Owner of this website

Helmuth Jarchow, Heilwigstraße 34, 20249 Hamburg
E-Mail: jarchow@reality-made.com
Telefon: +49 172 8000 666

Payers GmbH, CEO Helmuth Jarchow + Dr. Ulf Maywald, Ust-ID DE 258703562, AG HH HRB 147409
Payersdata GmbH, CEO Helmuth Jarchow, Ust-ID DE 301671811, AG HH HRB 142618
Pagency GmbH, CEO Helmuth Jarchow, Ust-ID DE 345500781, AG HH HRB 170548

PRIVACY POLICY

With this privacy policy, we, health system creativity, Helmuth Jarchow, Heilwigstraße 34, 20249 Hamburg, inform you about the personal data we collect, process and use when you use our website.
"Personal data" means any information relating to an identified or identifiable natural person, such as your name, address, email address or date of birth.

1. Responsible

The responsible party for the collection, processing and use of your personal data within the meaning of Art. 4 No. 7 DSGVO is health system creativity, Innocentiastraße 14, 20149 Hamburg represented by the Managing Director Helmuth Jarchow.

If you wish to object to the collection, processing or use of your data by us in accordance with these data protection provisions, either in whole or for individual measures, you can address your objection to the person responsible.

2. General purposes of the processing

We use personal data for the purpose of operating the website www.healthsystemcreativity.com.

2.1. When visiting the website

Each time a customer (or other visitor) accesses our website, information is automatically sent to the server of our website by the internet browser used on your end device (computer, laptop, tablet, smartphone, etc.). This information is temporarily stored in a so- called log file.

The following data is collected without your intervention and stored until automated deletion:

• IP address of the requesting computer, as well as device ID or individual device identifier and device type,
• Name of the file retrieved and amount of data transferred, as well as date and time of retrieval,
• Message about successful retrieval,
• requesting domain,
• Description of the type of Internet browser used and, if applicable, the operating system of your terminal device, as well as the name of your access provider,
• Your browser history data as well as your default weblog information, location data, including location data from your mobile device. Please note that most mobile devices allow you to control or disable the use of location services in the settings menu of the mobile device.

Our legitimate interest according to Art. 6 para. 1 p. 1 lit. f DSGVO to collect the data is based on the following purposes:
Ensuring a smooth connection and comfortable use of the website,
Evaluation of system security and stability and for other administrative purposes.

In no case do we use the collected data for the purpose of drawing conclusions about your person. The information is stored exclusively for the purposes of technical administration of our website. It is not passed on to third parties. We reserve the right to check the log data retrospectively if there is a justified suspicion of unlawful use due to concrete indications.

2.2. Data for the fulfilment of our contractual obligations

We process personal data that we need to fulfil our contractual obligations, such as

• Name,
• Address,
• E-mail address,
• Products,
• Invoice and payment data.

The collection of this data is necessary for the conclusion of the contract.

The deletion of the data takes place after the expiry of the warranty periods and legal retention periods.

The legal basis for the processing of this data is Art. 6 para. 1 p. 1 b) DSGVO, because this data is required so that we can fulfil our contractual obligations towards you.

2.3. When using our contact form or contacting us by e-mail

When you contact us by e-mail or via a contact form, the data you provide (your e-mail address, name and telephone number) will be stored by us in order to answer your questions. Further information can be provided voluntarily.

Data processing for the purpose of contacting us is carried out in accordance with Art. 6 para. 1 p. 1 lit. a DSGVO on the basis of your voluntarily given consent.

The personal data collected by us for the use of the contact form will be automatically deleted after completion of your request.

3. Disclosure of personal data

Your data will not be transferred to third parties for purposes other than those listed below. We will only share your data with third parties if:

• you have given your express consent to this in accordance with (Art. 6 para. 1 p. 1 lit. a DSGVO),
• this is necessary for the processing of contractual relationships with you (Art. 6 para. 1 lit. b DSGVO),
• there is a legal obligation to disclose the data (Art.6 para.1 lit. c DSGVO),
• the disclosure is necessary for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data (Art. 6 para. 1 p. 1 lit. f DSGVO).

In these cases, however, the scope of the transmitted data is limited to the necessary minimum.

4. Your rights as a data subject

Under the applicable laws, you have various rights regarding your personal data. If you wish to exercise these rights, please send your request by e-mail or by post, clearly identifying yourself, to the address mentioned in point 1. Below you will find an overview of your rights.

a) Right to confirmation and information

You have the right to receive clear information about the processing of your personal data.

In detail:
You have the right to obtain confirmation from us at any time as to whether personal data relating to you is being processed. If this is the case, you have the right to request information from us free of charge about the personal data stored about you, together with a copy of this data.

Furthermore, there is a right to the following information:

• the purposes of processing;
• the categories of personal data that are processed;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organisations;
• if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration;
• the existence of a right to rectification or erasure of personal data concerning you or to restriction of processing by the controller or a right to object to such processing;
• the existence of a right of appeal to a supervisory authority;
• if the personal data is not collected from you, all available information about the origin of the data;
• the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and - at least in these cases - meaningful information about the logic involved and the scope and intended effects of such processing for you.

If personal data are transferred to a third country or to an international organisation, you have the right to be informed about the appropriate safeguards pursuant to Art. 46 of the GDPR in connection with the transfer.

b) Right of rectification

You have the right to demand that we correct and, if necessary, complete personal data relating to you..
You have the right to request that we correct any inaccurate personal data relating to you without undue delay. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary declaration.

c) Right to erasure ("right to be forgotten")

In a number of cases we are obliged to delete personal data relating to you.
Pursuant to Article 17(1) of the GDPR, you have the right to request that we delete personal data relating to you without undue delay and we are obliged to delete personal data without undue delay if one of the following reasons applies:

• The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
• You revoke your consent on which the processing was based pursuant to Art. 6 (1) p. 1 a) DSGVO or Art. 9 (2) a) DSGVO and there is no other legal basis for the processing.
• You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR.
• The personal data have been processed unlawfully.
• The deletion of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which we are subject.
• The personal data have been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR. a) Right to restriction of processing

In a number of cases, you are entitled to request that we restrict the processing of your personal data. You have the right to request us to restrict processing if:

• the accuracy of the personal data is contested by you for a period of time that enables us to verify the accuracy of the personal data,
• the processing is unlawful and you refused to erase the personal data and instead requested the restriction of the use of the personal data;
• we no longer need the personal data for the purposes of processing, but you need the data to assert, exercise or defend legal claims, or
• you have objected to the processing pursuant to Art. 21 (1) DSGVO, as long as it has not yet been determined whether the legitimate reasons of our company outweigh yours.

d) Right to data portability

You have the right to obtain, transmit or have us transmit personal data relating to you in machine-readable form.
You have the right to receive the personal data relating to you that you have provided to us in a structured, commonly used and machine-readable format, and you have the right to transfer this data to another controller without hindrance from us, provided that

• the processing is based on consent pursuant to Art. 6 para. 1 sentence 1 a) DSGVO or Art. 9 para. 2 a) DSGVO or on a contract pursuant to Art. 6 para. 1 sentence 1 b) DSGVO and
• the processing is carried out with the aid of automated procedures.
• When exercising your right to data portability in accordance with paragraph 1, you have the right to obtain that the personal data be transferred directly from us to another controller, where this is technically feasible.

e) Right of objection

You also have the right to object to lawful processing of your personal data by us if this is based on your particular situation and our interests in the processing are not overriding.
You have the right to object on grounds at any time to the processing of your personal data which is carried out on the basis of Art. 6 (1) p. 1 e) or f) DSGVO; this also applies to profiling based on these provisions. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims.
If personal data is processed by us for the purpose of direct advertising, you have the right to object at any time to processing for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising.
You have the right to object to processing carried out for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) DSGVO, unless the processing is necessary for the performance of a task carried out in the public interest.

f) Right to revoke consent under data protection law

You have the right to withdraw consent to the processing of personal data at any time.

g) Right to complain to a supervisory authority

You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you is unlawful.

5. Data security

We are concerned about the security of your data within the framework of the applicable data protection laws and technical possibilities.
Your personal data is transmitted encrypted with us. This applies to your orders and also to the customer login. We use the SSL (Secure Socket Layer) coding system, but we would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.
To secure your data, we maintain technical and organisational security measures in accordance with Art. 32 DSGVO, which we continually adapt to the state of the art.

6. Cookies

WWe use cookies on our website. Cookies are small files with configuration information that are stored on your terminal device. Cookies can basically be divided into three categories. There are cookies that are essential for the functionality of the website (so-called function cookies), cookies that increase the comfort of a website visit and, for example, save your language settings (so-called comfort cookies) and cookies on the basis of which a pseudonymised usage profile is created (so-called tracking cookies). Only function and tracking cookies are provided for this website.
The processing of the function cookies is necessary to enable you to visit the website (cf. Art. 6 para. 1 lit. b DSGVO).
Tracking cookies are only set if the website visitor has consented to this (Art. 6 para. 1 lit. a DSGVO). Consent is given via the so-called cookie banner, which must be actively clicked on.

7. Analysis tools

The tracking measures listed below and used by us are carried out on the basis of Art. 6 para. 1 sentence 1 lit. f DSGVO, § 15 para. 3 TMG. With the tracking measures used, we want to ensure a needs-based design and the ongoing optimisation of our website. On the other hand, we use the tracking measures to statistically record the use of our website and to evaluate it for the purpose of optimising our offer for you. These interests are to be regarded as legitimate within the meaning of the aforementioned provision.

a) Google Analytics

This website uses the web analysis tool "Google Analytics", which is offered as a service by Google Ireland Limited. The purpose of its use is the "needs-based design" of this website, which is carried out on the basis of a weighing of interests. The web analysis also enables us to detect and correct errors on the website, e.g. due to faulty links. Google Analytics uses so- called "cookies". These are text files that are stored on your computer and enable an analysis of your use of the website. So-called "client IDs" are used, which are used to create pseudonymous usage profiles that record the use of the internet pages by desktop computers and mobile devices by a user together.
The information generated by the cookie about your use of this website is generally transmitted to a Google server in the USA and stored there. Since we have activated so-called IP anonymisation on this website and concluded a corresponding order processing agreement with Google, your IP address will, however, be truncated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google in the USA is certified according to the so-called "Privacy Shield" (list entry). Google guarantees an appropriate level of You the generated to your use of the website (incl. your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser add-on available at the following link http://tools.google.com/dlpage/gaoptout?hl=de . You may also refuse the use of cookies by selecting the appropriate settings on your browser. Alternatively, you can prevent the collection of data by Google Analytics - especially on mobile devices - by clicking on the following link: Deactivate Google Analytics. An opt- out cookie will then be set, which prevents the future collection of your data when visiting this website. You can find more information on the terms of use of Google Analytics and on data protection information at: https://policies.google.com/privacy

Deactivate Google Analytics (Opt-out)
As an alternative to the browser add-on, please click this link within browsers on mobile devices to prevent Google Analytics from collecting data within this website in the future.

• The opt out only works in this browser and only for this domain
• This places an opt-out cookie on your device.
• If you delete your cookies in this browser, you must click this link again.

b) Google Adwords / Conversion Tracking

We use the Google Ads Conversion offer to draw attention to our attractive offers on external websites with the help of advertising media (so-called Google Ads). We can determine how successful the individual advertising measures are in relation to the data of the advertising campaigns. In this way, we pursue the interest of showing you advertising that is of interest to you, making our website more interesting for you and achieving a fair calculation of advertising costs.
These advertisements are delivered by Google via so-called "ad servers". For this purpose, we use ad server cookies, which can be used to measure certain parameters for measuring success, such as the display of the ads or clicks by users. If you access our website via a Google ad, Google Ads will store a cookie on your end device. These cookies usually lose their validity after 30 days and are not intended to identify you personally. The unique cookie ID, number of ad impressions per placement (frequency) , last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wishes to be addressed) are usually stored as analysis values for this cookie.
These cookies enable Google to recognise your internet browser. If a user visits certain pages of an Ads customer's website and the cookie stored on their computer has not yet expired, Google and the customer will be able to recognise that the user clicked on the ad and was redirected to that page. A different cookie is assigned to each Ads customer. Cookies can therefore not be tracked via the websites of Ads customers. We ourselves do not collect or process any personal data in the aforementioned advertising measures. We only receive statistical evaluations from Google. These evaluations enable us to recognise which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising tools; in particular, we cannot identify users on the basis of this information.
Due to the marketing tools used, your browser automatically establishes a direct connection with Google's server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: Through the integration of Ads Conversion, Google receives the information that you have called up the corresponding part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is still possible for the provider to obtain and store your IP address.

You can prevent participation in this tracking process in various ways:

• by an appropriate setting of your browser software, in particular the suppression of third- party cookies leads to the fact that you do not receive advertisements from third-party providers
• by installing the plug-in provided by Google at the following link: https://www.google.com/settings/ads/plugin;
• by deactivating the interest-based ads of the providers that are part of the self-regulation campaign "About Ads" via the link http://www.aboutads.info/choices, whereby this setting is deleted when you delete your cookies;
• by permanently deactivating it in your Firefox, Internet Explorer or Google Chrome browsers at the link http://www.google.com/settings/ads/plugin,
• by means of the corresponding cookie setting. Please note that in this case you may not be able to use all the functions of this website to their full extent. Lifetime of cookies: up to 180 days (this only applies to cookies set via this website).

Legal basis: Art. 6 (1) a DSGVO (consent)

8. Data protection coordinator

If you still have questions or concerns about data protection, please contact us. info@healthsystemcreativity.com

as of June 2022