HP Andrea Kußmaul-Riempp,
Wielandstr. 16, 75223 Niefern-Öschelbronn
Tel .: +49 7233-6870780
Fax: +49 7233-6870787
Types of processed data
- Inventory data (e.g. names, addresses)
- Contact information (e.g. e-mail, phone 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 affected persons
Visitors and users of this online offering (hereinafter we refer to the affected persons as "users").
Purpose of processing
- Provision of our online offering, its functions and contents
- 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 the "data subject"); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
"Processing" means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term is broadly defined and includes virtually any handling of data.
"Responsible person" means the natural or legal person, public authority, legal entity, or organisation that decides, alone or in concert with others, on the purposes and means of processing personal data.
Relevant legal basis
In accordance with Art. 13 DSGVO, we inform the users of our online offering about the legal basis of our data processing. Unless the legal basis in the data privacy declaration is explicitly mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 DSGVO, the legal basis for data processing for the provision of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b DSGVO, the legal basis for processing in order to fulfil our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO. In case vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO is the legal basis for this.
Collaboration with data processors and third parties
If, in the context of our data processing, we disclose data to other persons and companies (contract processors or third parties), transmit data to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) DSGVO to fulfil the contract), users have consented, to comply to a legal obligation, or based on our legitimate interests (e.g. the use of agents, webhosters, etc.).
If we commission third parties to process data on the basis of a so-called "contract processing agreement", this is done on the basis of Art. 28 DSGVO.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is 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 legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. DSGVO. The processing is done e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the USA through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
Rights of data subjects
Data subjects have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 DSGVO.
They also have according to Art. 16 DSGVO the right to demand the completion of the data concerning themselves or the correction of the incorrect data concerning you.
In accordance with Art. 17 DSGVO, they have the right to demand that the respective data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 DSGVO.
They have the right to demand that the data relating to them, which they have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other persons responsible.
They have according to Art. 77 DSGVO the right to file a complaint with the responsible supervisory authority.
Data subjects have the right to revoke their formerly granted consent in accordance with Art. 7 para. 3 DSGVO with effect for the future.
Right to object
Data subjects can object to the future processing of their data in accordance with Art. 21 DSGVO at any time. The objection may in particular be made against processing for direct marketing purposes.
Cookies and right to object to direct mailing
"Cookies" are small files that are stored on users' computers. Different data can be stored within cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after a user's visit to an online offering. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online store or a login status are stored. The term "permanent" or "persistent" refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit an online offering again later. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A "third-party cookie" refers to cookies that are offered by providers other than the persons responsible for this online offering (otherwise, if it is only our cookies, this is called "first-party cookies").
If users do not want cookies stored on their computer, we ask them to disable the respective options in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offering.
Deletion of data
Furthermore we process
- contract data (e.g., subject, term, user category),
- payment data (e.g., bank details, payment history)
from our patients, prospects and healthcare partners for the purpose of providing contractual services, service and patient care, marketing, advertising and market research.
We may use hosting services for the purpose of providing the following services: infrastructure and platform services, computing capacity, storage and database services, security and technical maintenance services we use to operate this online offering.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of patients, interested parties and users of this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering in acc. to Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO (signing of a contract processing agreement).
Collection of access data and logfiles
We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, confirmation of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider. Logfile information is stored for security reasons (e.g. to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further storage is required for evidence purposes are excluded from the deletion until final clarification of the respective incident.
When contacting us (e.g. by contact form, e-mail, telephone or via social media) the information of the user for processing the contact request and its handling acc. to Art. 6 para. 1 lit. b) DSGVO is processed by us. The information provided by the users can be stored in a Customer Relationship Management System ("CRM System") or a comparable request system. We delete the requests, if these are no longer required. We check the necessity every two years. Furthermore, the legal archiving obligations apply.
With the following explanations, we inform users about the content of our newsletter as well as the registration, sending and statistical evaluation procedures as well as users' right of objection. By subscribing to our newsletter, users consent to its receipt and the procedures described.
Content of newsletters: We will send newsletters, e-mails and other electronic notifications with promotional information (hereinafter "newsletter") to users only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described during registration, this is authoritative for the consent of the users. Furthermore, our newsletters contain information about our services and us.
Double opt-in and logging: The registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration, a user will receive an e-mail asking him to confirm his registration. This confirmation is necessary to inhibit an unauthorized registration of e-mail addresses, e.g. those of other persons. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the registration and the confirmation time, as well as the IP address. Likewise, changes to user data stored with the sending service provider will be logged.
Credentials: To subscribe to the newsletter, users are asked to provide their e-mail address and a name for personal addressing in the newsletters.
Germany: The dispatch of the newsletter and the associated performance measurement is based on the consent of the recipient acc. to Art. 6 para. 1 lit. a, Art. 7 DSGVO in connection with § 7 Abs. 2 No. 3 UWG or on the basis of the legal permission according to § 7 Abs. 3 UWG.
The logging of the registration process is based on our legitimate interests in accordance with Art. 6 para. 1 lit. f DSGVO. Our interest lies in the use of a user-friendly and secure newsletter system, which serves both our interests and the expectations of the users and also allows us to prove the given consent.
Termination / Revocation: You may terminate the receipt of our newsletter at any time, i.e. withdraw your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may save the submitted email addresses for up to three years based on our legitimate interests before we delete them to prove prior consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.
Newsletter - Success Measurement
The newsletters may contain a so-called "web-beacon", i.e. a pixel-sized file that is retrieved from our server when opening the newsletter, or if we use an e-mailing service provider, from his server. Its loading will initially collect technical information, such as information about the browser and system of the user, as well as the requesting IP address and time of retrieval.
This information is used to improve the technical performance of our services based on the technical specifications, or the target audience and its reading habits, and based on their locations (which can be determined using the IP address) or access times. Statistical evaluations may also include determining if the newsletters are be opened, when they are opened and which links are clicked. For technical reasons, this information can in principle be assigned to the individual newsletter recipients. However, it is neither our goal nor, if used, that of the e-mailing service provider to observe individual users. The evaluations rather serve us to recognize the reading habits of our users and to adapt our content to these habits, or to send different content according to the interests of our users.
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
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 further services related to the use of this online offering and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
The IP address submitted by the user's browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by configuring their browser software accordingly. Users may also prevent the collection by Google of the data generated by the cookie and related to its use of our online offering and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout
For more information about Google's data usage, hiring and opt-out options, please visit Google's websites: https://policies.google.com/technologies/partner-sites ("Google's use of your data when you use websites or apps of our partners"), https://policies.google.com/technologies/ads ("Use of data for promotional purposes"), https://adssettings.google.com/authenticated ("Managing information that Google uses to show you advertising").
Online presence in social media
We maintain online presences within social networks and platforms in order to communicate with patients, prospects and users active there and to inform them about our services. When using the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
Integration of services and contents of third parties
Based on our legitimate interests (i.e. interest in the analysis, optimization and efficient operation of our online offering within the meaning of Art. 6 (1) lit. DSGVO), we make use of content or services offered by third-party providers in order to include their content and services, such as videos or fonts (collectively referred to as "content").
This always presupposes that the third-party providers of this content receive the IP address of our users, since they could not send the content to a user's browser without its IP address. The IP address is therefore required for the presentation of this content. We intend to only use content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to 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 include, but is not limited to, technical information about the browser and operating system, referring web pages, date and time of visit, and other information regarding the use of our online offer.
Created with Datenschutz-Generator.de by RA Dr. med. Thomas Schwenke