INTRODUCTION AND CONCEPTS
1. Introduction: With the operation of our website www.healthcare-germela-wuelfing.com (hereinafter referred to as "website") we process personal data. We treat this data confidentially and process it in accordance with the applicable laws - in particular the Basic Data Protection Ordinance (DSGVO) and the Federal Data Protection Act (BDSG-neu). With our data protection regulations we want to inform you which personal data we collect from you, for which purposes and on which legal basis we use them and, if applicable, to whom we disclose them. In addition, we will explain to you which rights you have to safeguard and enforce your data protection.
2. Terms: Our data protection provisions contain technical terms which are new to the DSGVO and the BDSG.
2.1 Personal data: "Personal data" is all information relating to an identified or identifiable person (Art. 4 No. 1 DSGVO). Information of an identified person can be e.g. the name or the e-mail address. However, personal data also includes data in which the identity is not immediately apparent but can be determined by combining one's own or third-party information and thus finding out who it is. A person can be identified e.g. by providing his address or bank details, his date of birth or user name, his IP addresses and/or location data. Relevant here is all information that in any way allows conclusions to be drawn about a person.
2.2 Processing Art: 4 No. 2 DSGVO defines "processing" as any process in connection with personal data. This applies in particular to the collection, recording, organisation, arrangement, storage, adaptation or alteration, retrieval, consultation, use, disclosure, transmission, dissemination or any other form of provision, comparison or linking, limitation, deletion or destruction of personal data. Responsible company and data protection officer
3. Responsible: The person responsible for data processing is:
Company: Germela Wülfing LLP ("we")
Legal representative: Dr. Thomas Wülfing
Address: Hohe Bleichen 21, 20354 Hamburg
Phone: +49 40 2848404-00
Fax: +49 40 2848404-99
4. Data Protection Officer: We have appointed an external data protection officer for our company.
You can reach him at:
Name: Arne Platzbecker
Anschrift: HABEWI GmbH & Co. KG, Palmaille 96, 22767 Hamburg
Phone: 040/ 18189800Fax: 040/ 181898099
5. Processing frame: Within the framework of the website with the URL www.germela-wuelfing.com, we process the personal data of you listed in detail below under numbers 6-13. We only process data from you which you actively enter on our website (e.g. by filling out forms) or which you automatically make available when using our services. Your data is processed exclusively by us and is not sold, lent or passed on to third parties. If we use the help of external service providers to process your personal data, this is done within the framework of a so-called order processing in which we as the customer are authorised to give instructions to our contractors. For the operation of our website, we use external service providers for hosting as well as for maintenance, care and further development. Should further external service providers be used for any of the processing operations listed in Sections 6-13, they will be named there. Data transfer to third countries does not take place and is not planned. We will inform you about exceptions to this principle in the processing operations described below.
THE PROCESSINGS IN INDIVIDUAL
6. Provision of the website and server log files
6.1 Description of processing Each time you access the website, we automatically collect information that your browser sends to our server. This information is also stored in the so-called log files of our system. This includes the following data:-your IP address-your browser software used by you, as well as its version and language-your operating system-your website from which you accessed our website (so-called referrer)-your subpages accessed by you on our website- the date and time of your access to our website-your Internet service provider- the amount of data transferred- the country and place from which you visited our website- your length of stay on our website-your IP address is recorded in the log files only shortened by the last three digits.
6.2 PurposeThe processing is done to enable you to access the Website and to ensure its stability and security. In addition, the processing serves the statistical evaluation and improvement of our online offer.
6.3 Legal basisThe processing is necessary to protect the predominant legitimate interests of the responsible person (Art. 6 Para. 1 lit. f DSGVO). Our legitimate interest lies in the purpose stated in Section 184.108.40.206
Storage period: The data are deleted as soon as they are no longer required for the purpose of their collection. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. The log files will be deleted after 30 days.
7. Contact by e-mail
7.1 Description of processing You can contact us at the e-mail addresses given on the website. In this case, the personal data transmitted with the e-mail will be processed by us.
7.2 PurposeThe data transmitted with and in your e-mail will be used exclusively for the purpose of processing and answering your request.
7.3 Legal basisThe processing is necessary to safeguard the predominant legitimate interests of the responsible person (Art. 6 Para. 1 lit. f DSGVO). Our legitimate interest lies in the purpose stated in Section 7.2. If the purpose of the e-mail contact is to conclude or fulfil a contract, data processing is carried out to fulfil the contract (Art. 6 para. 1 lit. b DSGVO).
7.4 Storage periodThe data is deleted by us as soon as it is no longer required for the purpose of collection. This is usually the case when the respective communication with you has ended. Communication is terminated when it can be inferred from the circumstances that your request has been conclusively clarified. If statutory retention periods prevent deletion, deletion will take place immediately after expiry of the statutory retention period.
8.1 Description of processingWe send a newsletter at irregular intervals. With the newsletter we inform you about our activities. You will only receive our newsletter if you actively subscribe to our mailing list. You can subscribe to it by filling in and sending a newsletter registration form on our website or in the lists for lectures. To subscribe to the newsletter, all you need to do is enter your e-mail address. All other details (e.g. your first name and surname) are voluntary and are used solely for personalising the e-mails. For the implementation and verification of newsletter subscriptions, we use the so-called double opt-in procedure. A registration takes place in several steps. First, you register on our website for the newsletter. You will then receive an e-mail from us at the e-mail address you provided. With this e-mail we will ask you to confirm that you have actually subscribed to the newsletter and wish to receive it. You can confirm by clicking on a confirmation link in the e-mail. Only after successful confirmation will we include you in our newsletter distribution list and send you e-mails in the future. As part of the double opt-in procedure, we store the date, time and your IP addresses both during registration and confirmation. If you are our client and enter your e-mail address here, this can subsequently be used by us to send a so-called existing customer newsletter. In such a case, only direct advertising for our own similar goods or services will be sent via the newsletter.
8.2 PurposeThe processing takes place in order to offer the newsletter function and to be able to send newsletter e-mails to subscribers and existing customers. The collection and storage of date, time and IP addresses during newsletter registration serves to document the consent given and to protect against the misuse of e-mail addresses.
8.3 Legal basisThe processing of our subscriber newsletter is based on consent pursuant to Art. 6 para. 1 lit. a DSGVO. Your consent is voluntary. The collection and storage of date, time and IP addresses when subscribing to the newsletter is necessary to safeguard the overriding legitimate interests of the person responsible (Art. 6 para. 1 lit. f DSGVO). Our legitimate interest lies in the purpose stated in Section 8.2. The processing of our existing customer newsletter takes place on the basis of Art. 6 Para. 1 lit. f DSGVO to safeguard the overriding interests of the responsible person. Our legitimate interest lies in direct advertising to existing customers. This is permissible within the framework of § 7 para. 3 UWG (German Unfair Competition Act), which we observe.
8.4 Storage period and revocation of consent If you do not confirm your subscription to our newsletter within 24 hours of receiving the corresponding registration e-mail, your data will be deleted automatically. We process your personal data for the duration of your newsletter subscription. You can cancel your subscription to our newsletter at any time by withdrawing your consent. A simple declaration (by e-mail to firstname.lastname@example.org, by post to Germela Wülfing LLP, Hohe Bleichen 21, 20354 Hamburg or by fax to +49 40 2848404-99) is sufficient. You can also unsubscribe from the newsletter by clicking the unsubscribe link in any newsletter e-mail. If you withdraw your consent, you will no longer receive any newsletters and your personal data will be removed from our active mailing list. In order to enforce your revocation, we will include your e-mail address in our so-called black list to a limited extent. This enables us to ensure that you will not receive any newsletters from us in the future and that your e-mail address will not be misused by third parties.
8.5 Recipients and transmission in third countriesWe use the services of the newsletter provider Netinventor to administer our newsletter distribution list and to send e-mails. This takes place within the framework of order processing. Netinventor is an offer of Net Inventors GmbH Stahltwiete 23, 22761 Hamburg.
9.1 Description of processing
9.3 Legal basis
Processing is necessary to safeguard the overriding legitimate interests of the data controller (Art. 6 para. 1 lit. f DSGVO). Our legitimate interest lies in the purpose specified in Section 2.
9.4 Storage period
Below we have compiled the links for you which will lead you to instructions on how you can change the settings in the current browsers. Further information can be found in the support menu of your browser:
Internet Explorer: windows.microsoft.com/de-DE/windows-vista/Block-or-allow-cookies
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, individual functions of our website cannot be used or can only be used to a limited extent.
10. social networks
Our website does not use social media plugins. The logos of the social networks Facebook, Twitter and InkedIn displayed on our website are only linked to the corresponding profiles of our company. If you click on one of the logos, you will be redirected to the external website of the respective social network.
11 Google Web Fonts
11.1 Description of processing
Our website uses "Google Webfonts", a font replacement service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as "Google"). With Google Web Fonts, the standard fonts of your end device are replaced by fonts from the Google catalogue when our website is displayed. If your browser prevents the integration of Google Web Fonts, the text of our website will be displayed in the standard fonts of your terminal device. The Google fonts are loaded directly from a Google server. In order for this to happen, your browser sends a request to a Google server. This may also mean that your IP address is transmitted to Google in connection with the address of our website. However, Google Webfonts does not store any cookies on your end device. According to Google, data processed within the framework of the Google Webfonts service is transferred to resource-specific domains such as fonts.googleapis.com or fonts.gstatic.com. They are not associated with data that may be associated with the use of other Google services such as the search engine of the same name or Gmail. Further information on data protection at Google Webfonts can be found at developers.google.com/fonts/faq. General information on data protection at Google can be found at www.google.com/intl/de-DE/policies/privacy/.
11.2 PurposeThe processing is carried out in order to be able to display the text of our website in a more legible and aesthetically pleasing manner.
11.3 Legal basisThe processing is necessary to safeguard the overriding legitimate interests of the person responsible (Art. 6 Para. 1 lit. f DSGVO). Our legitimate interest lies in the purpose set out in Clause 11.2.
11.4 Recipients and transfer to third countriesBy using Google web fonts, personal data may be transferred to Google. Google also processes your personal data in the USA and has submitted to the EU-US Privacy Shield. Further information on the EU-US Privacy Shield can be found at www.privacyshield.gov/EU-US-Framework.
12. Google Maps
12.1 Description of processing Our website uses "Google Maps", a map display service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as "Google"). We use Google Maps by including a map with our business address on our website. The map is loaded directly from a Google server. In order for this to happen, your browser sends a request to a Google server. This may also mean that your IP address is transmitted to Google in connection with the address of our website. However, Google Maps does not store any cookies on your end device. If you are logged in to Google when visiting our website, Google Maps assigns this information to your Google user account. Google stores your data as user profiles and uses them for advertising purposes, market research and/or to design the Google web pages according to your needs. You have the right to object to the creation of these user profiles, for the exercise of which you must contact Google directly. Further information on data protection at Google can be found at www.google.com/intl/de-DE/policies/privacy/.
12.2 PurposeThe processing is carried out in order to be able to display an interactive map on our website.
12.3 Legal basisThe processing is necessary to safeguard the predominant legitimate interests of the person responsible (Art. 6 Para. 1 lit. f DSGVO). Our legitimate interest lies in the purpose stated in Section 12.2.
12.4 Recipient and transfer to third countriesGoogle also processes your personal data in the USA and has submitted to the EU-US Privacy Shield. Further information on the EU-US Privacy Shield can be found at www.privacyshield.gov/EU-US-Framework.
13 Content Delivery Networks (CDN)
13.3 Legal basisThe processing is necessary to safeguard the predominant legitimate interests of the responsible person (Art. 6 para. 1 lit. f DSGVO). Our legitimate interest lies in the purpose stated in Section 13.2.
13.4 Recipient and transfer to third countries.
14. Data Subject's RightsWith respect to the data processing described above by our company, you have the following data subject's rights:
14.1 Information (Art. 15 DSGVO)You have the right to request confirmation from us as to whether we process personal data concerning you. If this is the case, you have the right, under the conditions set out in Art. 15 DSGVO, to have access to this personal data and to the further information listed in Art. 15 DSGVO.
14.2 Correction (Art. 16 DSGVO)You have the right to demand from us immediately the correction of incorrect personal data concerning you and, if necessary, the completion of incomplete personal data.
14.3 Deletion (Art. 17 DSGVO)You have the right to demand that we delete your personal data immediately if one of the reasons listed in Art. 17 DSGVO applies, e.g. if your data is no longer required for the purposes we pursue.
14.4 Limitation of data processing (Art. 18 DSGVO)You have the right to demand that we restrict data processing if one of the conditions set out in Art. 18 DSGVO is met, e.g. if you dispute the accuracy of your personal data, data processing will be restricted for the duration enabling us to verify the accuracy of your data.
14.5 Data transferability (Art. 20 DSGVO)You have the right, subject to the conditions set out in Art. 20 DSGVO, to request the disclosure of the data concerning you in a structured, common and machine-readable format.
14.6 Revocation of consents (Art. 7 para. 3 DSGVO)You have the right to revoke your consent at any time in the case of processing based on consent. The revocation applies from the time of its assertion. In other words, it is effective for the future. The processing does not therefore become retroactively illegal through the revocation of your consent.
14.7 Complaint (Art. 77 DSGVO)If you are of the opinion that the processing of your personal data violates the DSGVO, you have the right to complain to a supervisory authority. You may exercise this right with a supervisory authority in the EU Member State of your place of residence, place of work or place of presumed infringement.
14.8 Prohibition of automated decisions/profiling (Art. 22 DSGVO)Decisions that have legal consequences for you or significantly affect you may not be based exclusively on automated processing of personal data, including profiling. We inform you that we do not use automated decision making, including profiling, with regard to your personal data.
14.9 Opposition (Art. 21 DSGVO)If we process your personal data on the basis of Art. 6 para. 1 lit. f DSGVO (to safeguard overriding legitimate interests), you have the right to object under the conditions set out in Art. 21 DSGVO. However, this only applies if there are reasons arising from your particular situation. Following an objection, we will no longer process your personal data unless we can prove compelling grounds for processing worthy of protection which outweigh your interests, rights and freedoms. Nor do we have to stop processing if it serves the assertion, exercise or defence of legal claims. In any case - even regardless of a particular situation - you have the right to object at any time to the processing of your personal data for direct marketing purposes.
Status: May 2018