Privacy Policy

Royal Empowerment

Royal Empowerment takes your privacy seriously. This privacy policy explains how Barbara Reale, trading under Royal Empowerment, collects, uses, stores and protects personal data in connection with naturopathic consultations, culinary nutrition services, workshops, website use, communication, administration and related services.

This policy is written in line with the General Data Protection Regulation (GDPR) and common privacy standards for complementary healthcare and naturopathic practitioners in the Netherlands. Because naturopathic work may involve health-related information, Royal Empowerment handles personal and health data with particular care and confidentiality.

1. Who is responsible for your personal data?

Royal Empowerment is operated by Barbara Reale, a naturopathic practitioner and culinary nutritionist. Royal Empowerment is based in Delft, the Netherlands, and is registered with the Dutch Chamber of Commerce under number 98879529. Barbara Reale is the data controller for the personal data described in this policy.

Contact details

Email: barbara.reale@hotmail.it
Phone: +31 6 480 58 793

2. What personal data may be processed?

Depending on your contact with Royal Empowerment, the following categories of personal data may be processed:

  • Identification and contact details, such as name, address, date of birth, telephone number and email address.
  • Appointment and communication details, including messages, contact-form submissions and notes needed to schedule or follow up appointments.
  • Health-related information provided by you, such as lifestyle, nutrition, symptoms, medical history, medication, sleep patterns, stress factors, weight, allergies, relevant test results, treatment goals and other information necessary for naturopathic guidance.
  • Administrative and payment data, such as invoice details, billing address, payment status and information required for bookkeeping and tax obligations.
  • Website and marketing data, such as cookie preferences, newsletter registration, webinar or workshop sign-up details, social media interactions and review content, where applicable.

3. Why is your data processed?

Royal Empowerment processes personal data only where there is a clear purpose and lawful basis, including performance of an agreement, legal obligations, legitimate interests and, where required, your explicit consent.

  • To assess your request for support and provide naturopathic, nutrition or lifestyle guidance.
  • To create and maintain a client file that supports continuity, quality and safety of care.
  • To schedule appointments, communicate with you and respond to questions or requests.
  • To prepare invoices, process payments and comply with Dutch tax administration obligations.
  • To handle complaints, feedback, reviews or requests relating to services.
  • To send newsletters, workshop information or educational content, but only where permitted and with the option to unsubscribe.
  • To maintain and improve the website, including through functional and analytical cookies where applicable.

4. Client file, health data and confidentiality

For proper guidance, Royal Empowerment may keep a client file containing information relevant to your consultations and progress. This may include intake information, notes from sessions, treatment goals, advice provided, relevant health history and information that you choose to share. Health-related data is treated as sensitive personal data and is protected accordingly.

Barbara Reale is the only person with access to your client file unless access by another party is strictly necessary for technical, administrative or legal reasons, or unless you have given explicit consent. Information from your file will not be used for commercial purposes.

If information from another healthcare provider is needed, this will only be requested with your explicit consent. Likewise, sharing information with another healthcare provider, a substitute practitioner or a referring professional will only take place where necessary and, where required, with your explicit consent.

5. Children and consent

For clients under the age of 16, consent from the parent or legal guardian is required for the processing of personal data and the start of treatment. For children aged 12 to 16, the child’s own consent may also be required in addition to parental or guardian consent.

6. BSN and insurance information

Royal Empowerment may record the name of your health insurer or general insurance package if this is relevant for administration or reimbursement information. Royal Empowerment does not record your BSN unless there is a specific legal basis that permits or requires this. As a complementary healthcare provider, Royal Empowerment will normally avoid storing BSN numbers in client files.

7. Retention periods

Royal Empowerment does not keep personal data longer than necessary for the purpose for which it was collected, unless a longer retention period is required by law or professional guidance.

  • Client files and health-related records are generally retained for up to 20 years after the end of the client relationship, unless a different statutory obligation applies or earlier deletion is legally permitted and requested.
  • Financial and tax administration is retained for 7 years in accordance with Dutch tax requirements.
  • Complaint records are normally retained for up to 2 years after the complaint has been resolved, unless longer retention is necessary.
  • Contact-form data is deleted when the request has been handled, unless it leads to a client relationship or must be retained for another legitimate reason.
  • Newsletter and marketing data is retained until you unsubscribe or withdraw your consent.

8. Sharing personal data with third parties

Royal Empowerment does not sell personal data to third parties. Personal data may only be shared where this is necessary for service delivery, secure administration, technical support, bookkeeping, legal compliance, referral or continuity of care. Where third parties process personal data on behalf of Royal Empowerment, appropriate confidentiality and data-processing arrangements are used where required.

Examples may include secure practice software, IT hosting providers, bookkeeping support, payment providers, email or newsletter services, website hosting providers, legal or professional advisers, or another healthcare provider when referral or collaboration is requested by you or necessary for your care.

9. Security of your data

Royal Empowerment takes appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure, alteration and destruction. These measures may include secure login procedures, encrypted connections, protected devices, secure Wi-Fi, limited access to files, backups and confidentiality arrangements with relevant service providers.

If a personal data breach occurs and it is likely to create a risk for your rights and freedoms, Royal Empowerment will take appropriate action and, where legally required, notify the Dutch Data Protection Authority and/or affected individuals.

10. Website, cookies and social media

The Royal Empowerment website may use functional cookies to make the website work properly and analytical cookies to understand how the website is used. If marketing or tracking cookies are used, such as Google Analytics, Facebook Pixel, YouTube or similar services, these will be used in accordance with applicable consent requirements and the privacy settings of those services.

You can manage or delete cookies through your browser settings. Social media buttons or embedded content may allow social media platforms to collect data. Please consult the privacy policies of those platforms for more information about how they process your data.

11. Your privacy rights

You have several rights under the GDPR. Depending on the circumstances, you may request access to your personal data, correction of inaccurate data, deletion of data, restriction of processing, data portability, withdrawal of consent or objection to certain processing activities.

To exercise your privacy rights, please contact Barbara Reale by email at barbara.reale@hotmail.it. Royal Empowerment may ask you to identify yourself before processing your request, so that personal data is not disclosed to the wrong person.

12. Complaints

If you have a complaint about how Royal Empowerment handles your personal data, please contact Barbara Reale first so that the matter can be reviewed and, where possible, resolved. You also have the right to file a complaint with the Dutch Data Protection Authority.

13. Changes to this privacy policy

Royal Empowerment may update this privacy policy from time to time. The most recent version should be consulted regularly, especially when services, systems, legal requirements or privacy practices change.