This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”). In the context of the provision of our services as well as within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profile (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “person responsible”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Email address: email@example.com
CEO: Dr. Judith Kikhney
Types of data processed
– Inventory data (e.g., personal data, names or addresses).
– Contact details (e.g., e-mail, telephone numbers).
– Content data (e.g., text input, photographs, videos).
– Usage data (e.g. websites visited, interest in content, access times).
– Meta / communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (in the following we also refer to the persons concerned collectively as “users”).
Purpose of processing
– Provision of the online offer, its functions and content.
– Answering contact inquiries and communicating with users.
– Safety measures.
– Reach measurement / marketing.
“Personal data” is all information that relates to an identified or identifiable natural person (hereinafter “data subject”); A natural person is regarded as identifiable who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, which express the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.
“Processing” is any process carried out with or without the aid of automated processes or any such series of processes in connection with personal data. The term goes far and includes practically every handling of data.
“Pseudonymization” the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is stored separately and is subject to technical and organizational measures that ensure that the personal data cannot be assigned to an identified or identifiable natural person.
“Profiling” means any type of automated processing of personal data that consists of using this personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to work performance, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or relocation of this natural person.
“Responsible” is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
“Processor” means a natural or legal person, authority, institution or other body that processes personal data on behalf of the person responsible.
Relevant legal bases
In accordance with Article 13 GDPR, we will inform you of the legal basis for our data processing. For users from the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, unless the legal basis is mentioned in the data protection declaration, the following applies:
The legal basis for obtaining consent is Art. 6 (1) (a) and Art. 7 GDPR;
The legal basis for processing for the fulfillment of our services and the implementation of contractual measures as well as answering inquiries is Art. 6 Para. 1 lit. b GDPR;
The legal basis for processing in order to fulfill our legal obligations is Art. 6 Para. 1 lit. c GDPR;
The legal basis for processing in order to safeguard our legitimate interests is Art. 6 (1) lit.f GDPR.
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis.
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk for the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk.
The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transfer, ensuring availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, deletion of data and reaction to data threats. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings.
Cooperation with processors, jointly responsible persons and third parties
If we disclose data to other persons and companies (contract processors, jointly responsible persons or third parties) in the course of our processing, transmit the data to them or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g. if the data is transmitted to third parties, such as payment service providers to fulfill the contract). Users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we disclose, transmit or otherwise grant access to data to other companies in our group of companies, this is done in particular for administrative purposes as a legitimate interest and, furthermore, on a legal basis.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or in the context of the use of third-party services or disclosure or transmission of data to other persons or companies, this only happens if it is done to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data in a third country only if the legal requirements are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations.
Rights of data subjects
You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
You have accordingly the legal requirements to request the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with the legal requirements, you have the right to demand that the relevant data is deleted immediately or, alternatively, to request a restriction on the processing of the data in accordance with the legal requirements.
You have the right to request that the data relating to you that you have provided to us to be received in accordance with the legal requirements and to request that it will be transmitted to other responsible parties.
Furthermore, in accordance with the legal requirements, you have the right to lodge a complaint with the competent supervisory authority.
Right of withdrawal
You have the right to revoke your consent with effect for the future.
Right to object
You can object to the future processing of the data concerning you at any time in accordance with the legal requirements. The objection can in particular be made against processing for direct marketing purposes.
Cookies and right to object to direct mail
“Cookies” are small files that are stored on the users’ computers. Various information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie can, for example, store the content of a shopping cart in an online shop or a login status. Cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the users can also be stored in such a cookie, which are used for range measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only their cookies, they are referred to as “first-party cookies”).
We can use temporary and permanent cookies and clarify this in the context of our data protection declaration.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of data
The data processed by us will be deleted or restricted in their processing in accordance with the legal requirements. Unless stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention requirements.
If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
Business related processing
We also process
– Contract data (e.g., subject of the contract, term, customer category).
– Payment data (e.g., bank details, payment history)
by our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Health care services
We process the data of our patients and interested parties and other clients or contractual partners (uniformly referred to as “patients”) in accordance with Art. 6 Paragraph 1 lit.b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed here, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship. The processed data includes inventory and master data of the patient (e.g., name, address, etc.), as well as the contact details (e.g., e-mail address, telephone, etc.), the contract data (e.g., services used, purchased products, costs, names of contact persons) and payment data (e.g. bank details, payment history, etc.).
As part of our services, we can also process special categories of data in accordance with Art. 9 (1) GDPR, in particular information on the health of patients, possibly with reference to their sexual life or sexual orientation. For this purpose, if necessary, in accordance with Art. 6 Paragraph 1 lit. a., Art. 7, Art. 9 Paragraph 2 lit. a. DSGVO an express consent of the patient and otherwise process the special categories of data for health care purposes on the basis of Art. 9 Para. 2 lit h. GDPR, § 22 Paragraph 1 No. 1 b. BDSG.
If necessary for the fulfillment of the contract or by law, we disclose or transfer the patient’s data in the context of communication with medical professionals, third parties typically involved in the fulfillment of the contract, such as laboratories, billing offices or comparable service providers, provided that this is necessary for the provision of our services in accordance with. Art. 6 para. 1 lit b. GDPR serves, legally in accordance with Art. 6 Para. 1 lit c. GDPR is required to serve our interests or those of the patient in efficient and cost-effective healthcare as a legitimate interest in accordance with Art. 6 Para. 1 lit f. GDPR or in accordance with Art. 6 Para. 1 lit d. GDPR is necessary to protect the vital interests of the patient or another natural person or within the scope of consent in accordance with Art. 6 Para. 1 lit. a., Art. 7 GDPR.
The data will be deleted when the data is no longer required to fulfill contractual or statutory duties of care or to deal with any warranty or comparable obligations, whereby the need to store the data is checked every three years; otherwise, the statutory retention requirements apply.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as the organization of our operations, financial accounting and compliance with legal obligations, such as archiving. The processing of our data is in accordance with the fulfilment of our contractual service.. The processing bases are Article 6 Paragraph 1 Letter C. GDPR, Art. 6 Paragraph 1 Letter F. GDPR. The processing affects customers, interested parties, business partners and website visitors. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, tasks also serve the maintenance of our business activities, the performance of our tasks and the provision of our services. The deletion of the data relating to useful services and general communication corresponds to the processing activities of this information.
We transmit data to the financial administration, consultants, such as tax consultants or auditors as well as other fee offices and payment service providers.
Furthermore, based on our business interests, we provide information on suppliers, organizers and other business partners, e.g. for the purpose of later contact. We always save this mostly company-related data.
Business analysis and market research
In order to operate our business economically, to be able to recognize market trends, wishes of the contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata based on Art. 6 Para. 1 lit.f. GDPR, whereby the persons concerned include contractual partners, interested parties, customers, visitors and users of our online offer.
Analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we can take into account the profiles of the registered users with information, e.g. on the services they have used. Analyzes serve us to increase the user-friendliness, the optimization of our offer and the economic efficiency. Analyzes serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized values.
If these analyses or profiles are personal, they will be deleted or anonymized upon termination by the user, otherwise they will be deleted or anonymized after two years from the conclusion of the contract. In addition, the overall business analyses and general tendency determinations are created anonymously if possible.
Hosting and sending of e-mails
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, sending emails, security services and technical maintenance services that we use for operating this online offer.
We or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data from customers, interested parties and visitors to this online offer based on our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 Para. 1 lit.f GDPR in conjunction with Art. 28 GDPR (conclusion of an order-processing contract).
Collection of access data and log files
We, or our hosting provider, collect data on every access to the server on which this service is located (so-called server log files) based on our legitimate interests within the meaning of Art. 6 Paragraph 1 lit. The access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
For security reasons (e.g. to investigate acts of abuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data, where further storage of which is necessary for evidence purposes, is excluded from deletion until the respective incident has been completely clarified.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and the internet. In doing so, pseudonymous user profiles can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. The full IP address will only be transmitted to a Google server in the USA and shortened there in exceptional cases.
The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; Users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and from processing this data by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
You can find more information on the use of data by Google, setting and objection options in Google’s data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
The personal data of the users will be deleted or anonymized after 14 months.