Privacy policy

01

Controller

The controller within the meaning of the General Data Protection Regulation is the owner of the practice:

02

Provision of the website and hosting

The website is hosted by STRATO GmbH, Otto-Ostrowski-Straße 7, 10249 Berlin. In order to deliver a page to your browser, the web server processes technically necessary connection data. This may include, in particular, the IP address, date and time, requested file, amount of data transferred, HTTP status, referrer, and information about the browser and operating system.

The purpose is the secure and reliable provision of the website, including the detection of errors and misuse. The legal basis is Article 6(1)⁠(f) GDPR. Our legitimate interest is a technically reliable and secure online presence. The website cannot be delivered without the required connection data.

STRATO processes hosting data on behalf of the practice. The contractual framework is its data processing agreement under Article 28 GDPR.

According to STRATO, IP addresses are stored for up to seven days to detect and prevent attacks. Access logs made available to hosting customers cover six weeks and contain anonymised hostnames or IP addresses. According to STRATO, error logs can be accessed for up to five days.

Depending on the hosting package, STRATO also provides aggregated visitor statistics derived from web server data. According to STRATO, these statistics can be accessed for several years. STRATO generates them automatically, and the practice cannot switch them off. Where connection data is processed for this, the legal basis is Article 6(1)⁠(f) GDPR. The legitimate interest lies in the technical operation by the hosting provider and in evaluating access to and errors of the website.

The website does not set cookies, does not store information in your browser and does not load analytics or marketing scripts.

03

Contact, Doctolib appointments and telephone assistant

Contact by telephone, fax and email

If you call, fax or email us, we process the information you provide and the necessary communication data in order to handle your request. Depending on the content, processing is based on Article 6(1)⁠(b) GDPR for taking steps prior to or performing a treatment relationship, or on Article 6(1)⁠(f) GDPR for general enquiries. In the latter case, our legitimate interest is responding appropriately to the enquiry. Providing this information is voluntary, but without it we cannot handle your request.

Please do not send medical findings or other particularly confidential information unsolicited by ordinary email. Agree a suitable transmission method with the practice in advance.

Where you provide health data required for medical care, it is processed on the basis of Article 9(2)⁠(h) GDPR in conjunction with Section 22(1) no. 1(b) BDSG. Physicians and supporting staff are bound by confidentiality.

AI telephone assistant

The Doctolib AI telephone assistant may answer calls to the practice number. At the beginning, the assistant states that the call is recorded during the connection. The data processed may include your telephone number, the identification and contact details you provide, your request including possible health information, the audio recording, a transcript, classification of the request and an automatically generated summary. Responsible practice staff can view this information to handle your request.

The assistant receives appointment, prescription, callback and other enquiries and prepares them for the practice team to handle. The AI processing is performed by Doctolib and its subprocessors. The practice remains the controller for this processing. Doctolib GmbH, Friedrichstraße 111, 10117 Berlin, provides the technical service as a processor under Article 28 GDPR. Its responsibilities are governed by the data processing agreement included in the Doctolib contract. The assistant does not provide medical advice and is not intended for emergencies.

The data processing agreement also lists service improvements, statistics and anonymisation as purposes of the telephone assistant. A separate reuse of health data by Doctolib for its own research and product development is subject to additional requirements: Doctolib's terms require the practice's express authorisation and the patient's consent or an applicable authorisation from a competent authority. Consent for this separate reuse is managed through Doctolib. Simply calling the practice does not give that consent.

The legal basis for answering, recording, transcribing and AI-assisted processing of your call is Article 6(1)⁠(b) GDPR where your request prepares or concerns treatment, and otherwise Article 6(1)⁠(f) GDPR. Our legitimate interest is being reliably reachable by telephone and recording your request completely and verifiably. Health information is processed on the basis of Article 9(2)⁠(h) GDPR in conjunction with Section 22(1) no. 1(b) BDSG. We do not ask for consent for this processing. The greeting also includes a short privacy notice from Doctolib. If you do not want the call to be recorded, end the call and contact us by email at praxis@dr-⁠behle.de. There is no statutory or contractual obligation to use the telephone assistant.

Under the standard retention rule in the Doctolib data processing agreement, audio recordings are retained for 60 days after the conversation so that the practice can check and correct the transcripts. They are then deleted. A different period requires a written instruction from the practice. Messages generated from transcripts are retained separately from the audio recordings, according to the purpose of the enquiry, completion of its handling and applicable retention obligations (section 07).

Online booking via Doctolib

The online booking buttons lead to the practice profile on Doctolib.

When the Doctolib website is accessed, Doctolib initially processes technically necessary access data under its own responsibility. If you book an appointment there, the data processed may include, in particular, your name, date of birth, contact details, appointment time, treating person, reason for the appointment and health information provided voluntarily. The practice processes booking data to organise appointments and to take steps prior to or perform the treatment relationship on the basis of Article 6(1)⁠(b) GDPR. Article 9(2)⁠(h) GDPR in conjunction with Section 22(1) no. 1(b) BDSG additionally applies to necessary health data.

Where Doctolib provides appointment management for the practice, it processes booking data as a processor under the data processing agreement pursuant to Article 28 GDPR incorporated into the contract terms. Doctolib may itself be the controller for a personal Doctolib account and its own platform services. The privacy information provided there applies to those services. Under the standard rule of the data processing agreement, Doctolib keeps the appointment history for five years. Information that becomes part of the treatment record is subject to the periods in section 07. Online booking is voluntary. You can also request appointments by email. The practice keeps all appointments in its Doctolib calendar, including those arranged by email or telephone.

Storage location and transfers to third countries

According to its data processing agreement, Doctolib stores personal data within the European Economic Area (EEA). Some of Doctolib's subprocessors are based in the USA, and some also operate servers there. Transfers to the USA or access from there are therefore possible, for example for certain support services for its Google Cloud hosting. Doctolib bases such transfers on the European Commission's adequacy decision for the EU–U.S. Data Privacy Framework where the recipient is certified, and otherwise on standard contractual clauses or other safeguards under Chapter V GDPR with additional protective measures. Section 14 of Doctolib's data processing agreement and its list of subprocessors show which subprocessors are used and where their servers are located.

04

Doctolib AI consultation assistant

The Doctolib AI consultation assistant helps prepare consultation notes. When activated, it temporarily records the conversation, transcribes it and suggests structured notes. This may include voices, identifying details and health information discussed during the consultation, including information from accompanying people. The suggestions must be checked and, where necessary, corrected by the treating clinician before being added to the medical record. Medical decisions remain with the clinician.

Use is voluntary and requires your express consent before recording starts. The legal basis for recording and AI processing is Article 6(1)⁠(a) and Article 9(2)⁠(a) GDPR. You may refuse or withdraw consent at any time, including asking for the recording to stop during the consultation. Your treatment does not depend on consent to this assistant. Consultation notes can be prepared without it. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Doctolib GmbH processes the data on behalf of the practice under its data processing agreement, with the support of its subprocessors. Access within the practice is limited according to responsibilities in treatment, practice assistance and administration. The information on Doctolib's storage location and transfers to the USA in section 03 also applies.

The current Doctolib data processing agreement provides for transcripts and suggested notes to be retained for seven days after the consultation for review and correction, and then deleted. Information incorporated into the medical record is subject to the medical retention obligations (section 07).

Consent to consultation documentation does not in itself authorise Doctolib to reuse audio recordings for its own research or AI development. Such reuse requires a separate basis and the additional permissions set out in section 03. Doctolib provides separate consent settings for patients for this audio reuse.

05

Applications by email

If you apply by email, we process your contact, application and qualification data in order to decide whether to establish an employment relationship. The legal basis is Article 6(1)⁠(b) GDPR (steps taken at your request prior to entering into a contract). Applications arrive in the general practice mailbox. The practice team reviews them and forwards them to the people involved in the selection process. The email service provider of the practice is also technically involved.

If you voluntarily provide information about your health, such as a severe disability, we process it on the basis of Article 9(2)⁠(b) GDPR where it is necessary for the application process or the subsequent employment relationship.

An application cannot be assessed without the information required for the selection process. If no employment relationship is established, we generally delete application data no later than six months after the process has concluded. Data is stored for longer only with your separate consent (Article 6(1)⁠(a) GDPR) or where storage is required for the establishment, exercise or defence of legal claims (Article 6(1)⁠(f) GDPR).

06

External links

The website contains links to external services, including Doctolib, OpenStreetMap, the German medical on-⁠call service and professional cooperation partners. When you open such a link, the respective operator processes your IP address and other technically necessary access data under its own responsibility. Its privacy information applies. No referrer is transmitted.

07

Storage period and recipients

General enquiries are deleted once they have been handled conclusively and no statutory retention or evidentiary obligations remain. If a communication becomes relevant to treatment, it may become part of the medical record. This is generally subject to a statutory retention period of ten years after treatment has ended. Specific provisions may require longer periods in individual cases.

Recipients are limited to the responsible people within the practice and the service providers used for hosting, email, appointments, telephony, consultation documentation and maintenance of the practice software where this is necessary for the relevant purpose. Disclosure to other bodies takes place only where there is a legal basis, particularly a statutory obligation, performance of a contract or your consent.

08

Your data protection rights

Where the applicable statutory requirements are met, you have the right of access (Article 15 GDPR), rectification (Article 16 GDPR), erasure (Article 17 GDPR), restriction of processing (Article 18 GDPR) and data portability (Article 20 GDPR). You may withdraw consent at any time with effect for the future (Article 7(3) GDPR).

A message to the contact details in section 01 is sufficient to exercise your rights. Neither this website nor the Doctolib AI assistants make automated decisions with legal or similarly significant effects, and no profiling takes place. The assistants only prepare requests and notes, the practice team makes the decisions.

09

Right to lodge a complaint with a supervisory authority

Under Article 77 GDPR, you have the right to lodge a complaint with a data protection supervisory authority. In particular, you may contact the authority responsible for the practice: