Privacy Policy

Last updated: 27 June 2026

At FearFree, your privacy matters deeply to us. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have. It applies to all users of the FearFree programme at fearfree.rolandb31.com.

FearFree operates under the laws of the Netherlands and complies with the General Data Protection Regulation (GDPR) (EU Regulation 2016/679) and the Dutch Uitvoeringswet AVG. For the purposes of GDPR, FearFree is the data controller for your personal data.

1. Who We Are

FearFree operates the digital anxiety management programme available at fearfree.rolandb31.com. Contact for privacy matters:
Email: support@fearfree.rolandb31.com

2. What Personal Data We Collect

We collect the following categories of personal data:

Account data: name, email address, password (stored in encrypted form), and account preferences;
Billing data: subscription plan, payment status, billing history. Full card details are handled by our payment processor — we do not store them;
Programme interaction data: progress through modules, completed exercises, self-reported mood or anxiety check-ins, and in-app responses;
Device and technical data: IP address, browser type, operating system, device identifiers, and session logs;
Communications data: emails or messages you send to our support team;
Cookie and tracking data: as described in Section 7 below.

We do not deliberately collect special category data (such as diagnosed health conditions) through formal fields. However, if you voluntarily share information about your mental health within programme exercises or in support communications, this may constitute special category data. We process this solely to provide the Service to you, on the basis of your explicit consent, which you give when you engage with those features.

3. How We Use Your Data and Our Legal Bases

We only process your personal data when we have a lawful basis to do so under GDPR. Here is how we use your data and the basis for each use:

To provide and manage your subscription — basis: performance of contract (Art. 6(1)(b) GDPR);
To process payments and prevent fraud — basis: performance of contract and legitimate interests (Art. 6(1)(b) and (f));
To personalise your programme experience — basis: performance of contract and, where applicable, consent;
To send transactional emails (receipts, account notifications, renewal reminders) — basis: performance of contract;
To send marketing emails and product updates — basis: your consent (Art. 6(1)(a)); you may unsubscribe at any time;
To improve and develop our Service through aggregated analytics — basis: legitimate interests (Art. 6(1)(f)), balanced against your privacy rights;
To comply with legal obligations (e.g. tax records, responding to lawful requests) — basis: legal obligation (Art. 6(1)(c)).

4. Third-Party Data Processors

We share your data with carefully selected third-party processors who act on our instructions under GDPR-compliant data processing agreements. These include:

Payment processors (such as Stripe or Mollie) — to handle subscription billing. These providers may transfer data outside the EEA under appropriate safeguards (e.g. Standard Contractual Clauses);
Email service providers (such as Mailchimp or Brevo) — to deliver transactional and marketing emails;
AI and personalisation providers — to power intelligent features within the programme. Any AI provider we use is contractually bound to process your data only on our instructions;
Cloud hosting and infrastructure providers — to host and deliver the Service securely;
Analytics providers (such as Google Analytics or Plausible Analytics) — to understand usage patterns. Where possible, we use privacy-first or anonymised analytics solutions.

We do not sell your personal data to third parties. We do not share your data with third parties for their own marketing purposes without your explicit consent.

5. International Data Transfers

Some of our third-party processors are based outside the European Economic Area (EEA). Where this is the case, we ensure appropriate safeguards are in place, such as the European Commission's Standard Contractual Clauses (SCCs) or adequacy decisions, to protect your data to EEA standards.

6. Data Retention

We retain your personal data only for as long as necessary for the purposes described in this policy:

Account data: for the duration of your subscription plus 2 years after closure, to handle any post-cancellation queries or disputes;
Billing and transaction records: 7 years, to comply with Dutch tax and accounting obligations (Wet op de inkomstenbelasting and related legislation);
Programme interaction data: for the duration of your active subscription plus 12 months, unless you request earlier deletion;
Support communications: 2 years from last contact;
Marketing consent records: until you withdraw consent plus 1 year.

When data is no longer needed, we securely delete or anonymise it.

7. Cookies

FearFree uses cookies and similar tracking technologies on our website and platform. Cookies are small files stored on your device that help us operate and improve the Service.

Types of cookies we use:

Strictly necessary cookies: Required for the platform to function (e.g. keeping you logged in). These cannot be switched off.
Analytics cookies: Help us understand how users interact with the Service so we can improve it. These are only set with your consent.
Marketing cookies: Used to show you relevant content or measure the effectiveness of our marketing. These are only set with your consent.

When you first visit FearFree, a cookie consent banner will ask for your preferences. You can change your cookie settings at any time through the cookie preferences link in the website footer. You can also control cookies through your browser settings.

8. Your Rights Under GDPR

Under the GDPR, you have the following rights regarding your personal data:

Right of access: You can request a copy of the personal data we hold about you;
Right to rectification: You can ask us to correct inaccurate or incomplete data;
Right to erasure ("right to be forgotten"): You can ask us to delete your data, subject to legal retention obligations;
Right to restriction of processing: You can ask us to limit how we use your data in certain circumstances;
Right to data portability: You can request your data in a structured, commonly used, machine-readable format;
Right to object: You can object to processing based on legitimate interests or for direct marketing at any time;
Right to withdraw consent: Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please email us at support@fearfree.rolandb31.com. We will respond within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with the Dutch data protection authority, the Autoriteit Persoonsgegevens (AP) at autoriteitpersoonsgegevens.nl.

9. Security

We take the security of your data seriously. We use encryption in transit (TLS/HTTPS), encrypted storage for sensitive data, access controls, and regular security reviews. However, no system is 100% secure, and we cannot guarantee absolute security. If we become aware of a data breach that affects your rights, we will notify you and the relevant authorities as required by GDPR.

10. Children

FearFree is not intended for people under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has registered with us, please contact us immediately and we will delete their data.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email and by posting the updated policy on our website with a new "Last updated" date. We encourage you to review this policy periodically.

12. Contact

For any privacy-related questions or to exercise your rights:
Email: support@fearfree.rolandb31.com

Disclaimer: This Privacy Policy has been prepared in plain language for general informational purposes. It does not constitute professional legal advice. FearFree recommends seeking independent legal counsel to ensure full compliance with the GDPR and all applicable Dutch data protection laws specific to your circumstances.