MVZ Gastropraxis Eppendorferbaum GmbH

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Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter referred to as “data”) that we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us on our websites (hereinafter referred to as “online services”).

The terms used are not gender-specific.

Last updated: December 8, 2025

Table of contents

  • preamble
  • Responsible
  • Contact Data Protection Officer
  • Overview of processing activities
  • Relevant legal bases
  • Security measures
  • Transfer of personal data
  • International data transfers
  • General information on data storage and deletion
  • Rights of data subjects
  • Use of online platforms for offering and sales purposes
  • Provision of the online service and web hosting
  • Use of cookies
  • Contact and inquiry management
  • Plug-ins and embedded functions as well as content
  • Changes and updates

Responsible person

MVZ Gastroenterologie Eppendorfer Baum GmbH
Eppendorfer Baum 35 – 37
20249 Hamburg
Deutschland

E-Mail-Adresse: info@gastropraxis-eppendorferbaum.de

Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects.

Types of data processed

  • Basic data
  • Payment data
  • Location data
  • Contact data
  • Content data
  • Contract data
  • Usage data
  • Meta, communication and procedural data
  • Log data

Categories of data subjects

  • Service recipients and clients
  • Communication partners
  • Users
  • Business and contractual partners

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Organizational and administrative procedures.
  • Feedback.
  • Marketing.
  • Provision of our online services and user-friendliness.
  • Information technology infrastructure.
  • Business processes and business management procedures.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. Furthermore, should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

 

National data protection regulations in Germany: In addition to the GDPR data protection regulations, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (BDSG). The BDSG contains specific provisions regarding the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and data transfers, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may also apply.

Notice regarding the applicability of the GDPR and Swiss Federal Act on Data Protection (FADP): This privacy notice serves to provide information in accordance with both the Swiss FADP and the General Data Protection Regulation (GDPR). Therefore, please note that, due to its broader geographical scope and clarity, the terms used here are those of the GDPR. In particular, instead of the terms “processing” of “personal data,” “overriding interest,” and “special categories of personal data” used in the Swiss FADP, the terms “processing” of “personal data,” “legitimate interest,” and “special categories of data” used in the GDPR are employed. However, the legal meaning of these terms will continue to be determined according to the Swiss FADP when applicable.

Security measures

In accordance with legal requirements, 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 threat to 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 and electronic access to the data, as well as access to, input of, transfer of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.

IP address truncation: If IP addresses are processed by us or by the service providers and technologies we use, and processing a full IP address is not necessary, the IP address is truncated (also known as “IP masking”). This involves removing the last two digits, or the last part of the IP address after a period, or replacing them with placeholders. The purpose of truncating the IP address is to prevent or significantly hinder the identification of a person based on their IP address.

Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted through our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thus protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transfer of personal data

As part of our processing of personal data, it may be necessary to transfer or disclose this data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, IT service providers or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to ensure its protection.

Data transfer within the corporate group: We may transfer personal data to other companies within our corporate group or grant them access to it. This data transfer is based on our legitimate business interests. These include, for example, improving business processes, ensuring efficient and effective internal communication, optimizing the use of our human and technological resources, and being able to make informed business decisions. In certain cases, data transfer may also be necessary to fulfill our contractual obligations, or it may be based on the consent of the data subject or on legal permission.

Data transfer within the organization: We may transfer personal data to other departments or units within our organization or grant them access to it. If the data transfer is for administrative purposes, it is based on our legitimate business interests or is necessary for the fulfillment of our contractual obligations, or if the data subject has given consent or if there is a legal basis for doing so.

International data transfers

Data processing in third countries: If we transfer data to 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 or transferring data to other persons, bodies or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to the data transfer to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.

This dual safeguard ensures comprehensive protection of your data: The Data Protection Framework (DPF) forms the primary layer of protection, while the Standard Contractual Clauses serve as an additional safeguard. Should changes occur within the framework of the DPF, the Standard Contractual Clauses act as a reliable fallback option. This ensures that your data remains adequately protected even in the event of any political or legal changes.

For each service provider, we will inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information about the DPF and a list of certified companies can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, appropriate safeguards apply, in particular standard contractual clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the EU Commission’s information service: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and deletion

We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are withdrawn or no further legal basis for processing exists. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for legal prosecution or for the protection of the rights of other natural or legal persons, must be archived accordingly.

Our privacy policy contains additional information on the storage and deletion of data, which applies specifically to certain processing operations.

In cases where multiple retention periods or deletion deadlines for a given date are specified, the longest period always applies. Data that is no longer retained for its originally intended purpose, but is retained due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.

Data retention and deletion: The following general retention periods apply to data storage and archiving under German law:

  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
  • 8 years – accounting documents, such as invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
  • 6 years – Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. timesheets, operating statements, cost calculation documents, price labels, but also payroll documents, insofar as they are not already accounting documents and cash register tapes (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
  • 3 years – Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and standard industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

 

Commencement of a time limit at the end of the year: If a time limit does not expressly begin on a specific date and is at least one year long, it starts automatically at the end of the calendar year in which the event triggering the time limit occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the time limit is the effective date of the termination or other end of the legal relationship.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to withdraw any consent you have given at any time.
  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed, and to access this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of your personal data or the correction of inaccurate personal data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.
  • Right to data portability: You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, in accordance with the legal requirements, or to request its transmission to another controller.
  • Right to lodge a complaint with a supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you believe that the processing of personal data relating to you infringes the GDPR.

Use of online platforms for offering and sales purposes

We offer our services on online platforms operated by other service providers. In this context, the privacy policies of the respective platforms apply in addition to our privacy policy. This applies in particular to the processing of payments and the methods used on the platforms for audience measurement and interest-based marketing.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or telephone numbers); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Service recipients and clients. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; marketing. Business processes and operational procedures.
  • Storage and deletion: Deletion according to the information in the section “General information on data storage and deletion”.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

    • Online appointment booking via CLICKDOC (link): On our website, we offer patients an external link to the online appointment service “clickdoc.” This is an external service that allows you to flexibly book, manage, or request doctor’s appointments online. When you visit our website, no personal data is transmitted to the service provider, as no content from the service is embedded and no connection to their servers is established. Only when you click the corresponding link will you leave our website and be redirected to “CLICKDOC.” From this point on, your data is processed exclusively by the service provider under their own data protection responsibility; Service provider: CGM Mobile Services GmbH, Maria Trost 21, 56070 Koblenz; Legal basis: The provision of the link is based on our legitimate interest pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR, to offer our patients a simple way to book appointments; Website: https://clickdoc.de/. Privacy Policy: https://de.cgmlife.com/AWS/eu-inventory/Datenschutzerklaerung_CLICKDOC_DE_7_32.pdf. Data Processing Agreement: Provided by the service provider.

    Provision of the online service and web hosting

We process user data to provide our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.

  • Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Log data (e.g., log files concerning logins or data retrieval or access times).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
  • Storage and deletion: Deletion according to the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

 

Further information on processing procedures, methods and services:

  • Provision of online services on rented storage space: For the provision of our online services, we use storage space, computing capacity and software that we rent from a corresponding server provider (also called “web host”) or otherwise obtain; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Collection of Access Data and Log Files: Access to our online services is logged in the form of so-called “server log files.” Server log files may contain the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server capacity and stability. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of Data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes is exempt from deletion until the respective incident has been fully resolved.
  • Hetzner: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.hetzner.com; Privacy policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data processing agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.

Use of cookies

The term “cookies” refers to functions that store information on and read it from users’ devices. Cookies can also be used for various purposes, such as ensuring the functionality, security, and user-friendliness of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. Where necessary, we obtain users’ consent beforehand. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to providing explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We clearly inform users about the scope of this consent and which cookies are used.

Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage duration:  The following types of cookies are distinguished with regard to storage duration:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the user closes their device. This allows, for example, login status to be saved and preferred content to be displayed directly when the user revisits a website. User data collected via cookies can also be used for audience measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that these cookies are persistent and can be stored for up to two years.

 

General information on revocation and objection (opt-out):  Users can revoke their consent at any time and also object to the processing in accordance with legal requirements, including via their browser’s privacy settings.

    • Types of data processed: Metadata, communication data and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
    • Affected persons: Users (e.g., website visitors, users of online services).
    • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Contact and inquiry management

When you contact us (e.g. by mail, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the requesting persons is processed to the extent necessary to answer the contact requests and any requested measures.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Affected persons: Communication partners.
  • Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online services and user-friendliness.
  • Storage and deletion: Deletion according to the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing procedures, methods and services:

  • Contact form: When you contact us via our contact form, email, or other communication channels, we process the personal data you provide to answer and process your request. This typically includes information such as your name, contact details, and any other information you provide that is necessary for proper processing. We use this data exclusively for the stated purpose of contacting you and communicating with you; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Plug-ins and embedded functions as well as content

We integrate functional and content elements into our online service that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, or city maps (hereinafter collectively referred to as “content”).

The integration of third-party content always requires that these providers process users’ IP addresses, as they cannot send the content to users’ browsers without them. The IP address is therefore necessary for displaying this content or these functions. We strive to use only content from providers who use the IP address solely for content delivery. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. These pixel tags allow information such as visitor traffic on the pages of this website to be analyzed. The pseudonymized information can also be stored in cookies on users’ devices and may include, among other things, technical information about the browser and operating system, referring websites, the time of visit, and other information about the use of our online services, as well as be combined with such information from other sources.

Information on the legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved). Location data (information about the geographic position of a device or person).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online service and user-friendliness.
  • Storage and deletion: Deletion according to the information in the section “General information on data storage and deletion”. Cookies are stored for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Google Maps: We integrate maps from the “Google Maps” service provided by Google. The data processed may include, in particular, users’ IP addresses and location data; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).

Changes and updates

We ask that you regularly review the content of our privacy policy. We will update the privacy policy as soon as changes to our data processing activities make this necessary. We will inform you if any changes require action on your part (e.g., consent) or any other individual notification.

If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting them.