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Privacy policy


With the following data protection declaration, we would like to inform you about which types of your personal data (hereinafter also referred to as “data”) we process for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
The terms used are not gender-specific.
As of September 14, 2020


  • introduction
  • person in charge
  • Overview of processing
  • Relevant legal bases
  • Security measures
  • Transmission and disclosure of personal data
  • Use of cookies
  • Provision of the online offer and web hosting
  • Contact
  • Plugins and embedded functions as well as content
  • Deletion of data
  • Changes and updates to the Privacy Policy
  • Rights of data subjects
  • Definitions

Person in charge

Britta de Clercq
CEO and Owner of Frühförder- I Therapiezentrum de Clercq GmbH,
Frühförder- I Therapiezentrum de Clercq GmbH
Flachsland 23
22083 Hamburg

E-mail address: info@frueh-foerdern.de

Imprint: /imprint/

Overview of processing

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

Types of data processed

  • Inventory data (e.B. names, addresses).
  • Content data (e.B. text input, photographs, videos).
  • Contact details (e.B. e-mail, telephone numbers).
  • Meta/communication data (e.B. device information, IP addresses).
  • Usage data (e.B websites visited, interest in content, access times).

Categories of data subjects

  • Communication.
  • Users (e.B. website visitors, users of online services).

Purposes of processing

  • Provision of our online offer and user-friendliness.
  • Contact requests and communication.
  • Contractual services and service.

Relevant legal bases

In the following, we inform you of the legal bases of the General Data Protection Regulation (GDPR), on the basis of which we process the personal data. Please note that in addition to the provisions of the GDPR, the national data protection requirements may apply in your or our country of residence and domicile. If, in addition, more specific legal bases are decisive in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 sentence 1 lit. a GDPR) – The data subject has given their consent to the processing of personal data concerning them for a specific purpose or for several specific purposes.
  •  – The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – The processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data prevail.

National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. This includes, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states can be applied.

Security measures

In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
Measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to the threat to the data. Furthermore, we take into account the protection of personal data already during the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission and disclosure of personal data

As part of our processing of personal data, it happens that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

Data transfer within the organization:: We may transfer personal data to other entities within our organization or grant them access to this data. If this transfer takes place for administrative purposes, the transfer of the data is based on our legitimate business and business interests or takes place if it is necessary to fulfil our contractual obligations or if there is a consent of the persons concerned or a legal permission.

Use of cookies

Cookies are text files that contain data from websites or domains visited and are stored by a browser on the user’s computer. A cookie is primarily used to store the information about a user during or after his visit within an online offer. The stored information may include for example, the language settings on a website, the login status, a shopping cart or the place where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.B. when user information is stored on the basis of pseudonymous online identifiers, also referred to as “user IDs”)

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for range measurement or marketing purposes may be stored in such a cookie.
  • First-party cookies: First-party cookies are set by ourselves.
  • Third-party cookies (also: third-party cookies):: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or strictly necessary) cookies: Cookies may be strictly necessary for the operation of a website (e.B. to store logins or other user input or for security reasons).
  • Statistics, marketing and personalizationcookies:: Furthermore, cookies are usually also used in the context of reach measurement and when the interests of a user or his behavior (e.B viewing certain content, use of functions, etc.) are stored on individual websites in a user profile. Such profiles serve to show users content that corresponds to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or as part of obtaining consent.

Information on legal bases:The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (i.e. in the business operation of our online offer and its improvement) or if the use of cookies is necessary to fulfil our contractual obligations.

Storage period:  If we do not provide you with explicit information on the storage period of permanent cookies (i.e. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out):Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke a given consent or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can first declare your objection by means of the settings of your browser, i.e., by deactivating the use of cookies (whereby this may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ In addition, you can receive further objection notices in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis ofconsent: Before we process or have processed data in the context of the use of cookies, we ask users for consent that can be revoked at any time. Until consent has been given, cookies are used that are absolutely necessary for the operation of our online offer.

  • Types of data processed: Usage data (i.e. websites visited, interest in content, access times), meta/communication data (i.e. device information, IP addresses).
  • Data subjects: Users (i.e. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Provision of the online offer and web hosting

In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be retrieved. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.

The data processed in the context of the provision of the hosting offer may include all information concerning the users of our online offer that arises in the context of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

E-mail sending and hosting: The web hosting services used by us also include the sending, receiving and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information regarding the e-mail dispatch (i.e. the providers involved) as well as the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purposes of detecting SPAM. Please note that e-mails on the Internet are generally not sent encrypted. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of the e-mails between the sender and the receipt on our server.

Collection of access data and logfiles: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the accessed websites and files, date and time of retrieval, data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used on the one hand for security purposes, i.e. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability.

  • Types of data processed: Content data (i.e. text input, photographs, videos), usage data (e.B. websites visited, interest in content, access times), meta/communication data (e.B. device information, IP addresses).
  • Data subjects: Users (i.e. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).


When contacting us (i.e. via contact form, e-mail, telephone or via social media), the details of the requesting persons will be processed insofar as this is necessary to answer the contact requests and any requested measures.

The answer to contact requests in the context of contractual or pre-contractual relationships takes place to fulfil our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.

  • Types of data processed: Inventory data (i.e. names, addresses), contact data (i.e. e-mail, telephone numbers), content data (i.e. text inputs, photographs, videos).
  • Data subjects: communication partners.
  • Purposes of processing: contact requests and communication.
  • Legal basis: Performance of the contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit.b. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Plugins and embedded functions as well as content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may be, for example, graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the presentation of this content or functions. We endeavor to use only such content whose respective providers use the IP address only to deliver the content. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and contain, among other things, technical information about the browser and the operating system, to referring websites, the time of visit and other information on the use of our online offer as well as be combined with such information from other sources.

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

  • Types of data processed:Usage data (i.e. websites visited, interest in content, access times), meta/communication data (i.e. device information, IP addresses).
  • Data subjects: Users (i.e. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, contractual services and service.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

  • Font Awesome: display of fonts and symbols; Service provider: Fonticons, Inc. ,6 Porter Road Apartment 3R, Cambridge, MA 02140, USA; Website: https://fontawesome.com/; Privacy Policy: https://fontawesome.com/privacy.
  • Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the data of the users are used solely for the purpose of displaying the fonts in the browser of the users. The integration takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website https://fonts.google.com/; Privacy Policy:  https://policies.google.com/privacy.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions are omitted (i.e. if the purpose of the processing of this data has ceased to exist or they are not necessary for the purpose).

If the data is not deleted because it is necessary for other and legally permissible purposes, their processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example to data that must be stored for commercial or tax reasons or whose storage is necessary for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can also be provided in the context of the individual data protection information of this data protection declaration.

Changes and updates to the Privacy Policy

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the privacy policy as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (i.e. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that the addresses may change over time and ask you to check the information before contacting us.

Rights of data subjects

As a data subject, you are entitled to various rights under the GDPR, which result in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you on the basis of Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is related to such direct advertising.
  • Right of revocation for consents: You have the right to revoke your consent at any time.
  • Right to information: You have the right to request confirmation as to whether the data in question is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification:  In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be deleted immediately or, alternatively, to demand a restriction of the processing of the data in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request their transmission to another controller.
  • Complaint to the supervisory authority: In accordance with the legal requirements, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of your personal data infringes the GDPR.


This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to serve the purpose of understanding. The terms are sorted alphabetically.

  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (i.e. cookie) or to one or more special features that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations performed on personal data, with or without the aid of automated procedures. The term goes far and covers practically every handling of data, be it the collection, evaluation, storage, transmission or deletion.

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