English
Log in to the portal
Legal

Privacy Policy

1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders or other order enquiries.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.

For detailed information about these analysis programs please consult our Data Protection Declaration below.

2. Hosting

We are hosting the content of our website at the following provider:

External Hosting

This website is hosted externally. Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

The external hosting serves the purpose of fulfilling the contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user's end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

Our host(s) will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

We are using the following host(s):

Hostinger International Ltd.
61 Lordou Vironos Street,
6023 Larnaca,
Zypern

3. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website and in the portal is:

Terapi Avrupa, LLC
Mr Serdarhan Uyar
Weißenbachstraße 7
6060 Hall in Tirol, Austria

E-mail: info@terapiavrupa.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Recipients of personal data

In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
  • If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
  • If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Encrypted payment transactions on this website

If you are under an obligation to share your payment information (e.g. account number if you give us the authority to debit your bank account) with us after you have entered into a fee-based contract with us, this information is required to process payments.

Payment transactions using common modes of paying (Visa/MasterCard, debit to your bank account) are processed exclusively via encrypted SSL or TLS connections. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the communication with us is encrypted, third parties will not be able to read the payment information you share with us.

4. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.

Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

If other cookies and services are used on this website, you can find this information in this privacy policy.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

  • The type and version of browser used
  • The used operating system
  • Referrer URL
  • The hostname of the accessing computer
  • The time of the server inquiry
  • The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

5. Analysis tools and advertising

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place.

Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://business.safety.google/adscontrollerterms/sccs/.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

IP anonymization

Google Analytics IP anonymization is active. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.

Google Ads

The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks.

Conversion measurement and click identifier (“GCLID”)

When you reach this website via a Google ad, Google appends a click identifier to the address you call up (the so-called “GCLID”; on Apple devices additionally “wbraid” or “gbraid”). We use this identifier for conversion measurement, that is, to determine through which channel registrations and bookings arise. The click identifier is a pseudonymous identifier assigned by Google; it contains neither your name nor your email address and identifies the ad click, not you as a person.

Three separate operations must be distinguished here, which rest on different legal bases:

1. Reading the identifier and passing it to our booking portal (always). To book an appointment, you are taken to our booking portal (portal.terapiavrupa.com). The click identifier is read from the address and passed to this portal – including where you have not consented to any cookies. Without this transfer, a later registration could not be attributed to the ad click. The legal basis is our legitimate interest in measuring the success of our advertising (Art. 6(1)(f) GDPR).

2. Storage at your account (always). Upon registration, the click identifier is stored together with your account in our own database, likewise on the basis of our legitimate interest (Art. 6(1)(f) GDPR). In addition, we record whether you consented to the use of cookies; this record serves measurement purposes only. The precise identifier is deleted 12 months after registration and replaced by a coarse origin marker (e.g. only “Google Ads”).

3. Cookie on your device and transmission to Google (only with consent). Only if you consent via our cookie notice is the click identifier additionally stored in a cookie (“ta_click_id”) on your device (lifetime a maximum of 90 days) and the conversion transmitted to Google. The legal basis is your consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG), which you may revoke at any time with effect for the future. Without your consent nothing is transmitted to Google and no cookie is set; if you decline or revoke, an already-set cookie is deleted.

Right to object (Art. 21 GDPR). You may object at any time to the processing of the click identifier based on legitimate interest (operations 1 and 2). An informal message to the contact address stated in the section “Information on the responsible party” suffices; we will then delete the identifier associated with your account.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://business.safety.google/controllerterms/.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

6. Newsletter and e-mails from the portal

Newsletter data

If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the handling of the newsletter, we use newsletter service providers, which are described below.

Brevo

This website uses Brevo for the sending of newsletters. The provider is the Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany.

Brevo services can, among other things, be used to organize and analyze the sending of newsletters. The data you enter for the purpose of subscribing to the newsletter are archived on servers of Sendinblue GmbH in Germany.

Data analysis by Brevo

Brevo enables us to analyze our newsletter campaigns. For instance, it allows us to see whether a newsletter message has been opened and, if so, which links may have been clicked. This enables us to determine, which links drew an extraordinary number of clicks.

Moreover, we are also able to see whether once the e-mail was opened or a link was clicked, any previously defined actions were taken (conversion rate). This allows us to determine whether you have made a purchase after clicking on the newsletter.

Brevo also enables us to divide the subscribers to our newsletter into various categories (i.e., to “cluster” recipients). For instance, newsletter recipients can be categorized based on age, gender, or place of residence. This enables us to tailor our newsletter more effectively to the needs of the respective target groups.

If you do not want to permit an analysis by Brevo, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message.

For detailed information on the functions of Brevo please follow this link: https://www.brevo.com/de/newsletter-software/.

Legal basis

The data is processed based on your consent (Art. 6(1)(a) GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.

Storage period

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

For more details, please consult the Data Protection Regulations of Brevo at: https://www.brevo.com/de/datenschutz-uebersicht/ and https://www.brevo.com/de/legal/privacypolicy/.

Notifications from the portal

Independently of the newsletter, we send e-mails that are part of using the portal: confirmation of your registration, appointment and payment confirmations, reminders, and the notice that a new message is waiting for you. These e-mails are also sent via Brevo. They are part of the agreed service; the legal basis is Art. 6(1)(b) GDPR. They do not contain an unsubscribe link because you need these notices in order to use the portal. The notice about a new message never contains its content.

Advertising by e-mail

When registering in the portal, you may voluntarily consent to us sending you offers and useful content by e-mail. This consent is not a prerequisite for using the portal, and you can use the portal without restriction without it. The legal basis is Art. 6(1)(a) GDPR. You may revoke your consent at any time – via the unsubscribe link in each of these e-mails or by sending a message to info@terapiavrupa.com. Without this consent, we will not send you any advertising.

7. Plug-ins and Tools

Google Fonts (local embedding)

This website uses so-called Google Fonts provided by Google to ensure the uniform use of fonts on this site. These Google fonts are locally installed so that a connection to Google’s servers will not be established in conjunction with this application.

For more information on Google Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

The purpose of reCAPTCHA is to determine whether data entered on this website (e.g., information entered into a contact form) is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyzes the behavior of the website visitors based on a variety of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA evaluates a variety of data (e.g., IP address, time the website visitor spent on the site or cursor movements initiated by the user). The data tracked during such analyses are forwarded to Google.

reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is underway.

In this context, Google acts solely as a data processor within the meaning of Article 28 of the GDPR and will not use the data collected in this manner for its own purposes. Use of the tool is based on a Data Processing Agreement (DPA) with Google.

Data are stored and analyzed on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the protection of the operator’s websites against abusive automated spying and against SPAM. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

8. eCommerce and payment service providers

Processing of Customer and Contract Data

We collect, process, and use personal customer and contract data for the establishment, content arrangement and modification of our contractual relationships. Data with personal references to the use of this website (usage data) will be collected, processed, and used only if this is necessary to enable the user to use our services or required for billing purposes. The legal basis for these processes is Art. 6(1)(b) GDPR.

The collected customer data shall be deleted upon completion of the order or termination of the business relationship and upon expiration of any existing statutory archiving periods. This shall be without prejudice to any statutory archiving periods.

Data transfer upon closing of contracts for services and digital content

We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with the financial institution tasked with the processing of payments.

Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur.

The basis for the processing of data is Art. 6(1)(b) GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions.

Payment services

We integrate payment services of third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, bank account details, credit card number) are processed by the payment service provider for the purpose of payment processing. For these transactions, the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment transaction (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consent may be revoked at any time for the future.

We use the following payment services / payment service providers within the scope of this website:

Stripe

The provider for customers within the EU is Stripe Payments Europe, Ltd,1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (hereinafter “Stripe”).

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://stripe.com/de/privacy and https://stripe.com/de/guides/general-data-protection-regulation.

Details can be found in Stripe’s Privacy Policy at the following link: https://stripe.com/de/privacy.

9. Video sessions with your psychologist

How the sessions take place

The counselling sessions take place as video sessions via Google Meet. The provider for users within the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

We create the access to a session via our own business account. You need neither your own Google account nor a Google login for this; the access is sent to you as a link together with your appointment.

When you take part, Google processes the data technically required for the connection. This includes in particular your IP address, device type, operating system, browser or client version, details of camera, microphone and speaker, as well as the start, end and duration of your participation. We have only limited influence on this processing by Google; for details, please refer to Google’s privacy policy.

We do not record sessions

No recordings, captures or transcripts of your sessions are made. The recording function is not available in our configuration. Regardless of this, under our contractual terms with the psychologists, a recording is permitted only with your express and documented consent.

Purpose and legal basis

The video session is the service you have booked. The legal basis is Art. 6(1)(b) GDPR (performance of a contract). Your psychologist is independently responsible for the content of the conversation; they are bound by professional confidentiality.

Transfer to the USA

Our contractual partner is Google Ireland Limited. Nevertheless, a transfer of data to Google LLC in the USA cannot be ruled out. Google LLC is certified under the EU-US Data Privacy Framework, which is intended to ensure a level of data protection appropriate for transfers to the USA. In addition, the transfer is based on the Standard Contractual Clauses of the EU Commission.

Storage period

From the session itself, we store only the fact that and when it took place. This appointment data belongs to your booking; the retention periods are set out in section 14. We have no influence on how long Google stores the technical data it collects.

10. Our portal

What the portal is

In addition to this website, we operate our own portal at portal.terapiavrupa.com. There you create an account, choose a psychologist yourself, book and pay for appointments and can write messages. We do not assign anyone to you and do not make the choice for you. The website and the portal are technically separate systems.

This section and sections 11 to 14 describe what happens to your data in the portal. Sections 1 to 8 describe the website.

Who is responsible for what

Two parties are involved in your counselling, and under data protection law they are not the same:

  • We are responsible for everything that makes up the operation of the portal: your account, the presentation of the available psychologists, appointment bookings, payments and invoicing.
  • Your psychologist is independently responsible for everything that arises in the counselling itself. This also includes the documentation required by professional law. This documentation is kept outside our portal; we have no access to it and do not store it.
  • For the messages in the portal, we act on behalf of your psychologist. We provide the technology; the content belongs to the counselling relationship. The basis is a data processing agreement pursuant to Art. 28 GDPR.

One address for all requests

You do not need to know this division in order to exercise your rights. Direct every request to info@terapiavrupa.com. If it concerns the area of responsibility of your psychologist, we will forward it there and tell you so. The statutory period of one month runs from receipt by us, not from the forwarding.

Where your data is located

Like this website, the portal application runs at Hostinger International Ltd., 61 Lordou Vironos Street, 6023 Larnaca, Cyprus, on servers within the European Union.

We operate the portal’s database with Supabase. Our contractual partner is Supabase Pte. Ltd., based in Singapore. Your data is stored exclusively in a data centre in Frankfurt am Main and does not leave the European Union during normal operation. Because the company is based outside the EU, the cooperation is based on a data processing agreement incorporating the Standard Contractual Clauses of the EU Commission.

The portal window on this website

On the booking page, on individual advertising landing pages and on the profile pages of our psychologists, the portal is embedded in the website as a window. This window loads together with the page. In the process, your IP address is transmitted to portal.terapiavrupa.com before you click anything. This is our own infrastructure, not a third-party provider.

The website passes two pieces of information to the window: any click identifier from the address bar if you arrived via an ad, and the status of your cookie consent. Both are described in more detail in section 5.

11. Registration, account and appointment booking

Information provided at registration

Registration in the portal takes you through several short questions. They serve to set up your account and to present the offers to you in a suitable way. You decide yourself which psychologist you choose. We ask for:

  • form of address or gender, so that we address you correctly,
  • your country of residence and a time window that suits you, because of time zone and availability,
  • your age group,
  • for whom you are seeking support, for example for yourself, for your partner or for your child,
  • the topic you would like to talk about,
  • whether you prefer a female or a male psychologist,
  • when you would like to start.

You then create the account. To do so, you provide your first name, last name and e-mail address. You then set your password yourself via a link that we send you by e-mail; we do not store it in plain text.

The legal basis is Art. 6(1)(b) GDPR for the initiation and performance of the user contract, as well as your consent pursuant to Art. 6(1)(a) and Art. 9(2)(a) GDPR insofar as your information indicates that you are seeking psychological counselling.

Information about your health

The fact that someone is seeking psychological counselling may allow conclusions to be drawn about their health. Such information is specially protected. We therefore deliberately keep data collection to a minimum: we ask neither about diagnoses nor about previous treatment, medication or complaints. Whatever you wish to describe in substance, you discuss with your psychologist; we are not responsible for that content.

For the information that we do hold, we obtain your express consent pursuant to Art. 9(2)(a) GDPR at registration. We document when you gave it and which text was displayed to you at the time.

Your two checkboxes at registration

At registration you tick two boxes, which mean different things:

  • The first checkbox is required. With it you confirm the terms of use and this privacy policy and expressly consent to us processing your information in order to give you access to our psychologists. Without this consent we cannot provide the service.
  • The second checkbox is voluntary and concerns advertising by e-mail only. Whether or not you tick it has no effect on whether you can use the portal. More on this in section 6.

Withdrawing consent

You may withdraw your consent at any time with effect for the future. The easiest way is the account deletion function in the account settings of the portal. Since our matching service is not possible without this information, withdrawal also ends your use of the portal. The lawfulness of the processing carried out up to that point remains unaffected. Alternatively, an informal message to info@terapiavrupa.com is sufficient.

Appointment booking

You can also book an appointment directly on the profile page of a psychologist. In doing so, we collect the package chosen, your contact details, and the date and time of the appointment. We process the payment via Stripe; details in section 8.

After a successful booking, an account in the portal is created for you automatically, through which you manage your appointments and messages. If you cancel the booking or the payment fails, no account is created.

The legal basis is Art. 6(1)(b) GDPR as well as your consent pursuant to Art. 9(2)(a) GDPR, which you give during the booking process.

If you book for your child

Only adults may hold an account in the portal. Parents and other legal guardians may book counselling for their minor child. In that case the account, the contract and the consent lie with the adult; they also give consent for the information concerning the child.

12. Messages in the portal

Who can read your messages

Via the messaging function of the portal, you can write to your psychologist independently of an appointment. A message is visible only to the person you address it to. Other psychologists have no access.

Deletion after seven days

Messages are automatically deleted from the database seven days after they are sent. They are not part of our database backups and therefore do not live on there either. If you would like to keep something from a message, please save it yourself within these seven days.

Notification by e-mail

We inform the recipient of a new message by e-mail. This notification does not contain the text of your message, only the notice that something has arrived in the portal. The content stays in the portal.

Not for emergencies

The messaging function does not replace a session and is not suitable for acute crises. In an emergency, please contact the emergency number 112 or a crisis service near you.

Legal basis

Art. 6(1)(b) GDPR. For the content, we act on behalf of your psychologist (Art. 28 GDPR); they are bound by professional confidentiality.

13. Data processing for psychologists

This section is addressed to professionals who apply to us or work via the portal. For clients, sections 10 to 12 and 14 apply.

Application and admission

The admission process begins with an online introductory conversation. This conversation is not recorded. We then collect personal data, areas of expertise and specialisations, as well as proof of training and qualifications, in particular diplomas and the licence to practise, and verify them. The legal basis is Art. 6(1)(b) GDPR (initiation and performance of the contract). If no cooperation results, the documents submitted are deleted.

Your public profile

After activation, information about you is publicly visible in two places. On our website as a profile page with the details you provide us for this purpose: name, photo, professional title, location, professional experience, languages, focus areas, training, a short text about you and your fee. And in the booking window of the portal, which shows clients your name, your photo, a video if any, and your available appointments.

You decide which of these details you give us. You may request changes or the removal of individual details at any time.

Appointments, invoicing and payouts

For operations, we also process your appointment and booking data as well as the data we need for settling accounts with you. This data is not public; it is visible only to you and to us. Payouts are made via Stripe; for this you set up your own Stripe account, the details of which you provide directly to Stripe.

Reviews and assessment of the cooperation

Clients can leave reviews. In addition, we assess the cooperation on the basis of the criteria set out in our contractual terms, such as reliability regarding appointments, availability and feedback from clients. This assessment is carried out by people; we do not calculate or store automated metrics for it. No automated decision-making within the meaning of Art. 22 GDPR takes place.

Roles and data processing on behalf

You are independently responsible for the health and client data that arises in your counselling. Insofar as we process data exclusively on your behalf, in particular the messages in the portal, the data processing agreement attached as an annex to our contractual terms applies.

14. Storage period, recipients and your rights in the portal

How long we store what

We store data only for as long as the respective purpose requires. The periods apply per type of data, not across the board for the entire account:

  • Messages in the portal: seven days from sending, then automatic deletion.
  • Inactive account: twelve months from your last login to the portal. After that, the account is deleted automatically. One month beforehand we send you a reminder by e-mail so that you can still log in if you wish to keep it.
  • Appointment and booking data: for the duration of the business relationship.
  • Invoicing and accounting records: seven years, because the law requires it. This retention concerns only the commercial records. Information from the registration relating to your concern is not covered by this and is not retained with it.
  • Account deleted at your request: immediately, with the exception of the invoicing records.

We do not store a registration that has been started but not completed; your answers remain in your browser until the account is created.

Who receives your data in connection with the portal

We pass data on only to service providers that are necessary for operations. Data processing agreements pursuant to Art. 28 GDPR are in place with them:

  • Hostinger International Ltd., 61 Lordou Vironos Street, 6023 Larnaca, Cyprus – operation of the website and portal, servers in the EU.
  • Supabase Pte. Ltd., Singapore – database of the portal, storage in Frankfurt am Main, transfer on the basis of the Standard Contractual Clauses.
  • Sendinblue GmbH (Brevo), Köpenicker Straße 126, 10179 Berlin – sending of our e-mails.
  • Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Dublin, Ireland – payment processing and payouts.
  • Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland – video sessions via Google Meet.
  • Your psychologist receives the information required for the counselling. They are not a processor but independently responsible.

Your rights and how to exercise them

You are entitled to the rights described in section 3: access, rectification, erasure, restriction of processing, data portability, withdrawal of consent given, and objection. For the portal, the following also applies:

  • Delete account: You can delete your account yourself at any time in the account settings of the portal.
  • Access and data portability: We will provide you with a copy of your data in a common format on request. To do so, contact info@terapiavrupa.com.
  • Identity verification: So that no unauthorised person obtains information about you or deletes your account, we process requests only if they come from the e-mail address stored with us or are confirmed via a link sent to that address. We do not require a copy of your ID.
Free 15-min intro call