PRIVACY POLICY

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 and 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 jointly referred to as “online offering”). With regard to the terms used, such as “processing” or “person responsible”, we refer you to the definitions in Art. 4 of the Data Protection Basic Regulation (DSGVO).

Responsible

Systemic single and couple therapy Berlin
Katrin Schuy

Ehrenfeslsstr. 44, 10318 Berlin, Germany

E-mail address: kontakt@systemische-therapie-berlin.net
Managing Director/ Owner: Katrin Schuy
Link to the imprint: https://systemische-therapie-berlin.net/impressum/

Types of data processed

– Inventory data (e.g., person 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., 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 (hereinafter referred to collectively as “users”).

Purpose of processing

– Provision of the online offer, its functions and contents.
– Answering contact requests and communicating with users.
– Security measures.
– Range measurement/Marketing

Terms used

“personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier (e.g. a cookie) or to one or more specific characteristics which express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, is regarded as identifiable.

“processing” means any operation carried out with or without the aid of automated processes, or set of operations, involving personal data. The term is broad and covers practically every handling of data.

“Pseudonymisation” 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 provision of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person.

The “controller” is 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.

Applicable legal bases

In accordance with Art. 13 DSGVO we inform you about the legal basis of our data processing. For users from the area of application of the data protection basic regulation (DSGVO), i.e. the EU and the EEC, the following applies, if the legal basis is not mentioned in the data protection explanation:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO;
The legal basis for the processing for the fulfilment of our services and the implementation of contractual measures as well as the answering of inquiries is Art. 6 para. 1 lit. b DSGVO;
The legal basis for the processing for the fulfilment of our legal obligations is Art. 6 para. 1 lit. c DSGVO;
Art. 6 para. 1 lit. d DSGVO serves as the legal basis in the event that vital interests of the data subject or another natural person necessitate the processing of personal data.

In the event that vital interests of the data subject or another natural person necessitate the processing of personal data, Art. 6 para. 1 lit. d DSGVO serves as the legal basis.
The legal basis for the processing necessary for the performance of a task which is in the public interest or in the exercise of official authority entrusted to the data controller is Art. 6 para. 1 lit. e DSGVO.
The legal basis for the processing to safeguard 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 (4) DSGVO.
The processing of special categories of data (pursuant to Art. 9 para. 1 DSGVO) is governed by the provisions of Art. 9 para. 2 DSGVO.

Safety measures

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, extent, 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, in order to ensure a level of protection appropriate to the risk.

Measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to, access to, inputting, disclosure, securing and separation of data. In addition, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data and the response to data threats. 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, joint managers and third parties

Insofar as we disclose data to other persons and companies (contract processors, jointly responsible persons or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take 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 fulfilment of 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.).

Insofar as we disclose, transmit or otherwise grant access to data to other companies of our group of companies, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis corresponding to the 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 if this is done in the context of the use of third party services or disclosure or transfer of data to other persons or companies, this only occurs if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only if the legal requirements are met. I.e. the processing takes place e.g. on basis of special guarantees, like the officially recognized statement of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or observance of officially recognized special contractual obligations.

Rights of data subjects

You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.

You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the inaccurate data concerning you.

In accordance with the statutory provisions, you have the right to demand that the data concerned be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.

You have the right to demand that the data concerning you which you have made available to us be received in accordance with the statutory provisions and that it be transferred to other persons responsible.

They also have the right to file a complaint with the competent supervisory authority in accordance with the statutory provisions.

Right of withdrawal

You have the right to revoke any consent you have given with effect for the future.

Right of objection

You may object at any time to the future processing of the data concerning you in accordance with the statutory provisions. In particular, you may object to the processing of your data for the purposes of direct marketing.

Cookies and right of objection for direct advertising

Cookies” are small files that are stored on the user’s computer. Different data 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 the user’s visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. The content of a shopping basket in an online shop or a login status, for example, can be stored in such a cookie. 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 who are used for range measurement or marketing purposes can also be stored in such a cookie. Third party cookies” are cookies that are offered by providers other than the person responsible for operating the online service (otherwise, if they are only the latter’s cookies, they are referred to as “first party cookies”).

We may use temporary and permanent cookies and explain this in our privacy policy.

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 your browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ . In addition, cookies can be saved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

Deletion of data

The data processed by us will be deleted in accordance with the statutory provisions or their processing will be restricted. 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 there are no legal obligations to retain them.

If the data are not deleted because they are required for other and legally permissible purposes, their 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 stored for commercial or tax reasons.

Changes and updates to the data protection declaration

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.

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 para. 1 lit. b) DSGVO in order to provide them with our contractual or pre-contractual services. The data processed, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship. The processed data basically includes the patient’s inventory and master data (e.g., name, address, etc.), as well as contact data (e.g., e-mail address, telephone, etc.), contract data (e.g., services used, products purchased, costs, names of contact persons) and payment data (e.g., bank details, payment history, etc.).

Within the scope of our services, we can also process special categories of data in accordance with Art. 9 Para. 1 DSGVO, in particular information on the health of patients, possibly with reference to their sexual life or sexual orientation. If necessary, we collect this information 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 health care purposes on the basis of Art. 9 Para. 2 lit. h. DSGVO, § 22 para. 1 no. 1 b. BDSG.

Insofar as necessary for the performance of the contract or required by law, we disclose or transmit patient data within the scope of communication with medical specialists, third parties involved in the performance of the contract, such as laboratories, accounting offices or comparable service providers, if this is necessary or typical for the provision of our services pursuant to Art. 6 Para. 1 lit b. BDSG. DSGVO serves, legally according to Art. 6 Para. 1 lit c. DSGVO, our interests or those of patients in efficient and cost-effective health care are regarded as legitimate interests pursuant to Art. 6 Para. 1 lit. f. of the DSGVO. DSGVO or is necessary pursuant to Art. 6 para. 1 lit. d. DSGVO. in order to protect the vital interests of patients or another natural person or within the framework of a consent pursuant to Art. 6 para. 1 lit. a., Art. 7 DSGVO.

The data will be deleted if it is no longer necessary to fulfil contractual or statutory duties of care or to deal with any warranty or comparable obligations, whereby the necessity of storing the data is reviewed every three years; otherwise the statutory duties of storage apply.

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) DSGVO in order to provide them with our contractual or pre-contractual services. The data processed, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship. The processed data basically includes inventory and master data of the clients (e.g., name, address, etc.), as well as contact data (e.g., e-mail 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.).

Within the scope 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, possibly with reference to their sexual life or sexual orientation, ethnic origin or religious or ideological convictions. For this purpose, we call, if necessary, according to Art. 6 Para. 1 lit. a., Art. 7, Art. 9 Para. 2 lit. a. DSGVO and otherwise process the special categories of data for health care purposes on the basis of Art. 9 Para. 2 lit. h. DSGVO, § 22 para. 1 no. 1 b. BDSG.

Insofar as is necessary for the performance of the contract or required by law, we disclose or transmit the client’s data within the scope of communication with other specialists, third parties involved in the performance of the contract, such as accounting offices or comparable service providers, if this is necessary for the provision of our services pursuant to Art. 6 Para. 1 lit b. BDSG. DSGVO serves, legally according to Art. 6 para. 1 lit c. DSGVO, our interests or those of our clients in efficient and inexpensive health care are deemed to be a legitimate interest pursuant to Art. 6 para. 1 lit f. DSGVO or is necessary pursuant to Art. 6 para. 1 lit. d. DSGVO. in order to protect the vital interests of clients or another natural person or within the scope of a consent pursuant to Art. 6 para. 1 lit. a., Art. 7 DSGVO.

The data is deleted when the data is no longer required for the fulfilment of contractual or statutory duties of care and for the handling of any warranty and comparable obligations, whereby the necessity of storing the data is reviewed every three years; otherwise the statutory duties of storage apply.

Business analyses and market research

In order to run our business economically, to be able to recognise market trends, wishes of our contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., in order to identify the most suitable and appropriate solutions for your needs. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby contractual partners, interested parties, customers, visitors, etc., are bound to the persons concerned.

The analyses are carried out for the purpose of economic evaluations, marketing and market research. We can consider the profiles of the registered users with information, e.g. about their used services. The analyses serve us to increase user friendliness, to optimise our range of services and to improve business efficiency. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with summarized values.

If these analyses or profiles are person-related, they will be deleted or anonymised upon termination by the user, otherwise after two years from the conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.

Hosting and e-mail dispatch

The hosting services used by us serve the provision of the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services which we use for the purpose of operating this online service.

Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors to this online service on the basis of our legitimate interests in the efficient and secure provision of this online service in accordance with Art. 6 Para. 1 lit. f DSGVO in connection with Art. 28 DSGVO (conclusion of an order processing contract).

Collection of access data and log files

We, and/or our Hostinganbieter, raise on basis of our entitled interests in the sense of the art. 6 Abs. 1 lit. f. DSGVO collects data on each access to the server on which this service is located (so-called server log files). 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 clarify abuse or fraud actions) for a maximum period of 7 days and then deleted. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.

Google Analytics

On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. of the German Civil Code), we act in accordance with the following principles DSGVO) Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about users’ use of the website is generally transmitted to and stored by Google on servers in the United States.

Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online services by users, to compile reports on activities within this online service and to provide us with other services related to the use of this online service and the Internet. Pseudonymous user profiles can be created from the processed data.

We use Google Analytics only 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. Only in exceptional cases is the full IP address 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 may refuse the use of cookies by selecting the appropriate settings on their browser, they may also refuse the use of cookies by selecting the appropriate settings on their browser, they may refuse the use of cookies by selecting the appropriate settings on their browser, and they may refuse the processing of cookies by selecting the appropriate settings on Google, and they may refuse the processing of cookies by selecting the appropriate settings on Google, and they may refuse the processing of cookies by Google, by downloading and installing the browser plugin available from the following link: http://tools.google.com/dlpage/gaoptout?hl=de=en.

 

Further information on the use of data by Google, setting 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).

The personal data of the users will be deleted or anonymized after 14 months.