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Privacy policy

Privacy policy


Data Privacy Statement


Any collection, processing and use (hereinafter "use") of data is solely for the purpose of providing our services. Our services have been designed to use as little personal information as possible. For that matter, "personal data" is understood as all individual details about a person or factual circumstances of an identifiable natural person (so-called "affected person"). The following statements on data protection describe what types of data are collected when accessing our website, what happens with these data and how you may object to data usage.


    1. General information on data processing

    2. Use of data on this website and in logfiles

    3. Use of cookies

    4. Contact

    5. Rating via Trustpilot

    6. Data processing for job applications

    7. Information for practitioners

    8. Social media links

    9. Tracking and analytics

    10. Tools for advertisement and marketing

    11. Other tools of third-party providers

    12. Service providers from third countries

    13. Your rights

    14. How you perceive these rights

    15. Subject to change



1.  General information on data processing  


1.1.  Person Responsible (Controller)


Responsible within the meaning of the EU General Data Protection Regulation (GDPR) is:

Homepage:  https://doctena.lu, *.doctena.lu, secure.doctena.com

Doctena SA

Address:    6 Rue Adolphe, 1855 Luxembourg, Luxembourg

Phone:   +352 2040 4130

Fax:    +352 2040 4131 

Email:  privacy-luxembourg@doctena.com 

 

Homepage:  https://doctena.at, *.doctena.at

Doctena Austria

Address:  Mooslackengasse 17, A-1190 Wien, Austria

Phone:  +43 01 8792 327

Email:  privacy-austria@doctena.com

 

Homepage:  https://doctena.be, *.doctena.be (außer afspraken.doctena.be)

Doctena Belgium Sprl

Address:  Square de Meeus 37, B-1000 Brüssel, Belgium

Phone:  +32 2 808 85 92

Fax:   +32 2 808 85 95 

Email:  privacy-belgium@doctena.com

 

Homepage:  https://doctena.ch, *.doctena.ch

Doctena Switzerland GmbH

Address:  Hagenholzstrasse 83b, 8050 Zürich, Switzerland

Phone:  +41 43 508 28 85

Fax:  +41 43 508 68 25

Email:  privacy-switzerland@doctena.com

 

Homepage:  https://doctena.de, *.doctena.de

Doctena Germany GmbH

Address:  Kurfürstendamm 14, 10719 Berlin, Germany

Phone:  +49 (30) 609 84 965

Fax:  +32 2 808 85 95

Email: privacy-germany@doctena.com

 

Homepage:  https://doctena.nl, *.doctena.nl

Doctena Belgium Sprl

Address:  Square de Meeus 37, B-1000 Brüssel, Belgium

Phone:  +32 2 808 85 92

Fax:   +32 2 808 85 95 

Email:  privacy-belgium@doctena.com



1.2.  Name and address of the Data Protection Officer 


The data protection officer is Kemal Webersohn of WS Datenschutz GmbH.

You can contact WS Datenschutz GmbH at the following email address:

privacy@doctena.com

WS Datenschutz GmbH

Dircksenstraße 51 

D-10178 Berlin

https://webersohnundscholtz.de 


1.3Protection of your data


We have taken technical and organizational measures to ensure that the requirements of the EU General Data Protection Regulation (GDPR) are met by us, as well as, by external service providers working for us.

If we work with other companies to provide our services, such as email and server providers, this will only be done after an extensive selection process. In this selection process, each individual service provider is carefully selected for its suitability in terms of technical and organizational data protection skills. This selection procedure will be documented in writing and an agreement on the order processing of data (data processing agreement) will only be concluded if the third party complies with the requirements of Art. 28 GDPR.

Your information will be stored on specially protected servers. Access to it is only possible for a few specially authorized persons. Our website is SSL/TLS encrypted, as can be seen by the https:// at the start of our URL.

You can also find more information on the topic of data protection in our Doctena Privacy Center: https://www.doctena.com/en-de/gdpr


1.4.  Erasure of personal data


We process personal data only if necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.


2.  Use of data on this website and in log files


2.1Scope of processing personal data 


When visiting our website, our web servers temporarily store every access in a log file. The following data is collected and stored until automated erasure:

  • IP-address of the requesting computer
  • Date and time of access
  • Name and URL of the retrieved file
  • Transmitted amount of data
  • Message if the retrieval was successful
  • Detection data of the browser and operating system used

We or our partners may process additional data occasionally. You will find information about this below.



2.2.  Legal basis for processing personal data 


The legal basis for the temporary storage of the data and log files is Art. 6 para. 1 s. 1 lit. f) of the GDPR. Our legitimate interest is to make our website accessible for you.


2.3.   Purpose of data processing

The processing of this data serves: the purpose of enabling the use of the website (connection establishment), system security, the technical administration of the network infrastructure, as well as to optimize the website. The IP address is evaluated only in case of attacks on our network infrastructure or the network infrastructure of our internet provider.

Furthermore, no input of your personal data is required to use our website.


2.4.  Duration of storage

As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out. This happens as soon as you close our website. Our hosting service might use data for statistical purposes. Any personal data will be anonymized for this. Our hosting service Amazon Web Services is based in Frankfurt, Germany. We will automatically delete this data after a period of 15 days. You can find more information about our hosting service provider below.


2.5.   Right of objection and erasure

The data processing is necessary in order to present the website and to ensure the website’s operation. Therefore, objecting is impossible. 


2.6.   Amazon Web Services (AWS)

2.6.1.    Scope of processing personal data

Our website uses the services of the hosting provider AWS. Data processing is carried out by: Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, Luxembourg 1855, Luxembourg (a subsidiary of Amazon.com Inc., 410 Terry Avenue North, Seattle WA 98109, USA).

AWS hosting services are used to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, Email dispatch, security services and technical maintenance services, which we use for the purpose of operating this website. 

To ensure the greatest possible data security, we have chosen the server location in Frankfurt am Main for the service provider AWS.

You can find more information on the data protection of the service provider here: https://aws.amazon.com/de/privacy

2.6.2.    Legal basis for processing personal data

The legal basis for the processing of personal data is Art. 6 para. 1 s.1 lit. f) GDPR. It is in our legitimate interest to provide a secure and stable website. 

2.6.3.    Purpose of data processing

Data processing is carried out for the purpose of enabling the use of the website. It serves the system security, the technical administration of the network infrastructure, as well as the optimization of the website. 

2.6.4.    Duration of storage

Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) and deleted as soon as the purpose of data processing is achieved and no legal retention periods oppose a deletion. As a rule, this is the case after 15 days.

Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. 

2.6.5.    Right of objection and erasure

The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. Consequently, there is no possibility for the user to object.

If you have any questions in this regard, please feel free to contact our data protection office. 


2.7.   Visual Online

2.7.1.    Scope of processing personal data

Our website uses the services of the Internet service provider Visual Online. Data processing is carried out by: Visual Online S.A., Z.I. Weiergewan 6, rue Goell L-5326 Contern, Luxembourg.

We are using Visual Online to provide the following services: Infrastructure services, computing capacity, data storage and database services, security services and technical maintenance services, which we use for the purpose of operating this service.

You can find more information about the privacy policy of the service provider here: https://www.vo.lu/cvp

2.7.2.    Legal basis for processing personal data

The legal basis for the processing of personal data is Art. 6 para. 1 s.1 lit. f) GDPR. It is in our legitimate interest to provide a secure and stable website. 

2.7.3.    Purpose of data processing

Data processing is carried out for the purpose of enabling error-free use of the website even after malfunctions. It thus serves the purpose of system security.

2.7.4.    Duration of storage

Backups are stored for security reasons and are usually deleted after 2 months unless legal, contractual or official regulations prevent deletion. 

2.7.5.    Right of objection and erasure

The collection of data as part of a backup is mandatory for the operation of the website. Consequently, there is no possibility for the user to object.

If you have any questions in this regard, please feel free to contact our data protection officer



2.8.  Open Telekom Cloud


2.8.1.   Description and scope of data processing


We are using the services of the hosting provider Open Telekom Cloud. Data processing is carried out by T-Systems International GmbH, Hahnstraße 43d D-60528 Frankfurt am Main.

The hosting services of Open Telekom Cloud are used to provide the following services: Infrastructure and platform services, computing capacity, data storage and database services, e-mail distribution, security services and technical maintenance services, which we use for the purpose of operating this service.

Further information on the data protection of the service provider can be found here: https://open-telekom-cloud.com/en/data-protection


2.8.2.   Legal basis for data processing


The legal basis for the processing of personal data is Art. 6 para. 1 s.1 lit. f) GDPR. It is our legitimate interest to provide a secure and stable website.


2.8.3.   Purpose of data processing


Data processing is carried out for the purpose of enabling the use of the website. It is used for system security, the technical administration of the network infrastructure, as well as the optimization of the Internet offer.


2.8.4.   Duration of data storage


Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) and is deleted by us as soon as the purpose of the data processing has been achieved and no legal retention periods prevent deletion. As a rule, this is the case after 15 days.

Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.


2.8.5.   Right to objection and erasure


The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

If you have any questions in this regard, please feel free to contact our data protection officer.

3.  Use of cookies


3.1.   Description and scope of data processing 

Our website is using cookies. Cookies are stored on your computer when you use our website. Cookies are small text files which are stored on your hard drive assigned to the browser you use. Through this information flows to us or the party who set the cookie. Cookies cannot run programs on or transmit viruses to your computer. Cookies are used to analyze the use of our website in anonymized or pseudonymized and generally to keep our website functional. The following data may be transmitted:

  • Frequency of website visit
  • Which functions of the website are used by yo
  • Your cookie-settings

Upon entering this website, our cookie manager informs you about the use of cookies on this website and asks for your consent to the use of cookies. Also, you are pointed to the data privacy statement of this website. 

Note on data processing in the USA by Facebook, Google:

By clicking on "Accept all", you consent to your data being processed in the USA in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR. According to the ECJ, the data protection standard in the USA is insufficient and there is a risk that your data will be processed by the US authorities for control and monitoring purposes, possibly also without any legal remedy. If you only consent to the setting of essential cookies, the transfer does not take place. Consent given can be revoked at any time.


3.2.   Legal basis for data processing 

The legal basis for the processing of data by cookies, which do not only serve the functionality of our website, is Art. 6 para. 1 s. 1 lit. a) GDPR.

The legal basis for the processing of data for cookies, which serve only the functionality of this website, is Art. 6 para. 1 s. 1 lit. f) GDPR.


3.3.   Purpose of data processing 

Our legitimate interests are to provide you with a working website connection and to ensure a comfortable use of this website. Also, we need to process your personal data to solve occurring safety and security issues, as well as to ensure system stability.

The data processing takes place to make a statistical evaluation of our website possible.



3.4.   Duration of storage 

This website uses the following types of cookies. The extend and function of each are being explained below:

  • Transient cookies (see a)
  • Persistent cookies (see b)


a) Transient cookies are automatically deleted when you close the browser. This is especially true for session cookies which store your session ID, with which various requests from your browser can be assigned to your session. This will allow your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close the browser.

b) Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie.

You can find more information about the type and storage duration of the individual cookies in the Cookie Manager. You can access it by clicking on the blue fingerprint icon in the bottom left corner of our website.


3.5.   Right to objection and erasure

You have the possibility to revoke your consent to the data processing by means of cookies, which do not only serve the functionality of the website. In addition, we do not set cookies until you have agreed to set cookies when you visit the site. In this way, you can prevent data processing via cookies on our website. You can also delete the cookies in your browser's security settings at any time. Please note that you may not be able to use all the features of this website. The setting of cookies can also be prevented at any time by appropriate settings in your internet browser.


3.6.   CookieFirst 

3.6.1.   Description and scope of data processing

Cookie First serves the practical implementation of the GDPR and other data protection related law regarding the use of cookies on our website and the integration of analytics tools by means of consent. If you give your consent via the cookie banner, the following data will be processed:

  • Your IP address
  • Details of your consent
  • URL of the consent website
  • Date and time of consent
  • Date and time of the last page access

Data processing is performed by: CookieFirst by Digital Data Solutions B.V., Plantage Middenlaan 42a, 1018 DH Amsterdam, The Netherlands.

For more information about the data processing, please visit:https://cookiefirst.com/legal/privacy-policy/

3.6.2.   Legal basis for data processing

The Processing of this data is based on Art. 6 para. 1 s.1 lit. c) GDPR.

3.6.3.  Purpose of data processing

We use the service to comply with our legal obligations and to ensure the legally compliant guarantee of the full function of our website

3.6.4.  Duration of storage 

The data will only be stored as long as it is necessary for the verification, unless legal regulations require a longer storage of the data. On the part of CookieFirst, your consent will be deleted after 12 months.

3.6.5.  Right to objection and erasure

The collection of data for the provision of a cookie banner is mandatory for the operation of the website. If you have any questions in this regard, please feel free to contact our data protection officer.

You can revoke consent given via CookieFirst by deleting the corresponding cookie named "cookiefirst-cookieconsent". 



4.  Contact


4.1.   Description and scope of data processing


Via our website it is possible to contact us via Email or via contact form. This will require different data to answer the request, which will be automatically saved for processing. Your data will not be passed on to third parties, unless you have given your consent. The following data are required to process your request: 

  • Email address
  • First name
  • Last name
  • Request type
  • Phone number

Furthermore, you can enter the following data optionally:

  • Message
  • Country
  • Documents can be attached, too


The following data is collected mandatorily in the contact form for the purpose of arranging a demo appointment or initiating a contract with Practitioners

  • Name
  • Medical specialty
  • Email address
  • Phone number


Furthermore, you can enter the following data optionally:

  • Consent to the mailing of advertising material



4.2.   Legal basis for data processing

The legal basis depends on Art. 6 para. 1 s. 1 lit. b) GDPR.



4.3.   Purpose of data processing

The processing of personal data from the input form is used solely handling the contact request.



4.4.   Duration of storage 

The data will be deleted as soon as the purpose of the data processing has been achieved and no legal or contractual retention periods prevent deletion.



4.5. 
 Right to objection and erasure

The user has the right to withdraw their consent to the processing of personal data at any time. If the user contacts us, they can object to storage of their personal data at any time. In such cases, the conversation cannot be continued. All personal data that has been stored in the course of the contact will be deleted.


4.6.  SMS Postmark 

4.6.1.   Description and scope of data processing

Our system emails, such as confirming your registration or reminding you of an appointment, are being sent by “Postmark“, an email service provider. The personal data is being processed by: AC PM, LLC, 1 North Dearborn St, 5th Floor Chicago, IL 60602, USA.

Postmark processes our and your email address, the email subject and the IP address of our website as so-called message metadata. As Postmark is sending the email it also processes the email body itself. Doctena takes care not to include personal or confidential medical data in the email body.

We trust in the reliability and the IT and data security of Postmark. We have signed a data processing agreement with Wildbit, the company behind Postmark. In this agreement Wildbit commits to protect the data of our users, to process this data according to its regulations and to not share with unauthorized third parties. You can view the privacy policy of Wildbit here: https://wildbit.com/privacy-policy. You can learn more about data protection at Postmark here: https://postmarkapp.com/eu-privacy#summary


4.6.2.  Legal basis for data processing

This data processing is legally based on Art. 6 para. 1 s. 1 lit. f) GDPR. It is our legitimate interest to verify your identity as part of the registration process, to inform you about your booked appointment as well as to give you the opportunity to change it.

Data processing within the scope of the newsletter is based on your consent according to Art. 6 para. 1 s. 1 lit. a) GDPR. 

4.6.3.   Purpose of data processing

We use Postmark as a processor to ensure an efficient management and reliable delivery of our system emails.

4.6.4.   Duration of storage 

Postmark declares to store the personal data described above as message metadata as well as the message itself for 45 days to facilitate troubleshooting processing and delivery issues.

4.6.5.   Right to objection and deletion

The sending of Emails is necessary for our service of appointment bookings and registration. Therefore, objecting is impossible.

You have the option to revoke your consent at any time. To do so, please contact our data protection officer or use the opt-out link in our newsletter. You may also opt out of reminders by email through your preferences, if you are a registered user. 


4.7.  Zendesk Support & Chat 

4.7.1.   Description and scope of data processing

We use the services of Zendesk for support request management and as a live chat on some parts of our website. The data processing is carried out by: Zendesk Inc., 1019 Market Street, San Francisco, CA 94103, USA. 

For this purpose, Zendesk sets cookies that enable the recognition of the website visitor's internet browser, so that individual chat users can be distinguished. The following data is processed:

  • Chat history
  • Ticket information (Request)
  • Name
  • IP address
  • Country
  • Visited pages
  • Duration of the visit to the pages
  • Further personal information, depending on the information provided (e.B. Email address, telephone number)
  • Browser type
  • System language
  • Browser version
  • Device type


The privacy policy of our ticket system provider Zendesk can be found here: https://www.zendesk.de/company/customers-partners/privacy-policy/.


4.7.2.  Legal basis for data processing

The data processing takes place in accordance with Art. 6 para. 1 s. 1 lit. b) GDPR and serves to answer your questions about our service in the context of the (pre-) contractual relationship. 

4.7.3.   Purpose of data processing

The purpose of data processing is to provide users of our website with a direct and fast means of communication. 

The processing of the data entered in the chat window is used solely to answer your questions. 

4.7.4.   Duration of storage 

The data will be deleted as soon as the purpose of the data processing has been achieved and no legal or contractual regulations prevent deletion. For costumers this is usually the case, if their contract with us ends. 

4.7.5.   Right to objection and deletion

You have the possibility to object data processing at any time. For this purpose, please contact our Data Protection Officer. 



5.  Rating via Trustpilot 


5.1.     Description and scope of data processing

Our website uses the services of Trustpilot. The data processing is carried out by: Trustpilot A/S, Pilestraede 58, 5th floor, DK-1112 Copenhagen K, Denmark. 

We use Trustpilot to give registered patients the opportunity to rate their appointment booked through Doctena. After the booked appointment, a patient with a Doctena account has the opportunity to submit a rating with Trustpilot by clicking on a verification link that opens the Trustpilot website with the rating dialog. This link is unique and contains only encrypted data. Trustpilot itself does not receive any information about the patient from Doctena. In order to submit a rating to Trustpilot, the patient must agree to Trustpilot's terms and conditions. The rating can then be displayed on the page of the respective doctor or practitioner.

Trustpilot collects personal data only in the context of its customer account, which allows patients to edit their rating in the future.

For more information about the data processing, please visit:https://legal.trustpilot.com/for-reviewers/end-user-privacy-terms


5.2.    Legal basis of data processing

Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.


5.3.    Purpose of data processing

This data processing allows for an independent quality assessment of the services provided by the practitioner by the patient. This information may be used by your practitioner and Doctena in raw or aggregated form to publicly promote the services provided and serves as guidance to other patients.


5.4.    Duration of storage

Personal data you provide, including your reviews, is kept for as long as you have a Trustpilot account, or as needed to provide you with its services. If you choose to delete your user account, Trustpilot will save a log with the following information: your name, email address and the date of the deletion of your account. Trustpilot will keep the log for three years. In some cases, even if you delete your Trustpilot account, Trustpilot may retain certain information that they are required by law or have compelling legitimate interests to keep. Reasons Trustpilot might retain some data for longer periods of time include (but are not limited to) security, fraud and platform abuse prevention, complying with legal or regulatory requirements, and defending their legitimate business interests.


5.5.    Right to objection and deletion

You have the option to withdraw your consent to data processing at any time, see Art. 7 GDPR. A withdrawal takes effect from the time at which it is expressed. The withdrawal will be effective for the future. For this purpose, please contact our data protection officer.

In addition, you have the option of deleting or editing your reviews yourself via your customer account at Trustpilot.


6.  Data Processing for Job Applications

6.1.  Description and scope of data processing


We offer the opportunity to apply for jobs by contact form, by email at jobs@doctena.com or our application platform https://doctenasa.recruitee.com. For this purpose, personal data is processed and stored for further processing during the respective application process. If the contact form is used, we collect the following data as part of our application form:

  • Email adress
  • First name 
  • Last name
  • Subject
  • Message


Furthermore, you can enter the following data optionally:

  • Phone number
  • Country
  • Documents can be attached, too


6.2.     Legal basis for data processing


Data processing will be based on Art. 88 GDPR.



6.3.     Purpose of data processing


We process your data exclusively for the purpose of carrying out the application process.



6.4.    Duration and storage


In case of successful application and employment, the personal data is stored in accordance with the legal requirements. In case of unsuccessful application, the data will be deleted in accordance with the rules of the local erasure concept.

This does not apply if we are obliged to any legal erasure periods or if you have given consent to store your data for further communication with us (e.g. we have another suitable job in the future). If you have given consent the legal basis for further storage of your data is Art. 6 para. 1 s. 1 lit. c) or lit. a) GDPR.



6.5.   Right to objection and erasure

You can contact us at any time and object to further processing of your data. All personal data of the application process will be deleted in this case.


7.    Informations for Practioners

7.1.    Description and scope of data processing

On our website practioners can give their consent via the contact form to receive informations on our products.

The information will be sent by email, we may also contact you by phone. We won’t transfer the data to third parties.



7.2.    Legal basis for data processing


Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.



7.3.    Purpose of data processing


The information for practioners has the function of informing the affected parties about our services and news about it.



7.4.   Duration of storage


We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.



7.5.   Right to objection and erasure


The consent to receiving the informations can be revoked by you at any time. For this purpose, you can click the integrated link in each email to unsubscribe. It is also possible to inform us about the revocation of the consent in any other way, e.g. via mail or email.



8.  Social media links


We have integrated social media platforms through links into our services, which may result in the social media provider receiving data from you. If you click on the social media link, the website of the respective social media provider is loaded. By loading the website of the respective social media provider via our services, the respective reference data is transmitted to the respective social media provider. The social media provider thereby receives the information that you have visited us. 

Note on data processing to the United States:

If you click on a social media link, data about you may be processed by the respective provider in the United States. According to the European Court of Justice, the data protection standard in the United States is not adequate and there is a risk that your data will be processed by the U.S. authorities for control and monitoring purposes, possibly also without any legal remedy. Provided that you do not click on the links of the social media providers, no data transfer takes place.

Further information on data processing by the social media providers can be found here:


Facebook, Instagram: https://www.facebook.com/policy

LinkedIn: https://www.linkedin.com/legal/privacy-policy

Twitter: https://twitter.com/en/privacy



9.  Tracking and analytics

 

For the continuous improvement of our website we use the following tracking and analytics tools. Below you can find information on which personal data is processed in each case and how you can reach the respective service providers:



9.1.  Facebook Custom Audience / Facebook-Pixel


9.1.1.   Description and data processing


Our website uses Facebook's Custom Audience pixel to measure conversions. Data processing is carried out by: Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Irland (a Subsidiary of Meta, 1 Hacker Way, Menlo Park, CA 94025, USA).

With the help of the Facebook pixel, we can analyze the behaviour of our website’s visitors. As a result, the effectiveness of Facebook advertisements can be evaluated. Facebook receives the following data:

  • Redirect URL
  • Browser information
  • Facebook user ID if the person has a Facebook account

The data is stored and processed by Facebook, a connection to the user profile is possible. Facebook can use the data for its own advertising purposes. This use of data cannot be influenced by us as the site operator.

The data we receive is used for analysing website traffic generated from facebook ad campaigns. We cannot create a personal reference.

The data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, according to the Facebook data usage directive. As a result, Facebook can enable ads to be displayed on Facebook and outside of Facebook. This use of data cannot be influenced by us as the site operator. You can find Facebook’s data privacy policy here: https://www.facebook.com/about/privacy/


9.1.2.   Legal basis of data processing


Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.


9.1.3.   Purpose of data processing


We process your data to continue the optimization of our website and our advertising activities.


9.1.4.   Duration of storage


The data will be deleted as soon as they are no longer needed for our recording purposes.


9.1.5.   Right to objection and erasure


You have the option to revoke your consent to data processing at any time with effect for the future. Please contact our data protection officer for this purpose.

You can deactivate the remarketing feature "Custom Audiences" in the Ads Settings section of Facebook: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen, if you have a Facebook account. If you do not have a Facebook account, you can disable Facebook’s usage-based advertising on the European Interactive Digital Advertising Alliance website: http://www.youronlinechoices.com/de/praferenzmanagement/



9.2.   Google Analytics


9.2.1.   Description and scope of data processing


Our website uses Google Analytics. This is a service for analyzing access to websites of Google Inc. ("Google") and allows us to improve our website.  Data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).

Cookies enable us to analyze your use of our website. The information collected thus are:

  • IP address
  • Access time
  • Access Duration

The information is transmitted to a Google server in the USA and stored there. The evaluation of your activities on our website is transmitted to us in the form of reports. Google may pass on the collected information to third parties, if required by law or if third parties process this data on behalf of Google. The Google tracking codes of our Internet offer use the function "_anonymizeIp ()", thus IP addresses are processed only shortened, in order to exclude a possible direct personal link to you. Under https://www.google.de/intl/de/policies/ as well as under http://www.google.com/analytics/terms/de.html you can find out more about the terms of use and privacy policy of Google Analytics.


9.2.2.  Legal basis of data processing


Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.


9.2.3.  Purpose of data processing


By processing the data, we can analyze how our website is used, so we can improve it for our users.


9.2.4.   Duration of storage


The data will be deleted 26 months after your last website visit.


9.2.5.   Right to objection and erasure


You have the option to revoke your consent to data processing at any time with effect for the future. Please contact our data protection officer for this purpose.

You can also prevent the installation of cookies by Google Analytics in your browser settings or by not giving your consent in the cookie manager. In this case, however, it may happen that you cannot fully use all features of our website. Also, trough browsers extensions e.g. http://tools.google.com/dlpage/gaoptout?hl=de Google Analytics can be disabled and controlled.



9.3.   Google Tag Manager


9.3.1.   Description and scope of data processing


Google Tag Manager is a solution that allows us to manage web site tags through one interface (including Google Analytics and other Google marketing services on our website). The tag manager itself (which implements the tags) does not process users' personal data. Regarding the processing of users' personal data, reference is made to the details of the Google services. Google Tag Manager usage policies can be viewed here: https://www.google.com/intl/de/tagmanager/use-policy.html



9.4.  Hotjar


9.4.1.   Description and scope of data processing


We use Hotjar, an analysis software on www.doctena.com. Data processing is carried out by: Hotjar Ltd. ("Hotjar"), 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta, Europe.

With Hotjar it is possible to measure and analyze the usage behavior (clicks, mouse movements, scroll heights, etc.) on our website. The information generated by the "Tracking Code" and "Cookie" from your visit to our website will be transmitted to the Hotjar servers in Ireland and stored there. The tracking code collects the following information:

  • The IP address of your device (aggregated and stored in an anonymous format)
  • Your Email address, including your first and last name, provided you have made it available through our website
  • Screen size of your device
  • Device type and browser information
  • Geographical viewpoint (only the country)
  • Preferred language to represent our website
  • Referring domain
  • Visited pages
  • Date and time when the website was accessed

Hotjar will use this information to evaluate your usage of our website, to generate reports of use, as well as other services related to the website use and internet evaluation of the website. Hotjar also uses third-party services such as Google Analytics and Optimizely to provide services. These third parties may store information that your browser sends during your visit to the Website, such as cookies or IP requests. For more information on how to store and use Google Analytics and Optimizely data, please refer to their respective privacy policies.

You will find more Information at: https://www.hotjar.com/legal/policies/privacy


9.4.2.   Legal basis of data processing


Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.


9.4.3.   Purpose of data processing


We process your data to continue the optimization of our website. Our goal is to provide a compatible website and to optimize our online services.


9.4.4.   Duration of storage


The cookies that Hotjar uses have a different "lifespan"; some stay up to 365 days, some remain valid only during the current visit.


9.4.5.   Right to objection and erasure


You have the option to revoke your consent to data processing at any time with effect for the future. Please contact our data protection officer for this purpose.

You can prevent the collection of data by Hotjar by clicking on the following link and follow the instructions: https://www.hotjar.com/legal/compliance/opt-out



9.5.   Hubspot


9.5.1.  Description and scope of data processing


We use "HubSpot", a platform for marketing, sales, customer management and customer service for analytical purposes. The data processing is carried out by: HubSpot, Inc, 25 First Street Cambridge, MA 02141, USA.

HubSpot does not use the data and does not share it with third parties. We trust HubSpot's reliability and IT and data security. For more information on data protection at HubSpot, please visit https://legal.hubspot.com/de/terms-of-service.


9.5.2.   Legal basis of data processing


Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.


9.5.3.   Purpose of data processing


We use the service for analysis purposes and to evaluate the use of our website.


9.5.4.   Duration of storage

According to HubSpot, HubSpot stores your personal data only as long as we use your personal data. HubSpot deletes your data when we delete you from our address database or delete our account with HubSpot after a period of 30 days.

9.5.5.   Right to objection and erasure


You have the option to revoke your consent to data processing at any time with effect for the future. Please contact our data protection officer for this purpose.

 


10.  Tools for advertisement and marketing


Tools are also included on our website to ensure that our website is displayed to you during an internet search, as a relevant search result or as an advertisement. Below, the programs used in connection with our website have been broken down for you:



10.1.  Google Ad Manager (former Double Click)


10.1.1.  Description and scope of data processing


We use Google Ad Manager. Data processing for the European Economic Area and for Switzerland is carried out by:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ad Manager uses information of your visits of this and other websites to generate advertisements of products and services that might interest you. For further information on the methods used or what you can do to prevent Google Ad Manager from using this information, please refer to the following link: https://www.google.de/policies/technologies/ads/.


10.1.2.   Legal basis of data processing


Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.


10.1.3.   Purpose of data processing


We use Google Ad Manager to generate advertisements for our website visitors. Our interest is to cooperate with other companies to reach a broader audience.


10.1.4.  Duration of storage


The data will be deleted as soon as they are no longer needed for our recording purposes.


10.1.5.  Right to objection and erasure


The setting of cookies can be prevented by appropriate settings in your Internet browser at any time. The already set cookies can also be deleted in the settings of the Internet browser. We express our concern that preventing cookies from being set may mean that not all features are fully available.



10.2.  Google Ads and Google Conversion Tracking


10.2.1.  Description and scope of data processing


We have integrated the services of Google Ads (formerly Google AdWords) on our website. Google Ads is an internet advertising service. We use Google Ads to gain relevance in the results of Google's search engine. Data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

If the user accesses our website through a Google ad, Google will set a so-called conversion cookie on the user's system. For the explanation of the cookies, please refer to the pass to the cookies. The conversion cookie is used to create and analyze web-use statistics.

The conversion cookie stores the IP address when visiting the website. This data is stored in the USA. It is possible that Google will share this information with third parties.  

For further privacy notices of Google refer to: https://policies.google.com/privacy?hl=en&gl=de


10.2.2.  Legal basis of data processing


Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.


10.2.3.  Purpose of data processing


In particular, we use Google Ads to gain relevance in the results of Google's search engine.These advertisements are carried out to reach a greater audience.


10.2.4.   Duration of storage


30 days after setting the conversion cookie the cookie loses its validity. This means that the user can no longer be identified. Within these 30 days both- us and Google can track which subpages have been accessed.


10.2.5.   Right to objection and erasure


You have the option to revoke your consent to data processing at any time with effect for the future. Please contact our data protection officer for this purpose.

The setting of cookies can be prevented by appropriate settings in the user's Internet browser at any time. The already set cookies can also be deleted in the settings of the Internet browser. We express our concern that preventing cookies from being set may mean that not all features are fully available.

The user may separately object to interest-based personalized advertising by Google. Please refer to the following link: www.google.de/settings/ads



10.3. Google AdSense


10.3.1.  Description and scope of data processing


We use Google AdSense on the website. This is an online service used for promotional purposes. Google AdSense allows the placement of advertisements on third party websites. 

Data processing for the European Economic Area and for Switzerland is carried out by:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google AdSense places a cookie on the affected person. Regarding the clarification of “cookies”, see the passage on cookies above. The information stored by cookie can be recorded, collected and evaluated by Google Inc. or third parties. In addition, Google AdSense also uses so-called "WebBacons" (small invisible graphics) for the collection of information, through the use of which simple actions such as the visitor traffic on the website can be recorded, collected and evaluated.

The information generated by the cookie and / or WebBeacon about your use of this website is transmitted to a Google server in the USA and stored there. Google uses the information to evaluate your web behaviour with respect to the AdSense ads. Google may also transfer this information to third parties if required by law or as far as third parties process this data on behalf of Google. Your IP address will not be associated with other Google data stored by Google.

For more information about Google AdSense, please refer to the following link: https://www.google.de/intl/de/adsense/start/


10.3.2.  Legal basis of data processing


Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.


10.3.3.   Purpose of data processing


The purpose of data processing is to reach a wider audience by using targeted advertisements.


10.3.4.  Duration of storage


The data will be deleted as soon as they are no longer needed for our recording purposes.


10.3.5.  Right to objection and erasure


The user can prevent the storage of cookies on his hard drive and the display of WebBeacons by making the appropriate settings in the browser.

For more information about Google AdSense, please refer to the link below: https://www.google.de/intl/de/adsense/start/


10.4. Google Remarketing


10.4.1.  Description and scope of data processing


We use Google Remarketing. Data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Remarketing works by setting a cookie on the user. This cookie use gives Google the opportunity to recognize the user if they visit a website that also uses Google Remarketing. As a result, Google will be notified of the user's IP address or browsing behaviour.


10.4.2. Legal basis of data processing


Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.


10.4.3.  Purpose of data processing


By using Google Remarketing, we may display advertisements to users that have previously logged into our website. Google Remarketing ultimately enables user-directed personalized advertising.


10.4.4.  Duration of storage


The data will be deleted as soon as they are no longer needed for our recording purposes.


10.4.5.  Right to objection and erasure


You have the option to revoke your consent to data processing at any time with effect for the future. Please contact our data protection officer for this purpose.

The prevention (as well as the erasure) of the cookie setting can be achieved under the appropriate settings in the Internet browser.

The user can object to user-related advertising by Google at any time. For this we refer to: https://adssettings.google.com/authenticated  



10.5.   LinkedIn


10.5.1.  Description and scope of data processing


We have integrated LinkedIn components into its website. LinkedIn can be reached via the button at the bottom right of the website. Date processing is carried out by: LinkedIn Corporation, 1000 W. Maude Ave., Sunnyvale, California 94085, USA.  If an affected person lives outside of the United States or Canada and LinkedIn processes personal data, the responsible person is: LinkedIn Ireland, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

If the user clicks on the LinkedIn button, the website of LinkedIn will be opened. By accessing the LinkedIn website through our website, LinkedIn receives the information that the user has visited the website.The plug-ins used by LinkedIn can be found at: https://developer.linkedin.com/plugins and https://legal.linkedin.com/api-terms-of-use.

If, at the time of visiting our website, the user is logged in through a LinkedIn account at the same time (no matter if it's their own LinkedIn account), LinkedIn will get more information about what pages the user has visited. LinkedIn collects this information, so there is a theoretical possibility to associate that information to the LinkedIn account. For more information about privacy at LinkedIn, we refer to the following LinkedIn data policy: https://www.linkedin.com/legal/privacy-policy.


10.5.2.   Legal basis of data processing


Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.


10.5.3.  Purpose of data processing


We use social media to promote our company. We also want to give you the opportunity to interact with social media through our website.


10.5.4.  Duration of storage


According to LinkedIn, the service deletes all personal information when you delete your account. Plug-in Data can be stored longer. And will only be processed in anonymous or aggregated form.


10.5.5.  Right to objection and erasure


To prevent this form of processing, the user has to log out from LinkedIn and delete all cookies before visiting our website. Other settings and disagreements regarding the use of data for advertising purposes are possible within the LinkedIn profile settings or via the US page or the EU page of LinkedIn. The settings are platform independent, they are adopted for all devices, such as desktop computers or mobile devices.




11. Other tools of third-party providers


We also use third-party providers to help us with the site's appearance and functionality. These are listed below:



11.1. Cloudinary


11.1.1.  Description and scope of data processing


We are using Cloudinary to optimize the delivery and presentation of images on our website. Your IP address will be disclosed to Cloudinary in this process.The personal data is being processed by: Cloudinary Inc., 111 W Evelyn Ave Suite 206, Sunnyvale, California 94086, USA.

For more information about privacy at Cloudinary, we refer to their data policy: https://cloudinary.com/privacy


11.1.2.   Legal basis of data processing


It is our legitimate interest to make our show you pictures on our website in a fast an user friendly way.


11.1.3.  Purpose of data processing


We use Cloudinary to ensure a fast loading time and good presentation of images on our website.


11.1.4.   Duration of storage


As soon as the purpose of the data processing is fulfilled, personal data will be deleted, unless legal or contractual regulations oppose this.


11.1.5.  Right to objection and erasure


You have the right to revoke your consent at any time. For this purpose, please contact our data protection officer or privacy@cloudinary.com.



11.2.   Typeform


11.2.1.  Description and scope of data processing


The Doctena Privacy Center, which you can contact with questions about data protection, is hosted by Typeform. The data processing is carried out by: TYPEFORM SL, c/ Bac de Roda, 163 (local), 08018 Barcelona, Spain.

For this purpose, the following data will be processed:

  • IP address

Optionally, the following data will also be processed:

  • Request
  • Relation to Doctena (patient, practitioner [customer/no customer])
  • Portal concerned
  • Name
  • Email address
  • Message type

We have entered into a data processing agreement (DPA) with Typeform. Typeform is ISO27001 and SOC2 certified. You can view the AV contract and privacy policy provided by Typeform here: https://admin.typeform.com/to/dwk6gt/?typeform-source=www.typeform.com


11.2.2.  Legal basis for data processing


The processing of this data is based on Art. 6 para. 1 p.1 lit. f) GDPR. Our legitimate interest is based on guaranteeing the stability, functionality and security of the Privacy Center through a secure service provider. In addition, we thus fulfill our obligations under the General Data Protection Regulation pursuant to Art. 6 ABs. 1 S. 1 lit. c) GDPR.


11.2.3.  Purpose of data processing


We use the forms hosted by Typeform to provide our users with comprehensive and clear information on their questions regarding data protection.


11.2.4.  Duration of storage


The data will be deleted as soon as the purpose of the data processing has been achieved and no legal or contractual regulations prevent deletion.


11.2.5.  Right to objection and erasure


You have the possibility to object data processing at any time. For this purpose, please contact us.

 


12. Service providers from third countries

In order to be able to provide our services, we use the support of service providers from third party countries (non-EU countries). In order to ensure the protection of your personal data in this case, we conclude processing contracts with each - carefully selected - service provider. All of our processors provide sufficient guarantees to implement appropriate technical and organizational measures. Our third country data processors are either located in a country with an adequate level of data protection (Art. 45 GDPR) or provide appropriate safeguards (Art 46 GDPR).


Adequate level of protection
: The provider comes from a country whose level of data protection has been recognized by the EU Commission. For more information, see: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en


EU standard contract clauses
: Our provider has submitted to the EU standard contractual clauses to ensure secure data transfer. For more information, see: https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:DE:PDF 


Binding Corporate Rules
: Article 47 of the GDPR provides the possibility of ensuring data protection when transferring data to a third country via Binding Corporate Rules. These are examined and approved by the data security authorities within the framework of the consistency mechanism pursuant to Art. 63 GDPR.


Consent:
In addition, a data transfer to a third country without an adequate level of protection will only take place if you have given us your consent in accordance with Art. 49 sec. 1 lit. a) GDPR for this purpose.



13. Your rights


You have the following rights with respect to the personal data concerning you:



13.1. Right to withdraw a given consent (Art. 7 GDPR)


If you have given your consent to the processing of your data, you can withdraw it at any time. This will affect the admissibility of processing your personal data by us for the time after you have withdrawn your consent. To withdraw your consent, contact us personally or in written form.



13.2. Right of access (Art. 15 GDPR)


You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and the following information:

  • the purpose of processing;
  • the categories of personal data concerned;
  • the recipients or the categories of recipient to whom your personal data have been or will be disclosed, in particular recipients in countries outside of the EU or international organisations;
  • where possible, the envisaged period for which your personal data will be stored, or, if not possible, the criteria used to determine that period;
  • all available information on the source of your personal data;
  • the existence of automated decision-making, including profiling, referred to Art. 22 para. 1 and 4 GDPR and, in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.


In the case of such a request, you must provide enough information about your identity to proof that the request concerns your own personal data.



13.3.  Right to rectification and erasure (Art. 16, 17 GDPR)

You have the right to obtain from us without undue delay the rectification and completion of inaccurate personal data concerning yourself.

You may also request the erasure of your personal data if any of the following applies to you:

  • the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed;
  • you withdraw consent on which the processing is based according to Art. 6 para. 1 s.1 lit. a) or Art. 9 para. 2 lit. a) GDPR, and where there is no other legal ground of processing;
  • you object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or the you object to the processing pursuant to Art. 21 para. 2 GDPR;
  • the personal data have been unlawfully processed;
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject;
  • the personal data have been collected in relation to the offer of information society services referred to in Art. 8 para. 1.


Where we made the personal data public and are obliged to erase the personal data pursuant to Art. 17 para. 1 GDPR, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.


These rights shall not apply to the extent that processing is necessary:

  • for exercising the right of freedom of expression and information;
  • for compliance with a legal obligation which requires processing by Union or Member State law to which we are 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;
  • for reasons of public interest in the area of public health in accordance of Art. 9 para. 2 lit. h) and i) as well as Art. 9 para. 3 GDPR;
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, in so far as the right referred to above is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
  • for the establishment, exercise or defence of legal claims.



13.4.  Right to restriction of processing (Art. 18 GDPR)


You shall have the right to obtain from us restriction of processing where one of the following applies:

  • the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
  • the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
  • we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
  • you have objected to processing pursuant to Art. 21 para. 1 GDPR pending the verification whether our legitimate grounds override yours.


Where processing has been restricted under the aforementioned conditions, such personal data shall, except for storage, only be processed with your consent or for the establishment, exercise or defence 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 limitation of the processing is restricted, you will be informed by us before the restriction is lifted.



13.5.  Right to information (Art. 19 GDPR)


If you have asserted us your right to rectification, erasure or restriction of data processing, we will inform all recipients of your personal data to correct, delete or restrict the processing of data, unless this proves impossible or involves disproportionate effort.

You also have the right to know which recipients have received your personal data.



13.6. Right to data portability (Art. 20 GDPR)


You have the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to transmit those data to another controller, where:

  • the processing is based on consent pursuant of Art. 6 para. 1 s.1 lit. a) GDPR or of Art. 9 para. 2 lit. a) GDPR or is based on a contract pursuant of Art. 6 para. 1 s. 1 lit. b) DS-GVO; and
  • the processing is carried out by automated means.


In exercising your right to data portability, you have the right to obtain that personal data transmitted directly from us to another controller, as far as technically feasible. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority that has been delegated to us.



13.7.  Right to object (Art. 21 GDPR)


Where we based the processing of your personal data on a legitimate interest (Art. 6 para. 1 s. 1 lit. f) GDPR), you may object to the processing. The same applies if the data processing is based on Art. 6 para. 1 s. 1 lit. e).

In this case, we ask you to explain the reasons why we should not process your personal data. Based on this we will terminate or adapt the data processing or show you our legitimate reasons why we continue the data processing.



13.8. Right to lodge a complaint with supervisory authority (Art. 77 GDPR)


Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is against the infringes of the GDPR.

The supervisory authority to which the complaint has been submitted shall inform you of the status and results of the complaint, including the possibility of a judicial remedy according to Article 78 GDPR.




14.  How you perceive these rights

To exercise these rights, please contact our Privcy Center: https://www.doctena.com/gdpr

Or our data protection officer:

Kemal Webersohn  from Webersohn & Scholtz GmbH

Via email privacy@doctena.com 

or by mail:

WS Datenschutz GmbH

Dircksenstraße 51

D-10178 Berlin




15.  Subject to change

We reserve the right to change this privacy policy in compliance with legal requirements.

June 2022