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Data protection:
I am based in Germany. Here I state an English version of my privacy policy.
I work with ethic and confidentiality. I will not share your data (Name, personal record, address, email...) with anyone without your explicit consent, except when I am legally required to do so. Please keep in mind that the information you share on the Internet can be vulnerable to security gaps.
This service of online counselling, although performed by a Psychologist, is NOT a Psychotherapy.
This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and contents connected with it as well as external online presences, such as our Social Media Profile (hereinafter referred to as “online offer”). With regard to the terms used, e.g. “processing” or “responsible person”,we refer to the definitions in Art. 4 of the Basic Data Protection Regulation (GDPR).
Types of data processed:
– Contact data(e.g., e-mail, telephone numbers).
– Content data(e.g., text entries, photographs, videos).
– Inventory data(e.g., names, addresses).
– Usage data(e.g., web pages visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Purpose of processing:
– Answering of contact requests and communication with users.
– Provision of the online offer, its functions and contents.
– Range measurement/Marketing.
– Security measures.
Used terms:
“Personal data” shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); ani dentifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
“Processing” means any operation or set of operations which are performed up on personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data cannot be related to a specific data subject without the inclusion of supplementary information, provided that this supplementary information is kept separate and is subject to technical and organisational measures ensuring that the personal data is not related to an identified or identifiable natural person.
“Profiling” shall mean any automated processing of personal data consisting in using such personal data to evaluate certain personal aspects relating to a natural person, in particular with a view to analysingor predicting aspects relating to the performance of work, the economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person.
“Controller” shall mean the natural or legal person, public authority, agency or any 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.
Relevant legal basis:
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the purpose of fulfilling our services and implementing contractual measures and answering enquiries is Art. 6 Para. 1 lit. b GDPR, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 Para. 1 lit. c GDPR, and the legal basis for processing for the purpose of safeguarding our legitimate interests is Art. 6 Para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 paragraph 1 letter d GDPR serves as the legal basis.
Security measures:
In accordance with Art. 32 GDPR and taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection commensurate with the risk; these measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling the physical access to the data as well as the access, input, transmission, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted, and we respond to any threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by designing technology and by using data protection-friendly default settings (Art. 25 GDPR).
Cooperation with contract processors and third parties:
If, in the course of our processing, we disclose data to other persons and companies(processors or third parties), transfer it to them or otherwise grant them access to the data, this is only done on the basis of a legal authorisation (e.g. if the data must be transferred to third parties, such as payment service providers, in accordance with Art. 6 Para. 1letter b GDPR for the fulfilment of the contract), if you have given your consent, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, 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 GDPR.
Transfers to third countries:
If we process dat ain a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer the data in a third country if the special requirements of Art. 44 ff. GDPR. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognisedspecial contractual obligations (so-called “standard contractual clauses”).
Rights of data subjects:
You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information about this data and to receive further information and a copy of the data in accordance with Art. 15 GDPR.
In accordance with Art. 16 DPA, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with Art. 18GDPR, to demand that the processing of the data be restricted.
You have the right to demand that the data concerning you which you have made available to us be received in accordance with Art. 20 GDPR and to demand that it be passed on to other responsible parties.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.
Right of withdrawal:
You have the right to revoke consents granted in accordance with Art. 7 Para. 3 GDPR with effect for the future.
Right of objection:
You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection may, in particular, be made against processing for the purposes of direct advertising.
Cookies and right of objection for direct advertising:
“Cookies” are small files that are stored on the user’s computer. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”,are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online shop or a login status can be stored. Cookies are described as “permanent” or “persistent” if they remain stored even after the browser is closed. For example, the login status can be saved if users visit the site after several days. Likewise, the interests of the users can be stored in such a cookie, which are used for range measurement or marketing purposes.“Third-party cookies” are cookies that are offered by providers other than the person responsible for the online offer (otherwise, if it is only their cookies, they are called “first-party cookies”).
We may use temporary and permanent cookies and provide information about this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved 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 or restricted in their processing in accordance with articles 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage obligations. 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 is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
According to legal requirements in Germany, the storage is in particular for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 nos. 1 and 4, para.4 HGB (books, records, management reports, accounting vouchers, trading books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 nos. 2 and 3, para. 4 HGB (commercial letters).
Business-related processing:
Additionally, we process
– Contract data (e.g., subject matter of the contract, duration, customer category)
– Payment data (e.g., bank details, payment history) from our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Hosting:
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services as well as technical maintenance services that we use for the purpose of operating this online offer.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors of this online offer onthe basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of contract processing agreement).
Collection of access data and log files:
We, or our hosting provider, on the basis of our legitimate interests as defined in Art.6 Par. 1 lit. f. GDPR process data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited site), IP address and the requesting provider.
For security reasons(e.g. to clarify misuse or fraud), log file information is stored fora maximum of 7 days and then deleted. Data whose further storage is required for evidence purposes are excluded from deletion until the respective incident has been finally clarified.
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 letter b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed in this context, the nature, scope and purpose of such processing and the necessity of processing it, shall be determined by the underlying contractual relationship. The processed data basically includes the stock and master data of the clients (e.g. name, address, etc.), as well as contact data (e.g. e-mail address, telephone number, etc.), contract data (e.g. services used, fees, names of contact persons, etc.) and payment data (e.g. bank details, payment history, etc.).
Within the scope of our services, we may also process special categories of data in accordance with Art. 9 Para. 1 GDPR, in particular information on the health of clients, if necessary with reference to their sexual life or sexual orientation, ethnic origin or religious or ideological convictions. For this purpose, we obtain, if necessary, in accordance with Art. 6 para. 1 lit. a., Art. 7, Art. 9 para. 2 lit. a. GDPR, and otherwise process the special categories of data for the purposes of health care on the basis of Art. 9 para. 2 lit. h. GDPR, Art. 22Para. 1 No. 1 b. BDSG.
As far as it is necessary for the fulfilment of the contract or legally required, we disclose or transfer the clients’ data within the scope of communication with other professionals, third parties involved in the fulfilment of the contract as necessary or typically, such as billing offices or comparable service providers, if this is necessary for the provision of our services according to Art. 6 para. 1 lit b. GDPR, legally according to Art. 6 Para. 1 lit. c. GDPR, our interests or those of our clients in efficient and cost-effective health care as a legitimate interest in accordance with Art. 6 para. 1 lit. f. GDPR or is necessary according to Art. 6 para. 1 lit. d. GDPR to protect the vital interests of clients or another natural person or within the framework of consent according to Art. 6 para. 1 lit. a., Art. 7GDPR.
The data is deleted when the data is no longer required to fulfil contractual or statutory duties of care and to deal with any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years; otherwise the statutory retention obligations apply.
Administration, financial accounting, office organisation, contact management:
We process data within the framework of administrative tasks as well as the organisation of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process within the scope of providing ourcontractual services. The basis for processing is Art. 6 Par. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing.
The purpose of and our interest in processing lies in the administration, financial accounting, office organisation, archiving of data, i.e. tasks that serve to maintain our business activities, perform our duties and provide our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.
We disclose or transfer data to the tax authorities, consultants such as tax advisors or auditors, as well as other fee agencies and payment service providers.
Furthermore, we store information on suppliers, event organisers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We store these mostly company-related data permanently.
Business management analyses and market research:
In order to run our business economically, to identify market trends, customer and user wishes, we analyse the data available to us on business transactions, contracts, inquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR, whereby the persons concerned include customers, interested parties, business partners, visitors and users of the online offer.
The analyses are carried out for the purpose of business management evaluations, marketing and market research. In doing so, we can take into account the profiles of the registered users with details, e.g. on their purchase transactions. The analyses serve us to increase user-friendliness, to optimise our offer and for business management purposes. The analyses serve only us and are not disclosed externally, unless they are anonymous analyses with summarised values.
If these analyses or profiles are personal, they will be deleted or made anonymous when the user terminates the contract, otherwise after two years from conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.
Contact:
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user’s details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6 Para. 1lit. b) GDPR. The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable enquiry organisation.
We delete the enquiries if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
Online presence in social media:
We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Unless otherwise stated in our data protection declaration, we process the data of users if they communicate with us within the social networks and platforms, e.g. contribute to our online presence or send us messages.