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.

The person or company that decides on the purposes and means of the processing of personal data pursuant to Art. 4 No. 8 GDPR is referred to as the controller. A processor, on the other hand, processes the personal data on behalf of the controller and acts under the supervision and only under the instruction of the controller pursuant to Art. 28 GDPR. Depending on the type of data processed, Doctena is a controller or processor within the meaning of the GDPR.

Doctena acts in its capacity as data controller within the meaning of the EU General Data Protection Regulation, in particular for processing of data relating to the registration and management of your user account and data processing for the presentation of the website. Responsible for the data processing is:

Homepage: https://doctena.lu, *.doctena.lu, secure.doctena.com, soa.doctena.com, Mobile App
Doctena SA
Address: 42, Rue de la Vallée, L-2661 Luxembourg
Phone: +352 2040 4130
Fax: +352 2040 4131
Email: [email protected]

Homepage: https://doctena.at, *.doctena.at
Doctena Austria
Address: Simmeringer Hauptstraße 24, A-1110 Vienna, Austria
Phone: +43 01 8792 327
Email: [email protected]

Homepage: https://doctena.be, *.doctena.be, https://doctena.nl, *.doctena.nl
Doctena Belgium Sprl
Homepage: https:// afspraken.doctena.be
Doctena Afspraken BVAddress: Square de Meeus 37, B-1000 Brüssel, Belgium
Phone: +32 2 808 85 92
Fax: +32 2 808 85 95
Email: [email protected], [email protected]

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: [email protected]

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: [email protected]

The data protection officer for all Doctena companies is Kemal Webersohn of WS Datenschutz GmbH.
You can contact WS Datenschutz GmbH at the following email address:
[email protected]

WS Datenschutz GmbH
Dircksenstraße 51
D-10178 Berlin

https://webersohnundscholtz.de

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/gdpr

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.

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.

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.

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.

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.

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

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

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.

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.

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.

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

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 officer.

Our website uses the service CloudAMQP of data processor 84codes. Data processing is carried out by: 84codes AB, Sveavägen 98 2tr, SE-113 50 Stockholm, Sweden.

Storage and forwarding of data and other Processing of 84codes is used to ensure orderly and secure processing of all requests in the backend. We use CloudAMQP to provide, maintain, and improve the Service of our website.

You can find more information about the service provider’s data protection here: https://www.cloudamqp.com/legal/privacy_policy.html https://aws.amazon.com/de/privacy/

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.

Data processing is carried out for the purpose of enabling the use of this website. It facilitates our system security, the technical administration of the network infrastructure, as well as the interconnectivity between the systems used for our website.

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected and no legal or official retention periods prevent deletion.

The collection of data for the provision of the website 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.

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

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.

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

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

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.

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 visits
• Which functions of the website are used by you
• 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 withdrawd at any time.

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.

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.

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.

You have the possibility to withdraw 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.

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/

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

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

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.

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 withdraw consent given via CookieFirst by deleting the corresponding cookie named “cookiefirst-cookieconsent”.

You can book appointments with practitioners on our website. For this, it is necessary that you enter personal data in the booking form. The following data is at least collected for this:
• Name (identification)
• Gender (identification)
• Date of birth (identification)
• Email address (possibility of rescheduling the appointment and enabling practitioner to make inquiries)
• Cell phone number (verification of booking)
• Type of customer relationship (new patient/existing patient)
• Reason for treatment (execution of treatment)
Depending on the reason for treatment and the practitioner’s configurations, the following additional data can be collected:
• Insurance information (in the case of treatments covered by insurance).
• Payment data (for treatments that require payment)
• Consent to additional agreements with the doctor or therapist
• Address (for home visits)
You can optionally enter the following data:
• Message to the practitioner
The data you provide in the booking form will be used exclusively for the booking and execution of your treatment by the practitioner you have chosen and will not be passed on to third parties as a matter of principle.
They are used for the verification of your booking, your identification with the booked practitioner, the successful execution of the booked treatment and the creation and maintenance of your medical record by the practitioner.
During the booking process, you will receive an SMS with a code to the cell phone number you provided to verify your booking, which you must enter into the booking form. You will also receive confirmation of the booking and a reminder of the booked appointment one day before it takes place via SMS and Email.

If the data subject enters mandatory personal data in the booking form, the legal basis of the data processing is based on Art. 6 para. 1 s. 1 lit. b) GDPR. However, if the user also enters personal data in the optional input field, the data processing is based on Art. 6 para. 1 s. 1 lit. a) GDPR.

We process your data solely for the purpose of booking your appointment and to enable appropriate treatment by the practitioner.

The data are deleted by the practitioner as soon as the purpose of storage is no longer required, and no statutory or regulatory retention periods of erasure contradict.

If you wish to change, correct or delete the personal data provided during the booking process, please contact our Doctena DSGVO Data Protection Center at https://www.doctena.com/gdpr.

We use multiple service providers for sending SMS. SMS are being sent as part of the verification of your Mobile Number in the booking process as well as for appointment reminders. The following traffic data may be collected by our service providers in the process:
• Phone number of the person receiving the SMS
• Sending time • Input time
• Delivery status
• as well as the content of the message.
The data processing is carried out by:
• Spryng B.V., Bakkersstraat 23, 1017 CW Amsterdam, The Netherlands – https://www.spryng.de/en/privacy-policy
• LINK Mobility Poland Sp. z o.o., Toszecka 101, 5th floor, 44-100 Gliwice, Poland – https://www.smsapi.com/en/privacy

The data processing is based on Art. 6 para. 1 s. 1 lit. b) GDPR.

The Data processing is carried out in order to verify your mobile phone number as part of the booking process, as well as to remind you of the appointment you have booked.

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.

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

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
• Consent to the mailing of advertising material

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

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

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.

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.

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.

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.

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

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.

The sending of Emails is necessary for our service of appointment bookings and registration. Therefore, objecting is impossible. You have the option to withdraw 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.

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/

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.

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.

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.

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

We offer Stripe as a payment service for patients to pay practitioners before the appointment. With Stripe, you can use payment information stored in your Stripe account to make purchases quickly and securely. To use the payment service through Stripe, prior registration is required. The data processing is carried out by: Stripe Payments Europe Ltd (subsidiary of Stripe Inc., 510 Townsend Street, San Francisco, CA 94103, USA).
Data processing by Stripe is carried out only for bookings that require online payments. The information collected by Stripe includes:
• Payment method
• Payment method information (e.g. credit or debit card number or bank account details)
• Purchase amount
• Date of purchase.
Different payment methods may require the collection of different categories of data. The payment method information Stripe collects depends on the payment method you choose. When you complete a transaction, Stripe may also receive:
• Name
• Email address,
• Billing or shipping address
• and in some cases your transaction history to authenticate you.
On webpages of practitioners who enabled this payment method, Stripe’s secure widget may store cookies in your browser used for fraud prevention. For more information, please see Stripe’s privacy policy: https://stripe.com/en-lu/privacy

Our legal basis is based on Art. 6 para. 1 s. 1 lit. b) GDPR.

The transmission of the data is necessary to prevent any misuse. We inform you that Stripe may transmit the personal data to credit agencies. This is because Stripe reserves the right to check your identity and creditworthiness.

We will only store your data for as long as it is necessary to process your payment and invoice you. If you are a Stripe user, Stripe will retain your personal data for as long as the services are provided to you. The data will then be deleted unless there are regulatory, contractual or legal retention obligations that prevent deletion.

The data processing is mandatory in order to be able to process your payment via Stripe, which is why it cannot be dispensed with if you have chosen this payment method. There is therefore no possibility to opt out.

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 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/forreviewers/end-user-privacy-terms

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

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.

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.

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.

The transmission of the data is necessary to prevent any misuse. We inform you that Stripe may transmit the personal data to credit agencies. This is because Stripe reserves the right to check your identity and creditworthiness.

As a patient you can register a user account on our website. This requires you to submit personal data in the registration form. The following data is at least collected for this:
• First name
• Last name
• Email address
• Password
• Information on whether the person is a medical representative
Once registered the user can optionally specify the following data:
• Gender
• Date of birth
• Mobile phone number
• Address
• Health insurance / Identification number

If the data subject enters mandatory personal data in the registration form, the legal basis of the data processing is based on Art. 6 para. 1 s. 1 lit. b) GDPR. However, if the user also enters personal data in the optional input field, the data processing is based on Art. 6 para. 1 s. 1 lit. a) GDPR.

The processing of personal data is used solely for us to finish your registration and organize your Doctena-account.

The data are deleted as soon as the purpose of storage is no longer required. This is the case if you delete your account and no statutory or regulatory retention periods of erasure contradict.

During and after the registration, the data subject is free to change, correct or delete their personal data.

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

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:

Google Tag Manager is a solution that allows us to manage so-called website tags via an interface (and thus, for example, integrate Google marketing services into our online offer). The Tag Manager serves as a “manager” of the implemented tags. This allows us to centrally manage integrated Google products or other analysis tools on our website. The tags embedded on the website are referred to as sections of code that make it possible to track your activities on our website. By using our website, users download the Google Tag Manager, which automatically results in the user’s IP address being forwarded to Google With regard to the processing of personal data, please refer to the information on Google services. Data processing for the European Economic Area and Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

You can access the usage guidelines of the Google Tag Manager here: https://www.google.com/intl/de/tagmanager/use-policy.html

The legal basis for the processing of personal data is your consent pursuant to Art. 6 para. 1 s. 1 lit. a) GDPR.

Google Tag Manger simplifies the management and organization of the analysis tools used for the website. In order to integrate an analysis tool, JavaScript codes must be integrated into the website. By using Google Tag Manger, it is possible for us to manage these embedded codes from one place.

Since data storage is not carried out directly by Google Tag Manager, but the data is forwarded to the tracking tools, it is necessary to check with the individual embedded tracking tools how long the data is stored.

You have the option at any time to withdraw a given consent to data processing with effect for the future. Please use our consent manager for this purpose.

We use the web analytics service Matomo (formerly PIWIK). The data processing is carried out by: InnoCraft Ltd, 150 Willis St, 6011 Wellington, New Zealand.

Matomo is located in New Zealand, a third country with an adequate level of protection certified by the EU Commission according to Art. 45 para. 3 GDPR, https://eurlex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32013D0065

Matomo places a cookie into your browser. Regarding the clarification of “cookies”, see the passage on cookies above. The following data is stored by this cookie:

• Two bytes of the IP address of the calling system
• The visited website
• The websites from which you came to the called website (referrer)
• The subpages that are called from the called website
• The length of stay on the website
• The frequency of calling the website

The software runs exclusively on servers that are located within the European Union (Frankfurt). Your personal data is only stored there. This data is not passed on to third parties.

The software is set in a way that the IP addresses are not stored completely, but 2 bytes of the IP address are masked (ex.: 192.168.xxx.xxx). In this way, an assignment of the shortened IP address to the calling computer is no longer possible. For more information on Matomo’s privacy policy, please refer to the links below: https://matomo.org/privacy/ and https://matomo.org/privacy-policy/

Legal basis for processing data is your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR.

The web analytics service Matomo is mainly used by us for website optimization and costbenefit analysis. Matomo will furthermore be used to provide an analysis of users’ traffic to the site. It is in our interests to make our website offer clearly structured and user-friendly for you.

We process personal data only for as long as necessary. As soon as the purpose of the data processing has been fulfilled, blocking and deletion takes place in accordance with the standards of the deletion concept here, unless legal, official or contractual regulations prevent deletion.

You have the option to withdraw your consent to data processing at any time. Please use our consent manager for this purpose.
The setting of cookies can also be prevented at any time by making the appropriate settings in your internet browser or our consent manager. The cookies already set can also be deleted for the future in the settings of the Internet browser. For questions regarding data protection to Matomo, you can contact Matomo at the following e-mail address: [email protected]

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:

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 analyse 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

The legal basis is your consent pursuant to Art. 6 para. 1 s. 1 lit. a) GDPR.

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.

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.

You have the option to withdraw your consent to data processing at any time. Please use our consent manager 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

We use Google Remarketing. With the use of Google Remarketing, it is possible for us to display advertisements to you. This is also possible when visiting other websites if you have previously registered on our website. Google Remarketing thus ultimately enables userrelated advertising. 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.

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

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.

The data is deleted as soon as it is no longer required for our recording purposes and no official, legal or contractual regulations prevent deletion.

You have the option to withdraw your consent to data processing at any time with effect for the future. Please use our consent manager 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

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

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

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

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.

You have the option to withdraw your consent to data processing at any time with effect for the future. Please use our consent manager for this purpose. 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.

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

On our website we use the services of Cloudflare to ensure a safe and error-free use of our website. Cloudflare as CDN (“Content Delivery Network”) ensures the security of this website and the optimization of the loading times. For this purpose, Cloudflare generates log data, such as the number of page views. By receiving this data, Cloudflare looks for patterns of attack whose analysis will protect the customer’s website. This analysis is usually done in just a few minutes, so site security policies can be updated instantly. According to our settings, personal data is processed by Cloudflare in data centers within the European Union. We use the Cloudflare Data Localization Suite from Cloudflare for this purpose.

Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107 US.

More information to data privacy by Cloudflare: https://www.cloudflare.com/privacypolicy/?utm_referrer=https://www.google.de/

The data processing is based on Art. 6 para. 1 s. 1 lit. f) GDPR. A legitimate interest on our part lies in ensuring the safe use of our website. Through the implementation of Cloudflare, we are at the same time adhering to the principle of integrity and confidentiality of your data within the meaning of Art. 5 para. 1 lit. f) GDPR.

The purpose of the data agreement is in line with our legitimate interest in the confidentiality and integrity of our data processing and to ensure the availability and the full functioning of our website.

According to own data the erasure of the raw data usually takes place after four hours and at the latest after three days, as far as no legal regulations preclude a deletion.

The website can only be displayed, if the described data is processed. If you object to the further processing of the data, please contact our data protection officer.

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

The legal basis is Art. 6 para. 1 s. 1 lit. f) GDPR. It is our legitimate interest to make our show you pictures on our website in a fast an user friendly way.

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

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

The website can only be displayed if the described data is processed. If you object to the further processing of your data, please contact our data protection officer. For questions about Cloudinary’s privacy practices, please contact: [email protected].

We use the Datadog to monitor our application infrastructure and security. The data processing is performed by: Datadog, Inc, 620 8th Ave, 45th Fl, New York, NY 10018 USA. The following data is processed during this data processing: Your IP address, as well as the date and time of access and page you accessed. This data is only processed by Datadog in the event of abnormal behavior detection on our servers. For more information about the data processing, please visit https://www.datadoghq.com/legal/privacy

The use is based on our legitimate interest according to Art. 6 para. 1 s. 1 lit. f) GDPR. Our legitimate interest is to ensure the security of this infrastructure and thus of this website by monitoring the application infrastructure.

The purpose of this data processing is to ensure the security of this website.

The data will be deleted after two weeks if no legal or contractual regulations prevent deletion.

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

We use Google reCAPTCHA to protect us from excessive spam. This program is designed to ensure that the inquirer is a human and not an automated program. 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 automatically records the IP address, the access location and the time of access. In addition, the behavior of the website visitor is analyzed on the basis of various characteristics (e.g. time spent by the visitor on the website, mouse movements made, cookies stored in the browser history). This analysis by Google begins automatically as soon as you call up a page that uses Google reCAPTCHA, if you have previously consented to the use of Google reCAPTCHA. Further information on the handling of personal data can be found in the Google privacy policy https://www.google.de/intl/de/policies/privacy , at https://policies.google.com/technologies/partner-sites and at https://www.google.com/recaptcha.

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

Through Google reCAPTCHA, we ensure that there are natural persons with potential interest behind the requests. By limiting the number of inquiries in this way, we can respond to individual requests more quickly and more efficiently, and at the same time secure our website against automatically distributed malware.

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.

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. Please use our consent manager for this purpose.

This website uses the Maps product of MapBox Inc. Data processing for the European Economic Area and for Switzerland is performed by: MapBox Inc, 740 15th St Nw Suite 500 Washington, DC 20005, USA. We use MapBox to provide a location-based search for a practitioner and to display the location of a practitioner on a map. When used, your browser loads the required geoinformation into your browser cache in order to display the available apartments on a map. For this purpose, the browser you use must connect to MapBox’s servers. Through this, MapBox obtains knowledge that our website was accessed via your IP address and which map is displayed. The privacy policy of MapBox can be found at https://www.mapbox.com/legal/privacy

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

Using MapBox makes it easier for you to find a doctor or practitioner near you, as well as interact with the location in various ways, such as route planning.

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. Usually this is the case after 7 days.

You have the right to withdraw your consent at any time. Please use our consent manager for this purpose.

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

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.

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

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.

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

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/adequacyprotection-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://eurlex.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.

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

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.

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.

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.

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.

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.

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.

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.

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.

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

Or our data protection officer:
Kemal Webersohn from Webersohn & Scholtz GmbH
Via email [email protected]
or by mail:
WS Datenschutz GmbH
Dircksenstraße 51
D-10178 Berlin

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

February 2023