Contents

1        General information, controller, data protection officer

1.1        Note on the responsible body

1.2        Data Protection Officer

1.3        Scope of the processing of personal data

1.4        Legal basis for the processing of personal data

1.5        Data deletion and storage duration

1.6        Note on data transfer to the USA

2        Use of our website

2.1        Provision of the website, CDN and creation of log files

2.1.1        Informational use

2.1.2        Hosting

2.1.3        Use of cookies

2.1.4        Cookie consent with the "Cookie Consent Tool"

2.1.5        Cloudflare

2.1.6        Uploadcare

2.1.7        jsDelivr

2.2        Plugins and tools

2.2.1        Posthog

2.2.2        Sentry

2.2.3        Hubspot

2.2.4        Google Tag Manager

2.2.5        Google Analytics

2.2.6        Microsoft Advertising

2.2.7        Meta Pixel

2.2.8        Contentful

2.2.9        DoubleClick

2.2.10        reCAPTCHA

2.2.11        Availy / Anamnesis / Happy / PROMS

2.2.12        GRWAPI

2.2.13        Social media presence

3        Use of services, own services

3.1        Contact form and e-mail contact

3.2        Handling applicant data

4        Rights of the data subject

4.1        Right to information

4.2        Right to rectification

4.3        Right to restriction of processing

4.4        Right to erasure

4.4.1        Obligation to delete

4.4.2        Information to third parties

4.4.3        Exceptions

4.5        Right to information

4.6        Right to data portability

4.7        Right of objection

4.8        Right to revoke the declaration of consent under data protection law

4.9        Automated decision in individual cases including profiling

4.10        Right to lodge a complaint with a supervisory authority

5        Data security, third-party websites, changes

5.1        SSL or TLS encryption

5.2        Data protection and third-party websites

5.3        Changes to this privacy policy

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Privacy policy https://www.dental21-ulm.de/

and at the same time informing data subjects in accordance with Article 13 and Article 14 GDPR

1. General information, controller, data protection officer

1. Note on the responsible body

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is the:

MVZ Dentalzentrum Ulm GmbH

Wengengasse 29

89073 Ulm

Phone: 0731 85072441

Email: ulm-mitte@dental21.de

2. Data Protection Officer

The data protection officer of the institution can be contacted at datenschutz@patient21.com.

3. Scope of the processing of personal data

In principle, data relating to health is very sensitive data. For this reason, data protection is particularly important to us.

We only process our users' personal data insofar as this is necessary to provide a functional website and our content and services. The processing of our users' personal data only takes place regularly with the user's consent. An exception applies in cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by law.

4. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.

If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing.

5. Data erasure and storage duration

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Data may also be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. The data will also be blocked or erased if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfillment of a contract.

6. Note on data transfer to the USA

Among other things, tools from companies based in the USA are integrated on our website. If these tools are active, your personal data may be transferred to the US servers of the respective companies. We would like to point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are obliged to disclose personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for surveillance purposes. We have no influence on these processing activities. We have concluded valid suitable guarantees with the service providers for the transfer to these third countries in accordance with Art. 46 para. 2 GDPR.

At no time will health data be transferred to the USA. If you have any further questions, please contact our data protection officer.

2. Use of our website

1. Provision of the website, CDN and creation of log files

1. Informational use

Description and scope of data processing

It is generally not necessary for you to provide personal data in order to use our website for information purposes only. Rather, in this case we only collect and use the data that your Internet browser automatically transmits to us, such as:

• Date and time of access to one of our web pages
• Your browser type
• the browser settings
• the operating system used
• the last page you visited
• the amount of data transferred and the access status (file transferred, file not found, etc.)
• Your IP address.

Purpose of data processing

We collect and use this data during an informational visit exclusively in non-personalized form. This is done to enable you to use the web pages you have accessed, for statistical purposes and to improve our website. The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.

Legal basis for data processing

The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.

Purpose of data processing

Temporary storage of the IP address by the system is necessary to enable delivery of the website to the user's device. For this purpose, the user's IP address must remain stored for the duration of the session.

Duration of storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. If the data is stored in log files, this is the case after fourteen days at the latest. In this case, the IP addresses of the users are deleted or anonymized so that it is no longer possible to identify the accessing user. Access to the log data is only possible directly and exclusively for administrators.

Possibility of objection and removal

The collection of data for the provision of services and the storage of data in log files is absolutely necessary for the operation of the services offered. The user can object to this. Whether the objection is successful must be determined as part of a weighing of interests.

Further information

In order to use our offer and other services, it may be necessary to provide personal data. Further information on the use of these services can be found in the section "Use of offers".

2. Hosting

This website is hosted by an external service provider (hoster). Our service provider is:

Vercel Inc, 440 N Barranca Ave #4133, Covina, CA 91723, USA

The personal data collected on this website is stored on the hoster's servers. This may include IP addresses, contact requests, meta and communication data, contact details, names, website accesses and other data generated via a website.

This data is not merged with other data sources. This data is collected on the basis of Art. 6 para. 1 lit. f GDPR. Our legitimate interest in processing this data is to display our website without errors and to optimize its functions.

Our hoster will only process your data to the extent necessary to fulfill its performance obligations and follow our instructions with regard to this data.

In order to guarantee data protection-compliant processing, we have concluded an order processing contract with our hoster.

The website server is geographically located in the USA.

3. Use of cookies

Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user accesses a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

When accessing our website, the user is informed about the use of cookies by a consent banner and his consent to the processing of the personal data used in this context is obtained and documented in accordance with data protection regulations. In this context, there is also a reference to this data protection declaration and a reference to how the storage of cookies can be prevented in the browser settings.

We use cookies on our website that are not technically necessary. Cookies that are not technically necessary are text files that are not only used for the functionality of the website, but also collect other data.

By setting technically unnecessary cookies, the following data is processed:

• IP address
• Location of Internet users
• Date and time the website was accessed
• Customization of advertisements to the user
• Tracking of surfing behavior
• Linking the website visit with other social media platforms

You can determine yourself whether cookies can be set and retrieved using the settings in your browser. For example, you can completely deactivate the storage of cookies in your browser, restrict it to certain websites or configure your browser so that it automatically notifies you as soon as a cookie is to be set and asks you for feedback. For technical reasons, however, it is necessary to allow the above for the full functionality of our website.

Each browser differs in the way it manages cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You can find these for the respective browsers under the following links:

Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies

Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen

Chrome: https://support.google.com/chrome/answer/95647?hl=de&hlrm=en

Safari: https://support.apple.com/de-de/guide/safari/sfri11471/mac

Opera: https://help.opera.com/de/latest/web-preferences/#cookies

Please note that if you do not accept cookies, the functionality of our website may be restricted.

Legal basis for data processing

The provisions of the Telecommunications and Telemedia Data Protection Act (TTDSG) apply to the storage of information in the end user's terminal equipment and/or access to information already stored in the end user's terminal equipment. If the setting and reading of cookies is technically necessary, this is done to ensure the functionality of our website. In this case, cookies are stored and accessed on your terminal equipment on the basis of Section 25 (2) No. 2 TTDSG. The purpose of storing and accessing the information in your terminal equipment is to make it easier for you to use our website and to be able to offer you our services as you have requested. Some functions of our website would not work without the use of these cookies and could therefore not be offered. The cookies are generally deleted at the end of the session (e.g. logging out or closing the browser) or after a specified period of time.

Insofar as cookies are used that are not technically necessary, this is done on the basis of your express consent, which you can give via the cookie banner. In this case, the basis for storing and accessing information is Section 25 (1) TTDSG in conjunction with Art. 6 para. 1 lit. a), Art. 7 GDPR. You can revoke your consent at any time with effect for the future or subsequently grant it again by configuring your cookie settings accordingly. Alternatively, you can prevent the storage of cookies by making the appropriate settings in your browser software. Please note that the browser settings you make only apply to the browser you are using. If personal data is processed following the storage of and access to the information on your end device, the provisions of the GDPR apply. You can find information on this in the following sections of this privacy policy.

Purpose of data processing

If technically necessary cookies are used:

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary for the browser to be recognized even after a page change. We require cookies for the following applications:

• Saving the settings of the cookie notice banner (consent tool)
• Optimization of the functionality and design of our website.

The user data collected by technically necessary cookies is not used to create user profiles.

Cookies that are not technically necessary are used for the purpose of improving the quality of our website, its content and thus our reach and efficiency. By setting these cookies, we learn how the website is used and can thus constantly optimize our offer. In particular, these cookies serve the following purposes:

• Objective measurement of user numbers
• Analysis of user data

Duration of storage, objection and removal options

Cookies are stored on the user's computer and transmitted by it to our website. As a user, you therefore have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.

You will be informed about the exact storage period in the notes in our consent tool. If consent has also been given there, you can object to this there.

4. Cookie consent with the "Cookie Consent Tool"

Our website uses the cookie consent technology of

Usercentrics GmbH Sendlinger Str. 7, 80331 Munich, Germany

to obtain your consent to the storage of certain cookies on your end device and to document this in compliance with data protection regulations.

Description and scope of data processing

When you enter our website, your consent and other declarations regarding the use of cookies are obtained via our consent tool. The consent tool then stores a cookie in your browser in order to be able to assign the consents you have given or revoke them.

Legal basis for data processing

The "Cookie Consent Tool" is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 sentence 1 lit. c GDPR.

Purpose of data processing

The provision of the "Cookie Consent Tool" serves to comply with overriding legal provisions and to inform users about the context in which cookies are used on this website.

Possibility of objection and removal

The data collected by the consent tool remains stored until you delete the consent cookie yourself or the purpose for data storage no longer applies. Mandatory statutory retention obligations remain unaffected.

5. Cloudflare

This website uses the "Cloudflare" service. The provider is Cloudflare Inc, 101 Townsend St., San Francisco, CA 94107, USA (hereinafter referred to as "Cloudflare").

Description and scope of data processing

Cloudflare offers a globally distributed content delivery network with DNS. Technically, the information transfer between your browser and our website is routed via Cloudflare's network. This enables Cloudflare to analyze the traffic between your browser and our website and to serve as a filter between our servers and potentially malicious traffic from the Internet. Cloudflare may also use cookies or other technologies to recognize Internet users, but these are used solely for the purpose described here.

Legal basis for data processing

The processing of your data by the Meta Pixel is generally based on your consent (Art. 6 para. 1 lit. a GDPR).

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here:

https://www.cloudflare.com/privacypolicy/.

Further information on security and data protection at Cloudflare can be found here:

https://www.cloudflare.com/privacypolicy/.

In order to ensure data protection-compliant processing, we have concluded an order processing contract with Cloudflare.

6. Uploadcare

This website uses the "Uploadcare" service. The provider is Uploadcare LLC. with registered office at 18801 Collins Ave 102-120, Sunny Isles Beach, FL 33160, USA (hereinafter "Uploadcare").

Description and scope of data processing

Uploadcare is a Cloud Delivery Network (CDN) for processing and providing image files. For this purpose, all images/photos and graphics uploaded to this website (by the website owner) are uploaded to Uploadcare's servers using a plugin, optimized for display there and then delivered back to this server.

Legal basis for data processing

The use of Uploadcare is based on our legitimate interest in providing our website as error-free and secure as possible (Art. 6 para. 1 lit. f GDPR).

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://uploadcare.com/about/gdpr/.

Further information can be found at: https://uploadcare.com/about/privacy-policy/.

In order to ensure data protection-compliant processing, we have concluded an order processing contract with Uploadcare.

7. jsDelivr

To speed up the loading process of our website and optimize performance, we use jsDelivr, a content delivery network (CDN). jsDelivr is used to provide static files such as JavaScript libraries or stylesheets. By distributing these files to servers worldwide, the loading time for our users is reduced.

Purpose of data processing

Performance optimization: jsDelivr helps our website to load faster and increase user-friendliness.

Global delivery: By using jsDelivr, we can deliver our content faster worldwide.

Type of data processed

Technical usage data: When you visit our website, your IP address is transmitted to the jsDelivr servers in order to provide the requested files.

Legal basis for data processing

The processing of your data by jsDelivr is generally based on our legitimate interest in optimizing our website and improving the user experience (Art. 6 para. 1 lit. f GDPR).

2. Plugins and tools

1. Posthog

Scope of the processing of personal data

We use Posthog (https://posthog.com/) from the

PostHog Inc, 2261 Market Street #4008, San Francisco, CA 94114, USA.

PostHog can be used to analyze user behavior on our website for the purpose of improving our online offering. Your entries are not recorded, so that no name, address or health data are transmitted.

Further information on PostHog can be found at https://posthog.com/faq and in PostHog's privacy policy: https://posthog.com/privacy

Purpose of data processing

The purpose of processing personal data is to improve our online offering.

Legal basis for the processing of personal data

The legal basis for the processing of users' personal data is generally the consent of the user in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR.

Duration of storage

Your personal information will be stored for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law.

Right of revocation and removal

You have the right to withdraw your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

You can prevent the collection and processing of your personal data by PostHog by preventing the storage of third-party cookies on your computer, using the "Do Not Track" function of a supporting browser, deactivating the execution of script code in your browser or installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.

For objection and removal requests to PostHog, you can contact privacy@posthog.com.

2. Sentry

We use Sentry to ensure the stability and performance of our application. Sentry is an error monitoring service that helps us to detect and resolve technical problems in our application at an early stage. Sentry automatically collects data about errors that occur, such as stack traces, browser information and, in some cases, anonymized user IDs. This data is transmitted to Sentry's servers and analyzed there.

Purpose of data processing

Error detection and correction: Sentry helps us to identify and correct errors in our application to ensure an optimal user experience.

Performance optimization: By analyzing the collected data, we can improve the performance of our application.

Type of data processed:

Type of data processed:

Technical data: stack traces, browser information, operating system, device type.

User data (partially anonymized): User IDs, IP addresses (possibly shortened).

Legal basis for the processing of personal data

The processing of your data by Sentry is based on our legitimate interest in ensuring the functionality and security of our application (Art. 6 para. 1 lit. f GDPR).

3. Hubspot

Scope of the processing of personal data

We use Hubspot (https://hubspot.com/) from the

Hubspot INC, 2 Canal Park, Cambridge, MA 02141, USA

We use Hubspot to provide you with health information and offers at certain intervals, e.g. by e-mail. In addition to clinical data, this also includes further information on your treatment (e.g. the treatment and cost plan), additional recommendations and valuable preventive tips for your health as well as offers for our medical products.

If you give your consent, the following data will be processed:

• Names, address and contact details
• Age and gender
• Practitioner and practice data
• Medical history
• Completed treatments
• Date information
• Results of customer satisfaction surveys

Purpose of data processing

The purpose of processing personal data is to improve and individualize patient communication.

Legal basis for the processing of personal data

The legal basis for the processing of users' personal data is generally the consent of the user in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR.

Duration of storage

Your personal information will be stored for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law.

Right of revocation and removal

You have the right to withdraw your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

4. Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that enables us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store any cookies and does not carry out any independent analyses. It is only used to manage and display the tools integrated via it. However, Google Tag Manager records your IP address, which may also be transmitted to Google's parent company in the United States.

Legal basis for the processing of personal data

The Google Tag Manager is used on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the fast and uncomplicated integration and management of various tools on its website. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

5. Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. In doing so, the website operator receives various usage data, such as page views, length of visit, operating systems used and origin of the user. This data may be summarized by Google in a profile that is assigned to the respective user or their end device.

We can also use Google Analytics to record your mouse and scroll movements and clicks, among other things. Google Analytics also uses various modeling approaches to supplement the collected data records and uses machine learning technologies for data analysis.

Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is generally transmitted to a Google server in the USA and stored there.

Legal basis for the processing of personal data

The processing of your data by the Meta Pixel is generally based on your consent (Art. 6 para. 1 lit. a GDPR).

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here:

https://privacy.google.com/businesses/controllerterms/mccs/.

We have activated the IP anonymization function on this website. This means that your IP address 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 before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

You can prevent the collection and processing of your data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

You can find more information on how Google Analytics handles user data in Google's privacy policy:

https://support.google.com/analytics/answer/6004245?hl=de.

We have concluded an order processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

6. Microsoft Advertising

We use Microsoft Advertising to optimize our online advertising and present you with relevant ads. Microsoft Advertising is an online advertising platform that enables us to display our ads on various websites and in search engines.

Purpose of data processing

Personalized advertising: By analyzing your user behavior, we can present you with tailored advertisements that match your interests. Microsoft Advertising enables us to measure and optimize the effectiveness of our advertising campaigns.

Reach measurement: We can determine how many users have seen our advertising and how often.

Legal basis

The processing of your data by Microsoft Advertising is based on your consent (Art. 6 para. 1 lit. a GDPR).

7. Meta Pixel

In order to optimize our online advertising and present you with relevant ads on Meta platforms (Facebook, Instagram, etc.), we use the Meta Pixel. The Meta Pixel is a small piece of code that we have placed on our website. It enables us to track your behavior on our website and thus better understand your interests.

Purpose of data processing

Personalized advertising: By analyzing your user behavior, we can present you with tailored advertisements that match your interests.

Reach measurement: We can determine how many users have seen our advertising and how often.

Conversion tracking: We measure the effectiveness of our advertising campaigns by tracking what actions you take after clicking on one of our ads (e.g. making a purchase).

Legal basis

The processing of your data by the Meta Pixel is generally based on your consent (Art. 6 para. 1 lit. a GDPR). By continuing to use our website after being informed of the use of the meta pixel and the option to opt out, you consent to this data processing.

8. Contentful

We use the content management platform Contentful (Contentful GmbH, Max-Urich-Straße 3, 13355 Berlin, Germany) to create and manage our digital content. Contentful processes personal data on our behalf, which we collect to design our website and provide our services. Further information on data processing by Contentful can be found in their privacy policy: https://www.contentful.com/legal/privacy-at-contentful/privacy-notice/

Purpose of data processing

The data processed by Contentful is primarily used to manage our digital content and provide you with an optimal user experience. This includes, for example, the creation and maintenance of page content, the management of images and media and the personalization of content.

Type of data processed

The data processed by Contentful may vary depending on the scope of use. In general, this can be the following data:

• Technical usage data (e.g. IP address, browser information)
• Content that you create or upload via our system
• Metadata for this content

Legal basis for the processing of personal data

The processing of your personal data by Contentful is based on our legitimate interest in the efficient creation and management of our digital content and the provision of our services (Art. 6 para. 1 lit. f GDPR).

9. DoubleClick

We use Google DoubleClick, a service provided by Google LLC, to manage and optimize our online advertising. DoubleClick uses cookies and similar technologies to collect information about your use of our website. This information is used to present you with relevant ads and to measure the effectiveness of our advertising campaigns.

Purpose of data processing

Personalized advertising: By analyzing your user behavior, we can present you with tailored advertisements that match your interests.

Performance measurement: DoubleClick enables us to measure and optimize the effectiveness of our advertising campaigns.

Reach measurement: We can determine how many users have seen our advertising and how often.

Type of data processed

Technical usage data: This includes, for example, your IP address, browser information and the operating system of your device.

Usage behavior: Information about which pages you visit, which ads you click on and how long you stay on our website.

Legal basis for the processing of personal data

The processing of your data by the Meta Pixel is generally based on your consent (Art. 6 para. 1 lit. a GDPR).

10. reCAPTCHA

We use Google reCAPTCHA to protect our website from misuse. Google reCAPTCHA is used to check whether certain entries on our website originate from a human or an automated program (bot).

Purpose of data processing

Spam and abuse protection: reCAPTCHA helps us to prevent spam comments, registrations and other forms of abuse.

Website security: Distinguishing between humans and bots increases the security of our website.

Type of data processed

User interactions: reCAPTCHA analyzes your behavior on our website, such as how you move the mouse pointer or how quickly you fill out forms.

IP address: Your IP address will be transmitted to Google for verification purposes.

Legal basis for the processing of personal data

The processing of your data by reCAPTCHA is based on our legitimate interest in the security of our website and the prevention of spam (Art. 6 para. 1 lit. f GDPR).

11. Availy / Anamnesis / Happy / PROMS

Description, purpose and scope of data processing

On our website, you have the opportunity to make appointments with us, fill out a digital medical history and take part in a survey after treatment. We use the tools Availy, Ana, PROMS and Happy to book appointments, take medical histories and conduct patient surveys. The provider in each case is Patient 21 SE, Joachimsthaler Str. 20, 10719 Berlin, Germany (hereinafter "Patient 21").

To book an appointment, enter the requested data and the desired date in the form provided. The data entered will be used for the planning, execution and, if necessary, follow-up of the appointment.

To record your medical history, fill in the forms provided. The data will be made available to the treating physicians and practice staff for the purposes of treatment.

To help us ensure the quality of treatment, you voluntarily complete the PROMS and Happy tool masks provided after your visit to the practice. You can use PROMS to share your experience of the success of the treatment and Happy to inform us of your personal satisfaction with the practice. The data is made available to treating doctors and practice staff to improve our service.

The respective data is stored for us on the servers of Patient 21 SE. Further information about Patient21 can be found at https://www.patient21.com.

Duration of storage

The data you enter will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies. Mandatory statutory provisions - in particular retention periods - remain unaffected.

Legal basis for data processing

The legal basis for the processing of appointment and medical history data is Art. 6 para. 1 lit. b GDPR. The collection is an important pre-contractual measure for the treatment contract you have requested.

The legal basis for the processing of data by PROMS, Happy and optional information that is not absolutely necessary for the treatment is Art. 6 para. 1 lit. f GDPR. The practice has a legitimate interest in providing individualized care to patients.

Further information

We have concluded an order processing contract with the above-mentioned provider. This is a contract prescribed by data protection law, which ensures that the provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.

12. GRWAPI

We use GRWAPI to simplify and automate interaction with our web services. GRWAPI enables us to make API requests to external systems and process the data received.

Purpose of data processing

Automation of processes: GRWAPI is used to automate certain tasks, such as retrieving data from external systems or sending notifications.

Improving user-friendliness: By using GRWAPI, we can simplify and speed up certain functions for our users.

Legal basis

The processing of your data by GRWAPI is generally based on our legitimate interest in the efficient handling of our business processes and the improvement of our services (Art. 6 para. 1 lit. f GDPR).

Data protection notice for the use of Jameda Elements

13. Jameda Elements

We use Jameda Elements to optimize our online presence and provide patients with even more comprehensive information about our services. Jameda Elements is a tool that allows us to customize our Jameda profile and use additional functions.

Purpose of data processing

Individual profile presentation: Jameda Elements allows us to customize our Jameda profile to the needs of our patients and, for example, highlight special treatment focuses.

Analysis: The use of Jameda Elements enables us to analyze the use of our profile and thus further optimize our offer.

Type of data processed

Practice data: In addition to the data already stored on Jameda, Jameda Elements can collect further specific information about our services and treatment focuses.

User data: When using Jameda Elements, technical usage data such as your IP address, browser information and the operating system of your device may be collected.

Legal basis

The processing of your data by Jameda Elements is generally based on our legitimate interest in advertising our services and optimizing our online presence (Art. 6 para. 1 lit. f GDPR).

14. Social media presence

1. LinkedIn

By interacting with our LinkedIn presence (e.g. via a campaign), the data you provide will be transmitted by LinkedIn to companies of Patient21 SE as the operator of the LinkedIn presence.

The legal basis for these data transfers may also be Art. 6 para. 1 lit. f GDPR. You can determine which personal data is publicly accessible yourself via the settings of your LinkedIn account under "Data protection". You can check and adjust these settings at https://www.linkedin.com/psettings/privacy.

If you use LinkedIn forms to generate leads (legal basis is consent pursuant to Art. 6 para. 1 lit. a GDPR), personal data (e.g. your name, specified company, your e-mail address or your telephone number) will be stored by LinkedIn and made available to Patient21. The data can then be viewed by the Patient21 GmbH companies in the company-wide CRM software.

Patient21 uses this contact data to provide you with further information about our services and products. The use of the lead forms as part of our LinkedIn presence is carried out in accordance with Art. 6 para. 1 lit. f GDPR. Patient21 has legitimate interests in the processing, which can be seen in section 5.3. You can object to the use of your data from the lead form at any time. The lead data is stored on LinkedIn for 90 days and then deleted. For more information on how LinkedIn uses your data, please refer to LinkedIn's privacy policy at: https://www.linkedin.com/legal/privacy-policy

Patient21 stores your personal data that LinkedIn makes available to us for as long as knowledge of the data is required for the purposes of the business relationship or the purposes for which it was collected, or as long as statutory or contractual retention requirements exist. You can also object to data storage at any time (right to object).

LinkedIn offers the operators of the LinkedIn presence analysis functions. This function allows operators of the LinkedIn presence to analyze a summary of data in the form of page statistics within a tool. Patient21 uses this data to create anonymized statistics (page views, regional distribution, etc.) and to examine the effectiveness of campaigns. It is not possible to draw conclusions about individual users. The LinkedIn analysis function is used in accordance with Art. 6 para. 1 lit. f GDPR. See also the point "Legitimate interest".

Further information on the processing of user data by LinkedIn as the controller can be found at https://www.linkedin.com/legal/privacy-policy.

Further information on how you can assert or implement your data subject rights directly against LinkedIn can be found at: https://www.linkedin.com/help/linkedin/answer/50191?trk=microsites-frontend_legal_privacy-policy.

2. Facebook

We would like to point out that, according to current case law, there is joint responsibility between Facebook (Facebook Ireland Ltd. | 4 Grand Canal Square | Grand Canal Harbour | Dublin 2 Ireland) and the operator of the Facebook fan page ("joint controller"). You can find more information at: www.facebook.com/legal/terms/information_about_page_insights_data. If you have any questions about data processing by Facebook, you can contact Facebook's data protection officer (https://www.facebook.com/help/contact/540977946302970).

By interacting with our Facebook pages (e.g. in the form of messages, comments or "likes"), the data you provide will be transmitted by Facebook to companies of Patient21 GmbH as the operator of the page.

The legal basis for these data transfers is Art. 6 para. 1 lit. f GDPR. You can specify which personal data is publicly accessible in the settings of your Facebook account. To do this, go to the settings of your Facebook account under "Privacy". You can check and adjust these settings at https://www.facebook.com/settings?tab=privacy. You can also control the behavior of the "Like" information there (visibility for other users).

If you use Facebook forms to generate leads (legal basis is consent in accordance with Art. 6 para. 1 lit. a GDPR), personal data (e.g. your name, specified company, your e-mail address or your telephone number) will be stored by Facebook and made available to Patient21. The data can then be viewed by the Patient21 GmbH companies in the company-wide CRM software.

Patient21 uses this contact data to provide you with further information about our services and products. The lead forms on our Facebook fan page are used in accordance with Art. 6 para. 1 lit. f GDPR. Patient21 has legitimate interests in the processing, which can be found under "Legitimate interest". You can object to the use of your data from the lead form at any time. The lead data is stored on Facebook for 90 days and then deleted. For more information on how Facebook uses your data, please refer to the additional information provided by Facebook at: https://www.facebook.com/business/help/1526849577619206?id=735435806665862.

Patient21 stores your personal data that Facebook makes available to us for as long as knowledge of the data is required for the purposes of the business relationship or the purposes for which it was collected, or for as long as statutory or contractual retention requirements exist. You can also object to data storage at any time (right to object).

Facebook offers page operators analysis functions ("Facebook Insights"). These functions allow page operators to analyze a summary of data in the form of page statistics within a tool.

Patient21 uses this data to compile anonymized statistics ("likes", page views, regional distribution of users, reach of posts, etc.) and to examine the effectiveness of fan page posts. The Facebook Insights function is used in accordance with Art. 6 para. 1 lit. f GDPR. See also the point "Legitimate interest".

Facebook is responsible for all processing related to Facebook Insights and the further processing of user data. Further information can be found at: https://www.facebook.com/legal/terms/page_controller_addendum and here: https://www.facebook.com/privacy/explanation.

Further information on how you can assert or implement your data subject rights directly against Facebook can be found at: https://www.facebook.com/privacy/explanation

3. Instagram

By interacting with our Instagram presence (e.g. in the form of messages, comments or "likes"), the data you provide will be transmitted by Instagram to companies of Patient21 GmbH as the operator of the Instagram account.

The legal basis for these data transfers is, among other things, Art. 6 para. 1 lit. f GDPR. You can decide for yourself which personal data is publicly accessible in the settings of your Instagram account under "Privacy and security". You can check and adjust these settings at https://www.instagram.com/accounts/privacy_and_security/

If you use Instagram forms to generate leads (legal basis is consent in accordance with Art. 6 para. 1 lit. a GDPR), personal data (e.g. your name, specified company, your e-mail address or your telephone number) will be stored by Instagram or Facebook and made available to Patient21. The data can then be viewed by the Patient21 GmbH companies in the company-wide CRM software.

Patient21 uses this contact data to provide you with further information about our services and products. The use of the lead forms as part of our Instagram presence is carried out in accordance with Art. 6 para. 1 lit. f GDPR. Patient21 has legitimate interests in the processing, which can be found under "Legitimate interest". You can object to the use of your data from the lead form at any time. The lead data is stored on Instagram/Facebook for 90 days and then deleted. For more information on how Facebook, as the operator of Instagram, uses your data, please refer to the additional information provided by Facebook at: https://www.facebook.com/business/help/563690893827148?id=735435806665862.

Patient21 stores your personal data that Instagram/Facebook makes available to us for as long as knowledge of the data is required for the purposes of the business relationship or the purposes for which it was collected, or for as long as statutory or contractual retention requirements exist. You can also object to data storage at any time (right to object).

Instagram offers fan page operators analysis functions ("Instagram Insights"). These functions allow account owners to analyze a summary of data in the form of page statistics within a tool.

Patient21 uses this data to compile anonymized statistics ("likes", page views, regional distribution of users, reach of posts, etc.) and to examine the effectiveness of its Instagram presence. The Instagram Insights function is used in accordance with Art. 6 para. 1 lit. f GDPR. See also the point "Legitimate interest".

The responsibility for all processing related to Instagram Insights and the further processing of user data lies with Instagram or Facebook (Instagram as a product of Facebook). You can find more information on this at: https://www.facebook.com/help/instagram/155833707900388.

Further information on how you can assert or implement your data subject rights directly against Facebook (as the operator of Instagram) can be found at: https://www.facebook.com/help/instagram/155833707900388.

3. Use of offers, own services

1. Contact form and e-mail contact

Description and scope of data processing

Our website contains our contact details and a contact form that can be used to contact us. It is generally possible to contact us via the e-mail address provided. In this case, the transmitted personal data (name and request) of the user will be stored and processed by us for the purpose of processing your request.

If customers or interested parties use the option of sending messages via the contact form, the data entered in the input mask will be transmitted to us and stored. These data are

• Name
• E-mail address and other contact details
• Website of your practice

The following data is also stored at the time the message is sent:

• The IP address of the user
• Date and time of dispatch

In this context, no data will be passed on to third parties without your consent. The data will be used exclusively for processing the conversation.

Legal basis for data processing

Contacting us by providing an email address is only possible from the age of 16 or with the consent of a parent or guardian. By using this function, you confirm that you are over 16 years of age or that you have the consent of a parent or guardian.

The legal basis for the processing of data transmitted in the course of sending a request is Art. 6 para. 1 lit. a GDPR. The legitimate interest lies in the efficient and fast processing of user inquiries. If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.

Purpose of data processing

The processing of the personal data from the input screen or the data transmitted in any other way serves us to process the establishment of contact, the processing of user inquiries or the processing of appointment requests. In the case of contact by email, this also constitutes the necessary legitimate interest in processing the data.

The other personal data processed during the sending process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.

Duration of storage

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input screen of the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

Possibility of objection and removal

The user has the option to revoke their consent to the processing of personal data at any time. If the user contacts us by email, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued. To withdraw your consent, you can contact our data protection officer at any time using the contact details above.

All personal data stored in the course of contacting us will be deleted in this case.

2. Handling applicant data

Description and scope of data processing

We offer you the opportunity to apply to us (e.g. by e-mail or post). In the following, we inform you about the scope, purpose and use of your personal data collected as part of the application process. We assure you that your data will be collected, processed and used in accordance with applicable data protection law and all other statutory provisions and that your data will be treated in strict confidence.

We use Personio for the processing of applicant data:

Personio SE & Co. KG Seidlstraße 3 80335 Munich, Germany

Legal basis for data processing

The legal basis for data processing is § 26 BDSG n.F. under German law (initiation of an employment relationship), Art. 6 para. 1 lit. b GDPR (general contract initiation) and - if you have given your consent - Art. 6 para. 1 lit. a GDPR. Consent can be revoked at any time. Your personal data will only be passed on within our company to persons who are involved in processing your application.

If the application is successful, the data submitted by you will be stored in our data processing systems on the basis of § 26 BDSG n.F. and Art. 6 para. 1 lit. b GDPR for the purpose of implementing the employment relationship.

Purpose of data processing

If you apply to us electronically, i.e. by e-mail, we will collect and process your personal data for the purpose of handling the application process, deciding on the establishment of an employment relationship and implementing pre-contractual measures.

By submitting an application, you express your interest in taking up employment with us. In this context, you provide us with personal data that we use and store exclusively for the purpose of your job search/application.

In particular, the following data may be collected:

• Name (first name and surname)
• E-mail address
• Phone number
• LinkedIn profile (optional)
• Channel, how you became aware of us
• Matching job requirements with the applicant's skills
• Planned employment
• Communication during the application process
• Status updates and notes on your application

You also have the option of attaching informative documents such as a cover letter, your CV and references. These may contain further personal data such as date of birth, address, etc.

Only authorized employees from the HR department or employees involved in the application process have access to your data.

Personal data is stored exclusively for the purpose of filling the vacant position for which you have applied.

Duration of storage

Your data will be stored for a period of 6 months after the end of the application process. This is usually done to fulfill legal obligations or to defend against any claims arising from legal regulations. We are then obliged to delete or anonymize your data. In this case, the data will only be available to us as so-called metadata without direct personal reference for statistical evaluations (e.g. proportion of women or men in applications, number of applications per period, etc.).

You will not be informed separately about the deletion of your data.

In addition, we reserve the right to store your data for inclusion in our "talent pool" for one year after the end of the application process in order to identify any other interesting positions for you. This also applies, for example, to applications for an apprenticeship or internship. We will provide you with a separate consent form for this purpose, in which you can consent to any further storage of your data and inclusion in our "talent pool". The data will be deleted from the "talent pool" after one year.

You will not be informed separately about the deletion of your data.

If you receive an offer of employment with us during the application process and accept it, we will store the personal data collected during the application process for at least the duration of the employment relationship.

Possibility of objection and removal

If personal data is processed by us as the controller, you as the data subject have certain rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and purpose of the processing. These can be found in the "Rights of the data subject" section of this privacy policy.

If the processing of personal data is based on your consent, you have the right to withdraw this data protection consent in accordance with Art. 7 (3) GDPR. To assert your rights as a data subject with regard to the data processed in this application process, please contact our data protection officer using the contact details above.

4. Rights of the data subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

3. Right to information

You can request confirmation from the controller as to whether personal data concerning you is being processed by us.

If such processing has taken place, you can request the following information from the controller:

(1) the purposes for which the personal data are processed;

(2) the categories of personal data that are processed;

(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;

(4) the planned duration of the storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;

(5) the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;

(6) the existence of a right of appeal to a supervisory authority;

(7) all available information on the origin of the data if the personal data are not collected from the data subject;

(8) the existence of automated decision-making including profiling in accordance with Art. 22 (1) and (4) GDPR and - at least in these cases - meaningful information on the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

4. Right to rectification

You have a right to rectification and/or completion vis-à-vis the controller if the processed personal data concerning you is incorrect or incomplete. The controller must make the correction without delay.

5. Right to restriction of processing

Under the following conditions, you may request the restriction of the processing of your personal data:

(1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;

(2) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;

(3) the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims, or

(4) if you have objected to the processing pursuant to Art. 21 (1) GDPR and it is not yet certain whether the legitimate reasons of the controller outweigh your reasons.

If the processing of personal data concerning you has been restricted, such data may only be processed - apart from being stored - with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

6. Right to erasure

1. Obligation to delete

You have the right to obtain from the controller the erasure of personal data concerning you without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

(1) The personal data concerning you are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

(2) You revoke your consent on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR and there is no other legal basis for the processing.

(3) You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.

(4) The personal data concerning you has been processed unlawfully.

(5) The deletion of personal data concerning you is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.

(6) The personal data concerning you were collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.

2. Information to third parties

If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) GDPR, it shall take reasonable steps, including technical measures, taking into account the available technology and the cost of implementation, to inform controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

3. Exceptions

The right to erasure does not exist if the processing is necessary

(1) to exercise the right to freedom of expression and information;

(2) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(3) for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;

(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or

(5) for the assertion, exercise or defense of legal claims.

7. Right to information

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right to be informed about these recipients by the controller.

8. Right to data portability

You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where

(1) the processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and

(2) the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

9. Right of objection

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions.

The controller will no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Notwithstanding Directive 2002/58/EC, you have the option of exercising your right to object in connection with the use of information society services by means of automated procedures using technical specifications.

10. Right to revoke the declaration of consent under data protection law

You have the right to withdraw your declaration of consent under data protection law at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

11. Automated decision in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

(1) is necessary for the conclusion or performance of a contract between you and the controller,

(2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or

(3) with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g GDPR applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.

In the cases referred to in (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

12. Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.

5. Data security, third-party websites, changes

1. SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

2. Data protection and third-party websites

The website may contain hyperlinks to and from third-party websites. If you follow a hyperlink to one of these websites, please note that we cannot accept any responsibility or guarantee for third-party content or data protection conditions. Please check the applicable data protection conditions before you transmit personal data to these websites.

3. Changes to this privacy policy

We reserve the right to amend these data protection provisions at any time with effect for the future. A current version is always available on the website. Please visit the website regularly and inform yourself about the applicable data protection provisions.