This data protection declaration tells you about the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of providing our services as well as within our online offering and the websites, functions and content associated with it as well as external online presences, such as. our social media profile (hereinafter collectively referred to as “online offering”). With regard to the terms used, such as “processing” or “responsible person”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Types of data processed
- Inventory data (e.g., personal master data, names or addresses).
- Contact details (e.g., email, telephone numbers).
- Content data (e.g., text entries, 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 offering (hereinafter we refer to the affected persons collectively as “users”).
Purpose of processing
- Provision of the online offer, its functions and content.
- Answering contact requests and communicating with users.
- Safety measures.
- Reach measurement/marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); A natural person is considered identifiable if he or she 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. cookie) or one or more special features, which are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
“Processing” means any operation or series of operations relating to personal data, carried out with or without the aid of automated procedures. The term is broad and encompasses virtually every way data is handled.
“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data not be assigned to an identified or identifiable natural person.
“Profiling” means any type of automated processing of personal data, which consists in using that personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, economic situation, health, personal Analyze or predict the preferences, interests, reliability, behavior, location or movements of that natural person.
The “controller” is the natural or legal person, public 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, public authority, institution or other body that processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 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, the following applies, unless the legal basis is stated in the data protection declaration:
The legal basis for obtaining consent is Article 6 Paragraph 1 Letter a and Article 7 GDPR;
The legal basis for processing to fulfill our services and carry out contractual measures as well as answer inquiries is Article 6 Paragraph 1 Letter b GDPR;
The legal basis for processing to protect our legitimate interests is Article 6 (1) (f) GDPR.
In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6 (1) (d) GDPR serves as the legal basis.
The legal basis for the processing necessary to carry out a task that is in the public interest or in the exercise of official authority vested in the person responsible is Article 6 (1) (e) GDPR.
The legal basis for this processing to protect our legitimate interests is Art. 6 Para. 1 lit. f GDPR.
The processing of data for purposes other than those for which they were collected is determined in accordance with the provisions of Article 6 (4) GDPR.
The processing of special categories of data (according to Art. 9 Para. 1 GDPR) is determined in accordance with the provisions of Art. 9 Para. 2 GDPR.
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 the processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons Measures to ensure a level of protection appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, distribution, ensuring availability and its separation. We have also set up procedures to ensure the exercise of the rights of those affected, the deletion of data and the response to threats to data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.
Collaboration with processors, joint controllers and third parties
If, as part of our processing, we disclose data to other people and companies (processors, joint controllers or third parties), transfer it to them or otherwise grant them access to the data, this only takes place on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary for the fulfillment of the 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, 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, moreover, on a basis that complies with legal requirements.
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 using third-party services or disclosing or transferring data to other people or companies If this happens, this will only occur if it is to fulfill our (pre-)contractual obligations, based on your consent, based on a legal obligation or based on our legitimate interests. Subject to express consent or contractually required transfer, we only process or leave the data in third countries with a recognized level of data protection, which include US processors certified under the “Privacy Shield”, or on the basis of special guarantees, such as contractual obligations through so-called standard protection clauses the EU Commission, the existence of certifications or binding internal data protection regulations (Articles 44 to 49 GDPR, EU Commission information page).
Rights of data subjects
Right to information: 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 legal requirements.
Right to rectification: In accordance with legal requirements, you have the right to request that the data concerning you be completed or that incorrect data concerning you be corrected.
Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to demand that the data in question be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with the legal requirements.
Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with legal requirements or to request that it be transmitted to another person responsible.
Complaint to the supervisory authority: You also have the right, in accordance with legal requirements, to submit a complaint to the responsible supervisory authority.
Right of withdrawal
You have the right to revoke your consent with effect for the future.
Right to object
Right to object: You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is carried out on the basis of Article 6 (1) (e) or (f) of the GDPR; This also applies to profiling based on these provisions. If your personal data is processed for the purpose of direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; This also applies to profiling insofar as it is connected to such direct advertising.
Cookies and right to object to direct advertising
“Cookies” are small files that are stored on users’ computers. 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 their visit to an online offering. Temporary cookies, or “session cookies” or “transient cookies,” are cookies that are deleted after a user leaves an online offering and closes their browser. Such a cookie can, for example, store the contents of a shopping cart in an online shop or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be saved if users visit it after several days. The interests of users can also be stored in such a cookie, which is 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 offering (otherwise, if they are only their cookies, they are referred to as “first-party cookies”).
We can use temporary and permanent cookies and explain this in 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 browser’s system settings. The exclusion of cookies can lead to functional restrictions of this online offer.
You can view or change your privacy settings any time.
Deletion of data
The data we process will be deleted or its processing restricted in accordance with legal requirements. Unless expressly stated in 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 does not conflict with any legal retention obligations.
Unless the data is deleted because it is required for other legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
Therapeutic services and coaching
We process the data of our clients and interested parties and other clients or contractual partners (uniformly referred to as “clients”) in accordance with Art. 6 Para. 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 necessity of their processing are determined by the underlying contractual relationship. The data processed generally includes the clients’ inventory and master data (e.g., name, address, etc.), as well as contact details (e.g., email address, telephone, etc.), contract data (e.g., services used, Fees, names of contact persons, etc.) 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 Article 9 Paragraph 1 GDPR, in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, ethnic origin or religious or ideological beliefs . For this purpose, if necessary, we will consult Art. 6 Para. 1 lit. a., Art. 7, Art. 9 Para. 2 lit. a. GDPR requires the express consent of the clients and otherwise processes the special categories of data for health care purposes on the basis of Article 9 Paragraph 2 lit h. GDPR, Section 22 Paragraph 1 No. 1 b. BDSG.
If required for the fulfillment of the contract or by law, we disclose or transmit the client’s data in the context of communication with other specialists, third parties who are necessary or typically involved in the fulfillment of the contract, such as billing offices or comparable service providers, provided that this is necessary for the provision of our services in accordance with Art. 6 paragraph 1 lit b. GDPR serves, legally in accordance with Art. 6 Para. 1 lit c. DSGVO is prescribed, serves our interests or those of our clients 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 clients or another natural person or within the scope of consent in accordance with Article 6 Paragraph 1 Letter a., Article 7 GDPR.
The data will be deleted when the data is no longer required to fulfill contractual or legal duties of care as well as to deal with any warranty and comparable obligations, whereby the necessity of retaining the data is reviewed every three years; Otherwise, the statutory retention requirements apply.
Administration, financial accounting, office organization, contact management
We process data as part of administrative tasks such as organizing our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process as part of the provision of our contractual services. The basis for processing is Article 6 Paragraph 1 Letter c. GDPR, Art. 6 Para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, carry out our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and payment service providers.
Furthermore, based on our business interests, we store information about suppliers, organizers and other business partners, e.g. for the purpose of later contact. We generally store this mostly company-related data permanently.
When contacting us (e.g. via contact form, email, telephone or via social media), the user’s information is used to process the contact request and process it in accordance with Article 6 Paragraph 1 Letter b. (as part of contractual/pre-contractual relationships), Art. 6 Para. 1 lit. f. (other inquiries) GDPR processed. User information can be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.
We delete the requests if they are no longer necessary. We review the necessity every two years; The statutory archiving obligations also apply.
Hosting and email delivery
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email delivery, security services and technical maintenance services, which we use for the purpose of operating this online offering.
In doing so, 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 offering based on our legitimate interests in the efficient and secure provision of this online offering in accordance with Art. 6 Para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract).
Collection of access data and log files
We, or our hosting provider, collect data about 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 Article 6 Paragraph 1 Letter f of the GDPR. The access data includes the name of the website accessed, 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 .
Log file information is stored for security reasons (e.g. to investigate acts of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Google Tag Manager
Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus, for example, integrate Google Analytics and other Google marketing services into our online offering). The Tag Manager itself (which implements the tags) does not process any personal data of users. With regard to the processing of users’ personal data, reference is made to the following information on Google services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.
Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering and to provide us with other services related to the use of this online offering and internet usage. Pseudonymous user profiles can be created from the processed data.
We only use Google Analytics with IP anonymization activated. This means that the user’s IP address is shortened by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser is not 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 offering and from processing this data by Google by downloading and installing the browser plug-in available at the following link: http://tools .google.com/dlpage/gaoptout?hl=de.
If we ask users for consent (e.g. as part of cookie consent), the legal basis for this processing is Art. 6 Para. 1 lit. a. GDPR. Otherwise, the users’ personal data will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 Para. 1 lit. f. GDPR).
To the extent that data is processed in the USA, we would like to point out that Google is certified under the Privacy Shield Agreement and thereby guarantees that it will comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active) .
Further information on data usage by Google, settings and objection options can be found in Google’s data protection declaration (https://policies.google.com/privacy) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).
Users’ personal data will be deleted or anonymized after 14 months.
Our website uses the Hotjar web analysis service from Hotjar Ltd. Hotjar Ltd. is a European company based in Malta (Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe, Tel.: +1 (855) 464-6788).
With this tool, movements on the websites on which Hotjar is used can be tracked (so-called heatmaps). For example, you can see how far users scroll and which buttons users click and how often. The tool also makes it possible to obtain feedback directly from website users. Above all, the functionality of the Hotjar-based website can be improved by Hotjar’s services, making them more user-friendly, more valuable and easier to use for end users.
When using this tool, we pay particular attention to protecting your personal data. This means we can only track which buttons are clicked, the path of the mouse, how far the device is scrolled, the screen size of the device, device type and browser information, geographical location (country only) and the preferred language to display our website. Areas of the websites in which personal data from you or third parties are displayed are automatically hidden by Hotjar and are therefore not traceable at any time. In order to exclude direct personal reference, IP addresses are only stored and processed anonymously. However, Hotjar uses various third-party services such as Google Analytics and Optimizely. It may therefore be the case that these services collect data that is transmitted by your browser as part of web page requests. These would be, for example, cookies or your IP address. In these exceptional cases, this processing is carried out in accordance with Article 6 Paragraph 1 Letter a of the GDPR based on the consent you have given for the purpose of statistical analysis of user behavior for optimization and marketing purposes.
The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. The data will be deleted no later than 12 months after it was collected.
Hotjar offers every user the opportunity to prevent the use of the Hotjar tool using a “Do Not Track header” so that no data about the visit to the respective website is recorded. This is a setting that all common browsers support in current versions. To do this, your browser sends a request to Hotjar to deactivate the tracking of the respective user. If you use our websites with different browsers/computers, you must set up the “Do Not Track header” separately for each of these browsers/computers.
When you visit a Hotjar-based website, you can prevent Hotjar from collecting your data at any time by going to our opt-out page https://www.hotjar.com/legal/compliance/opt-out/ and clicking deactivate Hotjar .
More information about Hotjar Ltd. and the Hotjar tool can be found at:
Target group formation with Google Analytics
We use Google Analytics to show the advertisements placed within the advertising services of Google and its partners only to those users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products) based on the information they visit websites) that we transmit to Google (so-called “remarketing” or “Google Analytics audiences”). With the help of remarketing audiences, we also want to ensure that our ads match the potential interest of users.
German version created with Datenschutz-Generator.de by RA Dr. Thomas Schwenke