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Privacy Policy


This Privacy Policy explains how the Center for Applied Theory of Mind (“CAToM”) handles your personal information and data and applies to all services, products and websites (collectively the “Services”) offered by CAToM and its affiliates and third party providers, except where otherwise noted. Unless otherwise mentioned, our Services may be delivered virtually by CAToM on a worldwide basis.

  1. General privacy terms

    1. If you are a "Visitor”:

  1. We may use third party services that track how visitors navigate our website, for example, to know if they find us on Google Search, or if they come from an external link to our website.

  2. We gather information about how visitors behave on our website, for example, which pages they visit, whether they are returning visitors, or if they ever become a User or a Client.

  3. This information is totally anonymous and we can see only statistical information, not any of your personal data. If you are a Visitor, we cannot see any of your personal data.


​2. If you are a "User”:


  1. When you complete questionnaires, forms, or requests for CAToM materials, you own the data that we collected.  CAToM treats your data and personal information as confidential information. We will not sell your data to anyone and we will not use your data for any purpose that is not described in this Privacy Policy and/or in our General Terms and Conditions.

  2. We will never reveal your personal data (such as name, email address, IP address, location data, etc.) to any unauthorized third party without your consent.  Such data will be made available only to you, or as directed or authorized by you, in connection with our provision of Services to you.
    Your data, including but not limited to your personal data, is securely stored on our servers and/or on the secure servers of our Third Party Service Providers. We apply the latest and best technological and organizational practices to safeguard your data, which may also include your personal information.

  3. CAToM will handle your data on your behalf and under your instructions (including the ones agreed to in this privacy policy). We handle your data according to Dutch Law and other mandatory EU, international and/or foreign acts.



3. If you are a Client:

  1. We collect the data that you provide when you inquire about our Services, fill out an information form, complete any of our inventories (“Inventory Data”), inquire and/or communicate with us via our website, email, post or in person.

  2. Your Inventory Data will be maintained in a secure, encrypted and confidential manner by CAToM and/or CAToM’s Third Party Service Providers.  We will not sell any of your personal data to third parties. As provided in our General Terms and Conditions, we may transfer your data, including your personal data, to Third Party Service Providers, but only in accordance with the terms of a Data Processing Agreement (“DPA”) that complies with relevant data protection laws, including but not limited to the General Data Protection Regulation (“GDPR).



2. Compliance with General Data 

    Protection Regulation (GDPR)

We collect, use, process, disclose and protect any and all personal data that you provide in accordance with applicable data protection laws, including but not limited to the GDPR.  The GDPR is designed to protect personal data (information that can be used to identify you, the data subject). Your personal data may include sensitive information, which will be afforded additional safeguards and protections in accordance with the GDPR.

Our Services are intended for use by our Clients, and by Users and Visitors who are interested in learning about our Services and/or becoming Clients. We act as a Data Processor on behalf of our Clients and Users/Visitors.  As a result, and in accordance with the GDPR, for a part of the personal data that we collect and process about our business Clients, their employees and affiliates (Client Data Subjects), we act as a Data Processor on behalf of our Clients. In that case, our business Clients are the Data Controllers, and also they are Data Processors as well, for the data that they collect about their Client Data Subjects.

We are not responsible for the privacy or security practices of our Clients, which may differ from those set forth in this Privacy Policy. We require our Clients to comply with all applicable laws and regulations and to provide their Client Data Subjects with notice of the collection of data as outlined in this Privacy Policy.

Additional info:

Our GDPR obligations

According to the GDPR, you as an account owner must deliberately and wilfully give CAToM your consent to collect your personal data, which is done by registering an account and/or using our Services, as explained in our General Terms and Conditions and in the documents referenced in this Privacy Policy.

However, we must also clearly and transparently explain the following information to our users:

–  How we collect data

–  Why we collect data

–  How we protect collected data

–  For how long we keep collected data

–  If, how, and why we share collected data

–  What are our privacy policies

–  That they have the right to view, correct, or delete their personal data at any time

–  That they are required to follow the GDPR regulations for their own data subjects


3. Details of our data collection

We collect data from and about two categories of users.

  1. Visitors:  Visitors are business and individuals who visit pages of our website to learn more about CAToM and our Services.
  2. Users: Users are business and individuals who complete questionnaires, forms, or requests for CAToM materials.

  3. Clients:  Clients are business and individuals who pay for one or more of our Services.

For a description of the data that we collect from each category of users, please refer to DATA THAT WE COLLECT FROM YOU AND WHY


4. You give your consent to the 


By using our Services you indicate your acceptance of this Privacy Policy, and you expressly consent to the following:

  1. You consent to the collection, use, disclosure and processing of your personal data/information in the way described in this Privacy Policy.

  2. You accept that we share your personal data with relevant persons working for Third Party Service Providers who assist us in providing our Services.

  3. When you enabled cookies on your web browser, you accept our use of cookies as explained in this Privacy Policy and our Cookie Policy.

 This document was last updated on March 5, 2023

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