Privacy Policy pursuant to Art. 13 GDPR

1. Data protection at a glance

General information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data means any data that can be used to personally identify you. Detailed information on data protection can be found in the privacy policy set out 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 Clara Strubakis.

How do I collect your data?

Your data is collected, on the one hand, when you provide it to us. This may, for example, include data that you enter into a booking form.

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

What do I use your data for?

Some of the data is collected to ensure the error-free provision of the website. If you book an appointment with me via this website, this constitutes a contractual relationship for which I require your personal data in order to process and manage the appointment.

What rights do you have regarding your data?

You have the right at any time to receive free information 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 may revoke this consent at any time with effect for the future. Furthermore, you have the right, under certain circumstances, to request the restriction of processing of your personal data. You also have the right to lodge a complaint with the competent supervisory authority.

Hierzu sowie zu weiteren Fragen zum Thema Datenschutz können Sie sich jederzeit an mich wenden.

2. Hosting

I host the content of my website with the following provider:

All-Inkl

The provider is ALL-INKL.COM – Neue Medien Münnich, owner René Münnich, Hauptstraße 68, 02742 Friedersdorf (hereinafter “All-Inkl”). For details, please refer to All-Inkl’s privacy policy: [https://all-inkl.com/datenschutzinformationen/](https://all-inkl.com/datenschutzinformationen/).

The use of All-Inkl is based on Art. 6(1)(f) GDPR. We have a legitimate interest in ensuring the most reliable possible presentation of our website. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be withdrawn at any time.

Data processing agreement (processor agreement)

I have concluded a data processing agreement (DPA) for the use of the service mentioned above. This is a contract required under data protection law, which ensures that the provider processes the personal data of visitors to this website only in accordance with my instructions and in compliance with the GDPR.

3. General information and mandatory notices

Data protection

As the operator of these pages, I take the protection of your personal data very seriously. I treat your personal data as confidential and in accordance with the statutory data protection regulations, this privacy policy, and the Austrian Psychotherapy Act 2024 (link).

When you use this website, various personal data is collected. Personal data is data with which you can be personally identified. This privacy policy explains which data is collected and how it is used. It also explains how and for what purpose this is done.

Please note that data transmission over the internet (e.g. communication by email) may have security vulnerabilities. Complete protection of data from access by third parties is not possible.

Information on the responsible party

The responsible party for data processing on this website is:

Clara Strubakis
Grillgasse 20/12
1110 Vienna
Austria

Phone: +43 670 60 555 94
E-Mail: clara@strubakis.at

The responsible party is the natural or legal person who alone or jointly with others determines the purposes and means of processing personal data (e.g. names, email addresses, etc.).

Storage period

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with me until the purpose for which it was collected no longer applies. If you submit a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless I have other legally permissible reasons for storing your personal data (e.g. statutory retention periods). In the latter case, deletion will take place once these reasons no longer apply.

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

If you have given consent to data processing, I process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, insofar as special categories of personal data pursuant to Art. 9(1) GDPR 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(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your device (e.g. via device fingerprinting), data processing is additionally based on § 25(1) TDDDG. Consent can be withdrawn at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, I process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, I process your data if this is necessary to comply with a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also take place on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. The relevant legal bases applicable in each individual case are explained in the following paragraphs of this privacy policy.

Note on data transfer to third countries not considered secure under data protection law and to U.S. companies not certified under the EU–U.S. Data Privacy Framework (DPF)

I use tools (Wordfence) from companies based in third countries that are not considered secure under data protection law, as well as U.S.-based tools whose providers are not certified under the EU–U.S. Data Privacy Framework (DPF). When these tools are active, your personal data may be transferred to and processed in these countries. Please note that in third countries not deemed secure under data protection law, a level of data protection comparable to that of the EU cannot be guaranteed.

I would like to note that the United States is generally considered a secure third country providing a level of data protection comparable to that of the EU. Data transfers to the U.S. are therefore permissible if the recipient is certified under the “EU–U.S. Data Privacy Framework” (DPF) or provides appropriate additional safeguards. Information on transfers to third countries, including the data recipients, can be found in this privacy policy.

Recipients of personal data

In the course of my practice, I work with various external parties. In some cases, this may require the transfer of personal data to such external parties. I only transfer personal data to external parties if this is necessary for the performance of a contract, if I am legally obliged to do so (e.g. disclosure of data to tax authorities), if I have a legitimate interest pursuant to Art. 6(1)(f) GDPR in the transfer, or if another legal basis permits such disclosure. When using data processors, I only transfer clients’ personal data on the basis of a valid data processing agreement. In the case of joint processing, a joint controllership agreement is concluded.

In concrete terms, this means for you:
I handle your data with the utmost care. Data is only shared with services that are strictly necessary for the operation of my practice (e.g. my IT hosting provider All-Inkl in Germany or the secure practice software Psido). All partners are contractually bound to strict data protection requirements.

Withdrawal of your consent to data processing

Many data processing operations are only possible with your explicit consent. You may withdraw consent you have already given at any time. The lawfulness of data processing carried out up to the point of withdrawal remains unaffected.

Right to object to data collection in specific cases and to direct marketing (Art. 21 GDPR)

IF DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA; 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, I WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED, UNLESS I CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

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

Right to lodge a complaint with the competent supervisory authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or the place of the alleged infringement. This right of complaint exists without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to receive data that I process automatically on the basis of your consent or in fulfilment of a contract, in a commonly used, machine-readable format, either for yourself or for a third party. If you request the direct transfer of the data to another controller, this will only be done where technically feasible.

Access, rectification and erasure

Under the applicable legal provisions, you have the right at any time to receive free information about your stored personal data, its origin, recipients, and the purpose of data processing, as well as, where applicable, the right to rectification or erasure of this data. For this purpose, and for any further questions regarding personal data, you may contact me at any time.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You may contact me at any time to do so. The right to restriction of processing applies in the following cases:

  • If you contest the accuracy of the personal data stored by me, I generally require time to verify this. For the duration of the verification, you have the right to request the restriction of processing of your personal data.
  • If the processing of your personal data was/is unlawful, you may request the restriction of data processing instead of erasure.
  • If I no longer need your personal data, but you require it for the establishment, exercise, or defence of legal claims, you have the right to request the restriction of processing of your personal data instead of erasure.
  • If you have lodged an objection pursuant to Art. 21(1) GDPR, a balancing of interests must be carried out between your interests and mine. 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, such data – apart from being stored – may only be processed with your consent, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.

SSL / TLS encryption

For security reasons and to protect the transmission of confidential content, such as appointment bookings or inquiries that you send to me as a psychotherapist in training under supervision, this website uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the browser’s address bar changes from “http://” to “https://” and by the padlock symbol in your browser’s address bar.

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

Objection to advertising emails

The use of contact data published in the context of the legal notice obligation for the purpose of sending unsolicited advertising and information materials is hereby objected to. The operator of this website expressly reserves the right to take legal action in the event of unsolicited sending of advertising information, for example through spam emails.

4. Data collection on this website

Server log files

The provider of the website automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These include:

  • Browser type and browser version
  • operating system used
  • Referrer URL
  • hostname of the accessing computer
  • time of the server request
  • IP-Adress

This data is not merged with other data sources.

The collection of this data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of the website; for this purpose, server log files must be collected.

Contact form / booking form

If you send me enquiries via the contact form, the information you provide in the booking form, including the contact details you enter there, will be stored by me for the purpose of processing your request and in case of follow-up questions. I do not pass on this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR, insofar as your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on my legitimate interest in the effective handling of enquiries addressed to me (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), if such consent has been requested; consent can be withdrawn at any time.

The data you enter in the contact form will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your enquiry has been fully processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Online appointment booking (Latepoint)

To make appointment scheduling as easy as possible for you, I offer an online booking function on my website. For this purpose, I use the tool “Latepoint”. When you book an appointment, the data you enter (such as name, email address, and telephone number) is transmitted to me in encrypted form. I use this data exclusively to coordinate the appointment with you and to contact you in case of any follow-up questions. The legal basis is the initiation of a treatment relationship or my legitimate interest in efficient appointment management (Art. 6(1)(b) and (f) GDPR).

Enquiry by email or telephone

If you contact me by email or telephone, your enquiry, including all resulting personal data (such as name, enquiry, etc.), will be stored and processed by me for the purpose of handling your request. I do not pass on this data without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR, insofar as your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on my legitimate interest in the effective handling of enquiries addressed to me (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), if such consent has been requested; consent can be withdrawn at any time.

The data you send to me via enquiries will remain with me until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your enquiry has been fully processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Professional client management (Psido)

For the secure management of my client data and for legally required documentation, I use “Psido”, a specialised software for psychotherapists. All data is stored there in encrypted form according to state-of-the-art security standards and on servers within the EU. I have concluded a data processing agreement with the provider, ensuring that your data is treated strictly confidentially and only in accordance with my instructions.

Important: Psido also enables me to synchronise my calendar in an anonymised way (see section “Google Calendar”), so that no conclusions about your identity can be drawn from it.
 

5. Plugins and Tools

Appointment scheduling with Google Calendar

To allow me to organise appointments efficiently, I use “Google Calendar”. When you request or book an appointment via my website, the key details (date, time, and type of session) are transferred to my calendar. Important for your trust: No names or sensitive client data are transmitted to Google. The “Google Calendar” is used exclusively for scheduling purposes. The transfer takes place in encrypted form directly from my website to Google. The legal basis for this is my legitimate interest in smooth practice organisation (Art. 6(1)(f) GDPR). Details on Google’s data protection can be found at [https://policies.google.com/privacy](https://policies.google.com/privacy).

Wordfence

I have integrated Wordfence into this website. The provider is Defiant Inc., Defiant, Inc., 800 5th Ave Ste 4100, Seattle, WA 98104, USA (hereinafter “Wordfence”).

Wordfence is used to protect this website from unwanted access or malicious cyberattacks. For this purpose, this website establishes a permanent connection to Wordfence’s servers so that Wordfence can compare its databases with access attempts on our website and, if necessary, block them.

The use of Wordfence is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the most effective possible protection of the website against cyberattacks. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be withdrawn at any time.

Data transfers to the United States are based on the European Commission’s Standard Contractual Clauses. Further details can be found here: [https://www.wordfence.com/help/general-data-protection-regulation/].

Data processing agreement (processor agreement)

I have concluded a data processing agreement (DPA) for the use of the service mentioned above. This is a contract required under data protection law, which ensures that the provider processes the personal data of visitors to this website only in accordance with my instructions and in compliance with the GDPR.

Quelle: https://www.e-recht24.de

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