Privacy Policy
This privacy policy informs you about the nature, scope, and purpose of processing personal data (hereinafter briefly referred to as “data”) within our online offering and its associated websites, functions, and content, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”). Regarding the terminology used, such as “processing” or “controller,” we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Controller
Dierksmeier & Sharma
Neustadtring 30a
38114 Braunschweig
Phone: (0531) 50 21 00
Email: info@praxis-neustadtring.de
Types of Data Processed
Master data (e.g., names, addresses).
Contact data (e.g., email, phone numbers).
Content data (e.g., text input, photographs, videos).
Usage data (e.g., visited websites, interest in content, access times).
Meta/communication data (e.g., device information, IP addresses).
Categories of Data Subjects
Visitors and users of the online offering (hereinafter, we collectively refer to the data subjects as “users”).
Purpose of Processing
Provision of the online offering, its functions, and content.
Responding to contact inquiries and communicating with users.
Security measures.
Reach measurement/marketing
Terminology Used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data.
“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant Legal Bases
In accordance with Art. 13 GDPR, we inform you about the legal bases of our data processing. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and the implementation of contractual measures as well as responding to inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing for compliance with our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing for the protection of our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
Security Measures
In accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the varying likelihood and severity of the risk for the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access, input, disclosure, ensuring availability, and their separation. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, deletion of data, and response to data endangerment. We also consider the protection of personal data already during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default (Art. 25 GDPR). Cooperation with Processors and Third Parties If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them, or otherwise grant them access to the data, this is only done on the basis of a legal permission (e.g., if a transmission of data to third parties, such as payment service providers, is necessary for the performance of the contract in accordance with Art. 6 para. 1 lit. b GDPR), you have consented, a legal obligation provides for this, or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.). If we commission third parties to process data on the basis of a so-called “data processing agreement,” this is done on the basis of Art. 28 GDPR.
Transfers to Third Countries
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing/transmitting data to third parties, this only happens if it is necessary for the fulfillment of our (pre-)contractual obligations, based on your consent, due to a legal obligation, or based on our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special conditions of Art. 44 et seq. GDPR are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level equivalent to the EU (e.g., for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “Standard Contractual Clauses”).
Rights of Data Subjects
and to information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR. You have the right, in accordance with Art. 16 GDPR, to request the completion of data concerning you or the rectification of inaccurate data concerning you. In accordance with Art. 17 GDPR, you have the right to demand that relevant data be deleted without delay, or alternatively, in accordance with Art. 18 GDPR, to demand a restriction of the processing of the data. You have the right to receive the data concerning you, which you have provided to us, in accordance with Art. 20 GDPR, and to request its transmission to other controllers.
Furthermore, in accordance with Art. 77 GDPR, you have the right to lodge a complaint with the competent supervisory authority.
Right of Withdrawal
You have the right to withdraw consents granted in accordance with Art. 7 para. 3 GDPR with effect for the future.
Right to Object
You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection can be made in particular against processing for direct marketing purposes.
Cookies and Right to Object to Direct Marketing
“Cookies” are small files that are stored on users’ computers. Various information can be stored within cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Temporary cookies, or “session cookies” or “transient cookies,” are cookies that are deleted after a user leaves an online offering and closes their browser. Such a cookie can, for example, store the content of a shopping cart in an online shop or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent.” For example, the login status can be saved if users visit it after several days. Similarly, the interests of users can be stored in such a cookie, which are used for reach measurement or marketing purposes. “Third-party cookies” are cookies offered by providers other than the controller operating the online offering (otherwise, if they are only its cookies, they are called “first-party cookies”). We may use temporary and permanent cookies and explain this in our privacy policy. If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser’s system settings. Stored cookies can be deleted in the browser’s system settings. The exclusion of cookies may lead to functional restrictions of this online offering.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by deactivating them in the browser settings. Please note that in this case, not all functions of this online offering may be usable.
Deletion of Data
The data processed by us will be deleted or their processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated otherwise in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal retention obligations conflict with their deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
According to legal requirements in Germany, retention is particularly for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records, management reports, booking vouchers, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial letters).
According to legal requirements in Austria, retention is particularly for 7 years in accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, vouchers, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate, and for 10 years for documents in connection with electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU member states and for which the Mini One Stop Shop (MOSS) is used.
Deletion of Data
The data processed by us will be deleted or their processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated otherwise in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal retention obligations conflict with their deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
According to legal requirements in Germany, retention is particularly for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records, management reports, booking vouchers, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial letters).
According to legal requirements in Austria, retention is particularly for 7 years in accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, vouchers, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate, and for 10 years for documents in connection with electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU member states and for which the Mini One Stop Shop (MOSS) is used.
Data Protection Information in the Application Process
We process applicant data only for the purpose and within the scope of the application process in accordance with legal requirements. The processing of applicant data takes place for the fulfillment of our (pre-)contractual obligations within the framework of the application process in the sense of Art. 6 para. 1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR, if data processing becomes necessary for us, e.g., in the context of legal proceedings (in Germany, § 26 BDSG also applies).
The application process requires applicants to provide us with applicant data. The necessary applicant data are marked if we offer an online form, otherwise they result from the job descriptions and generally include personal details, postal and contact addresses, and the documents belonging to the application, such as cover letter, CV, and certificates. In addition, applicants can voluntarily provide us with additional information. By submitting the application to us, applicants agree to the processing of their data for the purposes of the application process in the manner and scope set out in this privacy policy.
Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily communicated during the application process, their processing also takes place in accordance with Art. 9 para. 2 lit. b GDPR (e.g., health data, such as severe disability status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants during the application process, their processing also takes place in accordance with Art. 9 para. 2 lit. a GDPR (e.g., health data, if these are necessary for the exercise of the profession).
If available, applicants can submit their applications to us via an online form on our website. The data is transmitted to us encrypted according to the state of the art. Furthermore, applicants can submit their applications to us via email. However, please note that emails are generally not sent encrypted, and applicants must ensure encryption themselves. We therefore cannot assume responsibility for the transmission path of the application between the sender and the receipt on our server and therefore recommend using an online form or postal delivery instead. Because instead of applying via the online form and email, applicants still have the option of sending us the application by post.
The data provided by the applicants can be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. The applicant’s data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.
Deletion takes place, subject to a legitimate withdrawal by the applicants, after a period of six months, so that we can answer any follow-up questions regarding the application and fulfill our obligations to provide evidence under the Equal Treatment Act. Invoices for any travel expense reimbursement will be archived in accordance with tax law requirements.
Contacting Us
When contacting us (e.g., via contact form, email, telephone, or social media), the user’s details are processed for handling the contact request and its processing in accordance with Art. 6 para. 1 lit. b) GDPR. User data may be stored in a Customer Relationship Management system (“CRM system”) or comparable inquiry organization.
We delete inquiries if they are no longer required. We review the necessity every two years; furthermore, legal archiving obligations apply.
Hosting and Email Dispatch
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services, and technical maintenance services that we use for the purpose of operating this online offering.
In doing so, we, or our hosting provider, process master data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties, and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).
Google Analytics
Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR), we use Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offering by users is usually transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on activities within this online offering, and to provide us with other services associated with the use of this online offering and internet usage. In doing so, pseudonymized usage profiles of users can be created from the processed data.
We only use Google Analytics with IP anonymization activated. This means that the IP address of users is truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.
The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software settings accordingly; users can also prevent Google from collecting the data generated by the cookie and related to their use of the online offering, and from processing this data by Google, by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
Further information on data use by Google, setting and objection options can be found in Google’s privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Users’ personal data will be deleted or anonymized after 14 months.
Integration of Third-Party Services and Content
Within our online offering, based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR), we integrate content or service offerings from third-party providers to embed their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always requires that the third-party providers of this content perceive the users’ IP address, as they would not be able to send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content. We endeavor to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Through the “pixel tags,” information such as visitor traffic on the pages of this website can be evaluated. The pseudonymized information can also be stored in cookies on the users’ device and may include technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, as well as be linked with such information from other sources.
Google Fonts
We integrate the fonts (“Google Fonts”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google Maps
We integrate the maps of the service “Google Maps” from the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of users, which are not collected without their consent (usually given in the settings of their mobile devices). The data may be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.