This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within the framework of the provision of our services as well as within our online offer and the websites, functions and contents connected with it as well as external online presences, such as our Social Media Profile (hereinafter referred to as “online offer”). With regard to the terms used, e.g. “processing” or “responsible person”, we refer to the definitions in Article 4 of the Datenschutzgrundverordnung (DSGVO).
TYPES OF DATA PROCESSED
- inventory data (e.g., personal master data, names or addresses).
- Contact data (e.g., e-mail, telephone numbers).
- Content data (e.g., text entries, photographs, videos).
- Usage data (e.g., visited websites, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
CATEGORIES OF PERSONS AFFECTED
Visitors and users of the online offer (in the following we will refer to the persons concerned collectively as “users”).
PURPOSE OF THE DATA PROCESSING
- Provision of the online offer, its functions and contents.
- Answering of contact requests and communication with users.
- security measures.
- Range measurement/Marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data.
“pseudonymisation” means the processing of personal data in such a way that the personal data cannot be related to a specific data subject without the inclusion of supplementary information, provided that this supplementary information is kept separate and is subject to technical and organisational measures ensuring that the personal data is not related to an identified or identifiable natural person
“profiling” refers to any automated processing of personal data consisting in using personal data to evaluate certain personal aspects relating to a natural person, in particular with a view to analysing or predicting aspects relating to the performance of work, the economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person
The term “controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
“processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller
In accordance with Art. 13 DSGVO, we inform you of the legal regulations governing our data processing. For users from the area of validity of the Datenschutzgrundverordnung (DSGVO), i.e. the EU and EEC, the following applies unless the legal basis is stated in the data protection declaration:
The legal base for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 DSGVO;
The legal basis for processing for the purpose of fulfilling our services and carrying out contractual services and answering requests is Art. 6 para. 1 lit. b DSGVO;
The legal basis for the processing of data to fulfil our legal obligations is Art. 6 para. 1 lit. c DSGVO;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO is used as the legal basis.
The legal basis for the processing necessary for the purpose of performing a task carried out in the public interest or carried out in the exercise of official authority that has been assigned to the controller is Art. 6 para. 1 lit. e FADP.
The legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f DSGVO.
The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 para. 4 DSGVO.
The processing of special categories of data (in accordance with Art. 9 para. 1 DSGVO) is governed by the provisions of Art. 9 para. 2 DSGVO.
security policy guidelines
We take appropriate technical and organizational precautions in accordance with the legal requirements and taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of processing as well as the varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
Such precautions will include, in particular, protection of the confidentiality, integrity and availability of data by controlling the physical access to data, as well as the access, input, disclosure, protection of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects’ rights are respected, that data is deleted, and that we respond to any threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings.
COOPERATION WITH CONTRACT PROCESSORS; JOINTLY RESPONSIBLE PERSONS AND THIRD PARTIES
If, in the course of our data processing, we disclose data to other persons and companies (processors, jointly responsible persons or third parties), transfer it to them or otherwise grant them access to the data, this will only be done on the basis of a legal authorisation (e.g. if the transfer of the data to third parties, such as payment service providers, is necessary for the fulfilment of a contract), users have consented, a legal obligation requires this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we disclose, transfer 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, moreover, on a basis that complies with the legal requirements.
TRANSMISSION 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 if this is done in the context of using the services of third parties or disclosure or transfer of data to other persons or companies, this will only take place if it is done to fulfil 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 express consent or contractually required transfer, we process or allow the data to be processed only in third countries with a recognised level of data protection, including the US processors certified under the “Privacy Shield” or on the basis of special guarantees, such as contractual obligations through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission).
RIGHTS OF THE PERSONS INVOLVED
Right of information: You have the right to obtain confirmation as to whether or not data are being processed and to obtain information on such data, as well as further information and a copy of the data in accordance with the law.
Right of rectification: You have the right to request the completion of data concerning you or the rectification of incorrect data concerning you, in accordance with the law.
Right to deletion and limitation of processing: You have the right to request that data concerning you be deleted immediately in accordance with the law or, alternatively, that the processing of the data be limited in accordance with the law.
Right to data transferability: You have the right to receive data relating to you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another person responsible.
Complaints to the supervisory authority: You also have the right to submit a complaint to the competent supervisory authority in accordance with the statutory provisions.
RIGHT OF WITHDRAWAL
You have the right to withdraw your consent with effect for the future.
RIGHT OF OBJECTION
You have the right to object at any time, for reasons resulting from your particular situation, to the processing of personal data concerning you that is based on Article 6 paragraph 1 letter e or f DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, to the extent that it is linked to such direct marketing.
COOKIES AND RIGHT OF OBJECTION FOR DIRECT ADVERTISING
” Cookies ” are small files that are stored on the computers of the users. Different 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 his 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. In such a cookie, for example, the contents of a shopping cart in an online shop or a login status can be stored. Cookies are described as “permanent” or “persistent” if they remain stored even after the browser is closed. For example, the login status can be saved if the user visits it after several days. Likewise, the interests of the users can be stored in such a cookie, which are used for range measurement or marketing purposes. As ” third party cookie” are called cookies, which are offered by other providers than the responsible person who operates the online offer (otherwise, if it is only their cookies, it is called “first-party cookies”).
If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored 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 explicitly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion is not contradicted by any statutory storage obligations.
If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
MODIFICATION AND UPDATE OF THE DATA POLICY
We ask you to inform yourself regularly about the content of our data policy. We will adapt the data policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to cooperate (e.g. to give your consent) or to provide other individual notification.
THERPEUTICAL SERVICES AND COACHING
We process the data of our clients and interested persons and other clients or contractual partners (uniformly referred to as “clients”) in accordance with Art. 6 Para. 1 letter b) DSGVO in order to provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope, purpose and necessity of their processing, is determined by the underlying contractual relationship. The processed data basically includes the clients’ personal and master data (e.g. name, address, etc.), as well as contact data (e.g. e-mail address, telephone number, etc.), contract data (e.g. services used, fees, names of contact persons, etc.) and payment data (e.g. bank details, payment history, etc.).
Within the context of our services, we may also process special categories of data in accordance with Art. 9 Para. 1 DSGVO, in particular information on the health of clients, if necessary with reference to their sexual life or sexual orientation, ethnic origin or religious or ideological beliefs. For this purpose, we obtain, if necessary, in accordance with Art. 6 para. 1 lit. a., Art. 7, Art. 9 para. 2 lit. a. DSGVO, and otherwise process the special categories of data for the purposes of health care on the basis of Art. 9 para. 2 lit. h. DSGVO, Art. 22 Para. 1 No. 1 b. BDSG.
As far as it is necessary for the fulfilment of the contract or legally required, we disclose or transfer the clients’ data within the framework of the communication with other professionals, third parties involved in the fulfilment of the contract as necessary or typically, such as billing offices or comparable service providers, as far as this is necessary for the provision of our services according to Art. 6 para. 1 lit b. DSGVO, legally according to Art. 6 Para. 1 lit. c. DSGVO, our interests or those of our clients in efficient and cost-effective health care as a legitimate interest in accordance with Art. 6 para. 1 lit. f. DSGVO or is necessary according to Art. 6 para. 1 lit. d. DSGVO to protect the vital interests of clients or another natural person or within the limits of a consent according to Art. 6 para. 1 lit. a., Art. 7 DSGVO.
The data is deleted when the data is no longer required to fulfil contractual or statutory duties of care and to deal with any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years; otherwise the statutory retention obligations apply.
ONLINE PRESENCE IN SOCIAL MEDIA
We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested visitors and users involved there and to inform them about our services.
We point out that user data may be processed outside the European Union. This can result in risks for the users, because the enforcement of the users’ rights could be made more difficult. With regard to US providers certified under the Privacy Shield, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.
Furthermore, user data is generally processed for market research and advertising purposes. For example, user profiles can be created from the user behaviour and the resulting interests of the users. The user profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the user profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
The processing of users’ personal data is based on our legitimate interests in effective information of users and communication with users in accordance with Art. 6 para. 1 lit. f. DSGVO. If the users are asked by the respective providers of the platforms to give their consent to the aforementioned data processing, the legal basis for the processing is Art. 6 para. 1 lit. a., Art. 7 DSGVO.
For a detailed presentation of the respective processing and the possibilities of objection (opt-out), we refer to the following linked information of the providers.
Also in the case of requests for information and the assertion of user rights, we would like to point out that these can most effectively be asserted with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.
INTEGRATION OF SERVICES AND CONTENT OF THIRD PARTIES
Within our online offer, on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO), we use content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third-party providers of these contents are aware of the IP address of the users, as without the IP address they would not be able to send the contents to their browsers. The IP address is therefore necessary for the display of this content. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain technical information about the browser and operating system, referring websites, visiting time and other details about the use of our online offer, as well as being linked to such information from other sources.
- Google Fonts
- Use of Facebook Social Plugins
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) Social Plugins (“Plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Facebook. The list and appearance of the Facebook social plugins can be viewed here.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law.
When a user activates a function of this online offer that contains such a plugin, his or her device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer by the user. User profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform the users according to our state of knowledge.
By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his or her Facebook account. If users interact with the plugins, for example, by pressing the Like button or making a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out his or her IP address and store it. According to Facebook, only an anonymized IP address is stored in Germany.
If a user is a Facebook member and does not want Facebook to collect data about him or her via this online offer and link it to his or her membership data stored on Facebook, he or she must log out of Facebook and delete his or her cookies before using our online offer. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings or via the US-American page or the EU page. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.
Within our online offer, functions and contents of the service Twitter, offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated. This may include, for example, content such as images, videos or text and buttons with which users can share content from this online service within Twitter.
Within our online offer, functions and contents of the Google+ platform, offered by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”), can be integrated. This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Google. If the users are members of the Google+ platform, Google can assign the call of the above-mentioned contents and functions to the user profiles there.