Privacy statement

Last updated: 19 August 2026
What this policy covers
This privacy policy is about comfortho.nl and about the contact that follows from it. So about what happens when you fill in the contact form, call us, email us, message us on WhatsApp or send a photo of your teeth. It also explains which cookies and tracking tools run on the site.
This policy does not cover your treatment or your patient file. Once you become a patient at one of the affiliated practices, that practice is responsible for your file. Different rules apply there, including the Dutch Medical Treatment Agreement Act (WGBO), with its own retention period of twenty years. The practice has its own privacy policy. Ask the practice for it.
Who is responsible for your data
The controller for the website is:
- Lotte Meereboer, trading as Comfortho
- Address: Teniersstraat 2 HS, 1071 DX Amsterdam
- Telephone: 085 401 47 37
- Email: ortho@comfortho.nl
- Privacy questions: ortho@comfortho.nl
Comfortho has not appointed a data protection officer. For questions about your data, use the email address above.
What we process, why, and on what legal basis
The contact form
There is a form on the contact page and on the frequently asked questions page. You fill in:
| Field | Required |
|---|---|
| Name | yes |
| Email address | yes |
| Phone number | no |
| Your message | yes |
Why: to answer your question and, if you want, to plan an appointment.
Legal basis: our legitimate interest in replying to people who contact us (Article 6(1)(f) GDPR). If your message is about booking an appointment, the basis is taking steps at your request before entering into a contract (Article 6(1)(b) GDPR).
Please note: your message arrives as a normal email in our mailbox. So do not put medical details in it that you would rather not send by email. If you do want to share those, call us instead.
Phone, email and WhatsApp
You can also reach us directly:
- Phone: 085 401 47 37
- Email: ortho@comfortho.nl
- WhatsApp: 06 38 91 82 55
We then process your name, your phone number or email address, and whatever you tell us. The legal basis is the same as for the contact form.
WhatsApp is a Meta service. The content of your message is encrypted between your phone and ours, including when we use WhatsApp Business. Meta does see that you are in contact with us, when, how often and from which number. If we use WhatsApp Business, Meta also records that you are writing to a business account, and the conversation may be stored in a business environment.
Sending a photo of your teeth
The site invites you to take a photo of your teeth and send it to us by WhatsApp or email, so we can give you a first idea of whether aligners make sense for you. This is entirely optional. You get exactly the same by simply booking an appointment.
A photo of your teeth is information about your health. Under the GDPR that is a special category of personal data, with extra protection. So here is exactly how it works.
Legal basis: your explicit consent (Article 9(2)(a) GDPR). You give that consent by sending us the photo yourself. If you do not send a photo, we do not process one.
What happens to the photo:
- The photo arrives in the Comfortho mailbox or in the Comfortho WhatsApp.
- A provider or a staff member of the practice that will be helping you looks at it and writes you a reply. Which practice that is depends on where you live and where there is room; there are six, and they are listed with their addresses on the contact page.
- We keep the photo for drie maanden nadat we je hebben geantwoord. After that we delete it.
- If you become a patient, the photo goes to the practice and becomes part of your patient file. From that moment the rules of the practice and the WGBO apply, including for how long it is kept.
- We do not use your photo for advertising, not on social media and not on the website.
- We do not hand the photo to other parties, apart from the parties that technically run our mailbox and our phone. See section 6.
What we do not do: we do not diagnose at a distance. What we see in a photo is a first impression, nothing more. Whether treatment is possible and what it would involve can only be said after your teeth have been examined at the practice. So do not count on anything based on a photo alone.
About the route you choose: if you send the photo through regular WhatsApp, your message travels through Meta. The content is encrypted, but the fact that you contacted us is known to Meta. If you would rather avoid that, email the photo to ortho@comfortho.nl, or simply book an appointment and have your teeth examined at the practice.
You can change your mind. You can ask us to delete the photo at any time, without giving a reason. Email ortho@comfortho.nl. If you sent the photo through WhatsApp, delete it from your own chat as well, otherwise it stays there.
Blocking spam and abuse
The contact form contains a field you cannot see and therefore never fill in. If it is filled in anyway, we know the form was submitted automatically and we throw the submission away. We store nothing from that field.
We also use Cloudflare Turnstile. It checks whether there is a person behind the screen rather than a program. To do that, Turnstile looks at your IP address, your browser and your behaviour on the page. Turnstile only loads on the contact page, where the form is, and on its Dutch counterpart. On every other page of the site no contact with Cloudflare is made.
Legal basis: our legitimate interest in protecting the form and the site against abuse (Article 6(1)(f) GDPR).
Visit data and statistics
This website does not measure your visit. There is no analytics program and no advertising script on it. We do not track which pages you look at, how long you stay or where you came from, and we do not link your visit to a phone call or to an advert.
What does happen, happens at our hosting provider: like any web server, Vercel records technical data in order to deliver and protect the site, including your IP address and which page was requested. That is not data we use to follow you.
Legal basis: our legitimate interest in being able to offer the website and keep it available (Article 6(1)(f) GDPR).
Cookies and similar techniques
A cookie is a small file placed on your device when you visit the site. There is only one kind on this site, and it is necessary. That is why you do not see a cookie banner: there is nothing to ask your permission for.
| Name | Party | Purpose | Category | Retention |
|---|---|---|---|---|
| Turnstile cookies | Cloudflare | checks at the contact form whether you are a person and not a program | necessary | up to thirty minutes |
What is explicitly not on it. This website does not measure your visit. There is no Google Analytics, no Google Tag Manager, no Meta Pixel, no Hotjar, no Google Ads and no call tracking. No statistics or marketing cookies are placed, and there is nothing that follows you across websites.
The previous version of comfortho.nl did have those programs. They were not carried over when the site was rebuilt. If they return, a cookie banner will come first that holds them back until you choose, and this chapter will be updated.
You can also delete or block cookies yourself through your browser settings. If you block the Turnstile cookies the contact form may not work; calling or emailing still will.
Third party content on our pages
Some pages carry content that comes from another party. As soon as that content loads, that party sees your IP address. There are exactly two:
- YouTube videos, on the pages where a video appears. We use the youtube-nocookie.com domain for this, which means YouTube only starts building a profile once you actually play the video. On most pages you first see a still with a play button, and contact with YouTube is only made when you click it. On a few older articles the video sits directly in the page; there YouTube makes contact as soon as the video comes into view.
- Cloudflare Turnstile, on the contact page. See 3.4.
Google Maps is not on this site. The addresses on the contact page are ordinary links to Google Maps. If you click one you leave our site and Google's terms apply. As long as you do not click, no contact with Google is made.
The fonts on this site are loaded from our own domain and are not fetched from Google.
These parties are subject to their own privacy policy. We have no influence over what they do with that data.
Who we share your data with
We do not sell your data and we do not rent it out. We share it only with:
- The affiliated practice that will be helping you, if you want an appointment or if someone needs to look at your question or your photo.
- Our hosting and email provider, Vercel voor de website en GraphicGenie voor de verzending van het contactformulier, dat daarvoor Amazon SES gebruikt. That is where the website, the delivery of the contact form and our mailbox run.
- The parties from chapters 4 and 5, that is Cloudflare for the spam check on the contact form and YouTube for any video you play.
- Others where the law requires it, for example a supervisory authority or the police acting on a statutory power.
We conclude a data processing agreement with parties that process data on our behalf.
Transfers outside the European Economic Area
Some of the parties above are American, or use servers outside the European Economic Area. That includes Google, Meta and Cloudflare. Your data may therefore be processed outside the EEA.
For those transfers these parties rely on the EU-US Data Privacy Framework, which the European Commission found to offer an adequate level of protection in July 2023, or on the European Commission's standard contractual clauses combined with additional measures.
There is no such thing as complete certainty about the protection of data in the United States. If you would rather avoid it, use the phone or the contact form for your message rather than WhatsApp, and do not play the videos on this site.
How long we keep your data
| What | How long |
|---|---|
| Message sent through the contact form, including your name, email address and phone number | twaalf maanden nadat je vraag is afgehandeld |
| Email and WhatsApp conversations | as long as a message sent through the contact form |
| Photo of your teeth | drie maanden nadat we je hebben geantwoord |
| Data in cookies and tracking tools | the period stated in the table in section 4 |
| Data in your patient file at the practice | governed by the practice and the WGBO, as a rule twenty years |
If you become a patient, your information moves to the practice and the retention periods of the practice apply from that moment.
Security
We take appropriate technical and organisational measures to protect your data against loss and against access by people who have no business with it. The website uses a secure connection (https). Only staff who need it for their work can reach the messages and the photos.
If you think your data is not properly protected, or you see signs of misuse, email ortho@comfortho.nl.
Visitors under 18
Part of this website is about orthodontics for children, and those pages are written for parents and carers. If you are under 18, you are welcome to read the site.
To process the data of anyone under 16 we do need permission from a parent or carer. If you are under 16, please do not fill in a form or send a photo without a parent or carer looking on and deciding with you. You will need them for an appointment anyway. If you think we hold a child's data without that permission, email ortho@comfortho.nl and we will delete it.
Your rights
You have the following rights:
- Access. You can ask which data we hold about you.
- Rectification. If your details are wrong, we will correct them.
- Erasure. You can ask us to delete your data, for example the photo of your teeth.
- Restriction. You can ask us to pause the use of your data while something is being sorted out.
- Objection. Where we process data on the basis of our legitimate interest, you can object.
- Portability. You can receive your data in a common file format, or have us send it to another organisation.
- Withdrawing consent. If you gave consent, for example for cookies or for the photo of your teeth, you can withdraw it at any time. Whatever happened before that moment remains lawful.
Send your request to ortho@comfortho.nl. We respond within one month. To avoid changing or deleting the data of the wrong person, we may ask you to identify yourself. If your question is about your patient file, we will refer you to the practice, because the practice is responsible for it.
Filing a complaint
If you are unhappy with the way we handle your data, tell us first at ortho@comfortho.nl. If we cannot sort it out together, you can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):
Autoriteit Persoonsgegevens, Postbus 93374, 2509 AJ The Hague, autoriteitpersoonsgegevens.nl.
You can also go to court.
Changes
We update this privacy policy when the website changes or when we start using other parties. The date at the top shows when that last happened. Check back now and then so you know what applies.
Contact
- Phone: 085 401 47 37
- Email: ortho@comfortho.nl
- Privacy questions: ortho@comfortho.nl
- Address: Teniersstraat 2 HS, 1071 DX Amsterdam