives your IP address to send you the page. When you send a form, it also keeps an unrecognisable fingerprint of that address, and for a sign-up of your e-mail address, in its memory for at most a day, to limit abuse. We use it for nothing else. The product examples contain only fictional data.

With the updates form you ask for an occasional e-mail about ombra and the launch. The form also sends the page language. Brevo (Sendinblue SAS) sends those updates, from the European Union (France, Germany and Belgium). We keep your e-mail address and your consent until you unsubscribe. You can unsubscribe through any update or through privacy@ombracare.com.

With the ideas form you send us your idea, your first and last name and, if you fill them in, your practice or organisation and your e-mail address so we can reply. The form also sends the page language. Brevo (Sendinblue SAS) receives them for us, from the European Union (France, Germany and Belgium). We use them only to read and answer your idea. Would you like us to delete them? E-mail privacy@ombracare.com.

A sign-up for updates is separate from your account and from any application to a practice. If you e-mail us, we use your message and your e-mail address to reply to you. Do not put client data in it.

Your rights

You have these rights over your own data:

• Access: knowing which data we hold about you, and getting a copy.
• Rectification: having incorrect data corrected or completed.
• Erasure: having your data erased, except what we must keep by law.
• Restriction: having the use of your data temporarily stopped.
• Objection: objecting to our use of your data based on our legitimate interest.
• Portability: taking your data with you in a common format.
• Withdrawing consent: for example by unsubscribing from updates.

You do a lot yourself in ombra: changing your data, exporting everything and closing your account. For the rest, e-mail privacy@ombracare.com. We answer within a month, as the GDPR requires, and it is free. If your request is complex, we let you know within that month how much more time we need. We ask who you are only when that is necessary, so that no one else receives your data. Do not send us a copy of your identity card unprompted.

Is your question about a record, an application or an appointment with a psychologist or therapist? Then ask that care provider: they decide on it, and we help.

Not satisfied? Let us know first. You can also lodge a complaint straight away with the Autoriteit Persoonsgegevens, the supervisory authority in the Netherlands, where ombra is established, or with the Data Protection Authority (Gegevensbeschermingsautoriteit) in Belgium. You can also go to court.

If something goes wrong

If data nevertheless ends up in the wrong hands, we report it to the Autoriteit Persoonsgegevens within 72 hours where the law requires it. If it poses a high risk to you, we let you know at once.

If it concerns your clients’ data, you hear it from us without undue delay, so that you can decide what needs to happen. That is what the data processing agreement says.

Changes

If we change this statement, you can tell from the date at the top. If it concerns something material, we e-mail you in advance. We send you earlier versions on request, and you can read what changed under Versions. Reading this statement is not consent to anything new.

Contact

A question about your data? E-mail us. ombra has not appointed a data protection officer: your question goes straight to the person who decides on privacy.

• Privacy and your dataprivacy@ombracare.com