Privacy Policy

Info

Non-binding translation. This is an English courtesy translation. Only the German-language version of this legal notice / privacy policy is legally binding.

1. Data protection at a glance

General information

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by NeuroPraxis Kleinmachnow. You can find contact details in the section “Notice regarding the controller” further below. For details on data collection when visiting the website, see Website visitors (AWS Amplify).

How do we collect your data?

Your data is collected, on the one hand, by you providing it to us. This may involve, for example, data that you transmit to us by phone or email. In addition, we receive data that a referring physician has noted on the referral slip or transmitted to us electronically.

Other data is collected automatically or with your consent when you visit the website through our IT systems. This is primarily technical data (e.g. internet browser, operating system or time of the page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure error-free provision of the website. Other data can be used to analyze your user behavior. In addition, we use your data for scheduling appointments and for medical care in our practice.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipients and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time with effect for the future. In addition, you have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this as well as other questions on the subject of data protection.

Notice regarding the controller

The controller responsible for data processing on this website is:

NeuroPraxis Kleinmachnow
Gelareh Torabi
Fachärztin für Neurologie (specialist in neurology)
August-Bebel-Platz 2
14532 Kleinmachnow

Phone: +49 33203 78205 Email: info@neuropraxis-kleinmachnow.de

Processing on behalf (AWS services)

A data processing agreement (DPA) has been concluded for all AWS services. This results from the AWS GDPR Data Processing Addendum (DPA), which is an explicit part of the AWS Service Terms.

This is a contract required under data protection law that ensures AWS processes personal data only in accordance with our instructions and in compliance with the GDPR (DSGVO).

AWS and GDPR compliance:

  • AWS provides extensive tools for access control (IAM, MFA, CloudTrail)
  • All AWS services used are operated exclusively in the EU region
  • AWS is certified according to ISO 27001, ISO 27017, ISO 27018 and SOC 1/2/3
  • Further information: AWS GDPR Center

AWS services used:

  • AWS Amplify – website hosting and CDN, data location EU (Frankfurt, eu-central-1), legal basis Art. 6 para. 1 lit. f DSGVO (GDPR)
  • AWS CodeCommit – source code management, data location EU (Frankfurt, eu-central-1), legal basis Art. 6 para. 1 lit. f DSGVO (GDPR) Note: The CodeCommit repository contains exclusively the source code of the website — no patient data or health data.
  • Amazon S3 Glacier Deep Archive – long-term archiving of business emails (10 years), data location EU (Stockholm, eu-north-1), server-side encryption with AES-256 (SSE-S3), legal basis Art. 6 para. 1 lit. c DSGVO (GDPR) (legal obligation pursuant to § 147 AO, § 630f para. 3 BGB). Details: see Email archiving
  • AWS WorkMail – email communication (shut down on 18 April 2026, replaced by mailbox.org), data location EU (Ireland, Dublin), legal basis Art. 6 para. 1 lit. b/f DSGVO (GDPR)

External service (not AWS):

  • Currently no external services in use beyond the AWS services and processors mentioned.

Further references:

Record of processing activities (overview pursuant to Art. 30 DSGVO)

The following overview documents the essential processing activities of NeuroPraxis Kleinmachnow:

  1. Website operation – Data subjects: website visitors. Data: IP address, access data, browser type. Legal basis: Art. 6 para. 1 lit. f DSGVO. Retention period: 14 days (access logs). Processors: AWS (Amplify, CodeCommit). Data location: EU (Frankfurt, eu-central-1).

  2. Email communication – Data subjects: patients, inquirers. Data: name, email, message content. Legal basis: Art. 6 para. 1 lit. b/f DSGVO. Retention period: after fulfillment of purpose (general inquiries at the latest after 6 months; tax-relevant emails 6–10 years under AO/HGB; medically relevant content is transferred to the patient file, the email is subsequently deleted). Processor: mailbox.org (data location Germany). Former processor: AWS WorkMail (data location EU Ireland, shut down on 18 April 2026).

  3. Email archiving – Data subjects: patients, inquirers (senders/recipients of business emails). Data: email content, sender/recipient addresses, subject, attachments. Legal basis: Art. 6 para. 1 lit. c DSGVO (legal obligation pursuant to § 147 AO, § 630f para. 3 BGB). Retention period: 10 years, automatic deletion thereafter. Processor: AWS (S3 Glacier Deep Archive). Data location: EU (Stockholm, eu-north-1). Encryption: AES-256 (SSE-S3). Details: see Email archiving.

  4. Online appointment booking – Data subjects: patients. Data: name, contact details, address, appointment request. Legal basis: Art. 6 para. 1 lit. b DSGVO. Retention period: until completion of treatment + 10 years. Processor: medatixx (x.webtermin).

  5. Patient administration (practice software) – Data subjects: patients. Data: health data, medical history, findings, treatment plans. Legal basis: Art. 9 para. 2 lit. h DSGVO, § 22 BDSG. Retention period: 10 years after completion of treatment. Processors: medatixx (practice software), Doctago (IT operations).

  6. Billing – Data subjects: patients. Data: billing data, insurance data. Legal basis: Art. 6 para. 1 lit. c DSGVO. Retention period: 10 years (tax law). Recipient: KV Brandenburg (KVBB).

  7. Telephone communication (SIP/VoIP) – Data subjects: patients, inquirers. Data: telephone numbers, connection data. Legal basis: Art. 6 para. 1 lit. b/f DSGVO. Retention period: pursuant to TDDDG at the provider. The telecommunications provider acts on its own responsibility (no DPA).

  8. Personnel administration – Data subjects: employees. Data: name, address, social security number, salary data. Legal basis: § 26 BDSG, Art. 6 para. 1 lit. b DSGVO. Retention period: 10 years after end of employment.

  9. AI-assisted documentation (Noa Notes) – Data subjects: patients (only with explicit consent). Data: audio recording of the doctor-patient conversation, derived transcript, structured documentation entry. Legal basis: Art. 9 para. 2 lit. a DSGVO (explicit consent) in conjunction with Art. 9 para. 2 lit. h DSGVO. Retention period: audio is deleted after transcription, transcript is deleted after creation of the structured entry, approved documentation entry 10 years (§ 630f para. 3 BGB). Processor: Jameda GmbH (Docplanner group), Munich. Data location: Germany/EU. ISO/IEC 27001 certified, BSI C5 attested. Details: see AI-assisted documentation.

The complete record of processing activities is maintained internally within the practice and made available to the competent supervisory authority upon request.

Overview of processors (Art. 28 DSGVO)

  • Amazon Web Services EMEA SARL (Luxembourg) – website hosting (Amplify), source code management (CodeCommit), email archiving (S3 Glacier Deep Archive, data location EU Stockholm, eu-north-1). Formerly also email communication (WorkMail, shut down on 18 April 2026). DPA: AWS GDPR DPA. Data location: EU (Frankfurt, eu-central-1; Stockholm, eu-north-1).
  • mailbox.org / Heinlein Support GmbH (Schwedter Str. 8/9B, 10119 Berlin) – email communication. DPA pursuant to Art. 28 DSGVO. Data location: Germany.
  • medatixx GmbH & Co. KG (Eltville/Rhein) – practice software, online appointment booking. DPA reviewed by the Hessian Data Protection Commissioner (2022). § 203 StGB: yes. Data location: local (practice) / Azure EU.
  • Doctago GbR (Schönefeld) – IT services, system maintenance. DPA pursuant to Art. 28 DSGVO. § 203 StGB: yes. Data location: EU.
  • Jameda GmbH / Docplanner group (Munich) – AI-assisted documentation (Noa Notes, only with explicit consent). DPA pursuant to Art. 28 DSGVO. § 203 para. 4 StGB (persons contributing to a professional secrecy holder): yes. ISO/IEC 27001 certified (equivalent to BSI C5 Type 2 according to the C5 equivalence regulation). Data location: Germany/EU.

All processors have been carefully selected and reviewed for compliance with the GDPR (DSGVO). The DPAs are reviewed regularly and updated as needed.

Data protection impact assessment (Art. 35 DSGVO)

Due to the processing of special categories of personal data (health data, Art. 9 DSGVO), a data protection impact assessment (DPIA) was carried out for the following processing activities:

  • Patient administration in the practice software (medatixx): processing of health data as part of neurological diagnostics and treatment
  • Electronic patient communication (mailbox.org): email communication with patients
  • Telephone communication (SIP/VoIP): connection data at the telecommunications provider in combination with the practice identity as a specialist neurology practice
  • AI-assisted documentation (Noa Notes, only with explicit consent): recording and processing of doctor-patient conversations to support documentation

The DPIA has shown that the implemented technical and organizational measures (TOM) reduce the risk to the rights and freedoms of the data subjects to an appropriate level. The DPIA is documented internally within the practice and reviewed regularly.

General information and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We point out that data transmission over the internet (e.g. when communicating by email) can have security gaps. Complete protection of data against access by third parties is not possible.

Retention period

Unless a more specific retention period has been stated within this privacy policy, your personal data will remain with us until the purpose for the data processing ceases to apply. If you assert a legitimate request for deletion or revoke consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g. retention obligations under tax or commercial law); in the latter case, deletion takes place after these reasons cease to apply.

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

Insofar as you have consented to the data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO, insofar as special categories of data pursuant to Art. 9 para. 1 DSGVO are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 para. 1 lit. a DSGVO. Insofar as you have consented to the storage of cookies or to access to information on your terminal device (e.g. via device fingerprinting), the data processing is additionally carried out on the basis of § 25 para. 1 TDDDG. 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 para. 1 lit. b DSGVO. Furthermore, we process your data insofar as it is required to fulfill a legal obligation on the basis of Art. 6 para. 1 lit. c DSGVO. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6 para. 1 lit. f DSGVO. Information on the respective legal bases applicable in each individual case is provided in the following paragraphs of this privacy policy.

Revocation of your consent to data processing

Many data processing operations are only possible with your explicit consent. You can revoke consent already given at any time. The lawfulness of the data processing carried out up to the revocation remains unaffected by the revocation.

Right to object to the collection of data in special cases and to direct advertising (Art. 21 DSGVO)

IF THE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 PARA. 1 LIT. E OR F DSGVO, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21 PARA. 1 DSGVO).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH ADVERTISING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT ADVERTISING (OBJECTION PURSUANT TO ART. 21 PARA. 2 DSGVO).

Right to lodge a complaint with the competent supervisory authority

In the event of violations of the GDPR (DSGVO), data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, their place of work or the place of the alleged violation. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.

Competent supervisory authority:

Die Landesbeauftragte für den Datenschutz und für das Recht auf Akteneinsicht Brandenburg Stahnsdorfer Damm 77 14532 Kleinmachnow Phone: +49 33203 356-0 Website: www.lda.brandenburg.de

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. Insofar as you request the direct transfer of the data to another controller, this will only be done to the extent that it is technically feasible.

Information, deletion and correction

Within the framework of the applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients and the purpose of the data processing and, if applicable, a right to correction or deletion of this data. You can contact us at any time regarding this as well as other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time regarding this. The right to restriction of processing exists in the following cases:

  • If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
  • If the processing of your personal data happened/is happening unlawfully, you can request the restriction of data processing instead of deletion.
  • If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
  • If you have lodged an objection pursuant to Art. 21 para. 1 DSGVO, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of an important public interest of the European Union or a member state.

Additional information on data processing

Contact and communication

If you contact us by email, phone or fax, your information will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

The processing is carried out on the basis of Art. 6 para. 1 lit. b DSGVO (contract fulfillment/pre-contractual measures) or Art. 6 para. 1 lit. f DSGVO (legitimate interest). The data remains with us until the purpose ceases to apply or you request its deletion. Statutory retention obligations remain unaffected.

Please do not send us any sensitive health data by email. For details on email encryption, see Email communication.

Telephone communication (SIP/VoIP)

For the practice’s telephone availability, we use a telephone connection based on SIP/VoIP (Voice over IP). The telecommunications provider provides an independent telecommunications service here and is not a processor bound by instructions within the meaning of Art. 28 DSGVO. It is subject to the Telecommunications Digital Services Data Protection Act (Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz, TDDDG) and processes traffic data on its own responsibility.

Note on connection data: Connection data (telephone numbers, time, duration of the call) may be generated at the practice’s telephone provider as well as at the caller’s telephone provider. This traffic data is subject to telecommunications secrecy (§ 3 TDDDG) and is processed by the respective provider exclusively for billing purposes or fault clearance on the basis of legal obligations.

The processing of your contact data by the practice as part of telephone communication is carried out on the basis of Art. 6 para. 1 lit. b DSGVO (contract fulfillment/pre-contractual measures) or Art. 6 para. 1 lit. f DSGVO (legitimate interest in the practice’s availability).

Data protection officer

NeuroPraxis Kleinmachnow employs fewer than 20 persons who are regularly involved in the automated processing of personal data. The appointment of a data protection officer is therefore currently not mandatory pursuant to § 38 BDSG. Compliance with data protection requirements is ensured by the practice owner.

Declarations of consent

The processing of patient data as part of medical treatment is provided for by law and does not require separate consent. The explicit consent of the patient is obtained when:

  • findings or medical letters are to be transmitted to physicians providing further treatment
  • data is passed on to third parties who are not directly involved in the treatment
  • a release from confidentiality obligations toward insurers, employers or other bodies is desired

Declarations of consent always contain a reference to the right of revocation at any time. Consents given are documented in the patient file.

Patient information on data protection in the practice

Pursuant to Art. 13 DSGVO, we inform patients about the processing of their personal data. This information may be provided through:

  • A notice posted in the practice premises
  • An information sheet in the waiting room
  • This privacy policy on our website

Personal information at the time of first contact or a signature for confirmation is not required.

Data protection incident and reporting obligation (Art. 33/34 DSGVO)

In the event of a breach of the protection of personal data (data protection incident), the following rules apply:

  • Every data protection incident is documented without delay
  • The practice owner checks whether there is a risk to the rights and freedoms of the data subjects
  • In the event of such a risk, a report is made to the competent supervisory authority (LDA Brandenburg) within 72 hours of becoming aware of it (Art. 33 DSGVO)
  • In the event of a high risk, the affected persons are additionally informed without delay (Art. 34 DSGVO)
  • Countermeasures are initiated and documented

Data protection incidents include, among others: loss of data carriers or devices, unauthorized access to patient data, hacker attacks, accidental disclosure of data to unauthorized persons.

Discretion and access protection in the practice

To protect the privacy of our patients, we have taken the following organizational measures:

  • Confidential doctor-patient conversations always take place in closed rooms
  • Discretion is observed at the reception
  • For telephone inquiries, the identity of the caller is verified through targeted follow-up questions
  • All computers are password-protected and equipped with automatic screen locks
  • Patient documents are positioned so that they cannot be viewed by other patients
  • Patient files are kept under lock and key when unattended

Deletion and destruction of data

Personal data is deleted as soon as the purpose of the processing ceases to apply and no statutory retention obligations conflict. Paper documents are destroyed in accordance with DIN 66399 (security level P-4 or higher), digital data carriers are securely deleted or physically destroyed in accordance with DIN 66399.

As of: 2026-07-04