Privacy notice

1. Who is responsible?

For the platform

Heiner Fischer
Männerberatung & Prävention
Vom-Bruck-Platz 30
47805 Krefeld
Email: hallo@heinerfischer.de

I operate the platform and am responsible for the website, the directory, the accounts of professionals and the technical operation. No data protection officer has been appointed because the legal requirements for this are not met.

For your counselling

The counselling centre or practice of your counsellor is responsible for everything that is part of your counselling. This includes your room, your messages, your appointments, your pseudonym and your counsellor's case notes. This also applies if the centre documents in-person counselling here (section 5). I process this data on behalf of the centre and according to its instructions (Art. 28 DSGVO). The centre gives you its contact details and the legal basis in its privacy notice. You will find the link on every counsellor profile and when booking.

Depending on the counselling field, counselling deals with health, violence, addiction, sexuality, relationships, family or debt. Much of this information is specially protected (Art. 9 DSGVO), and the platform treats everything else just as confidentially. That is why a pseudonym is enough, content is stored encrypted, and only your counsellor and, if one is assigned, a co-counsellor from the same centre may read it. If a co-counsellor is assigned, their name is shown in your room. The centre lead never reads it.

2. When you visit the website

Hosting and server logs

The platform is hosted by Hostinger International Ltd., 61 Lordou Vironos Street, 6023 Larnaca, Cyprus. The server is located in Germany. A data processing agreement is in place with Hostinger.

Each time a page is accessed, the server briefly stores what your browser sends: IP address, date and time, the page accessed, browser and operating system. This serves security, for example against attacks, and troubleshooting. The legal basis is my legitimate interest in secure operation (Art. 6 Abs. 1 lit. f DSGVO). The logs are deleted after seven days.

No third-party services

The connection is encrypted with TLS. Fonts, drawings and scripts come from our own server. There is no connection to Google Fonts, no trackers, no advertising and no audience measurement.

Cookies

The platform only sets cookies that are technically necessary: a session cookie that keeps you signed in, and a cookie that protects forms against misuse. When signing in, professionals can choose to stay signed in. Another cookie then keeps them signed in for longer. The legal basis is § 25 Abs. 2 Nr. 2 TDDDG in conjunction with Art. 6 Abs. 1 lit. f DSGVO. That is why there is no cookie banner.

Whether you want to see the site in light or dark mode is stored only by your browser (local storage). This choice is not transmitted.

The platform remembers which language you use (German or English) in your session on the server. It takes the language of the page you last opened, or your choice in the language switch. This way, pages without a language in the address, such as the sign in page, also appear in your language. There is no separate cookie for this. The setting ends with the session.

3. Booking a first session and writing anonymously

For a booking, a first message or the waiting list, you need a pseudonym and a password. You do not need a name or an email address.

• The platform stores the password and your recovery code only as a hash. Nobody can read them.
• A short keyword for the booking is optional and is stored encrypted.
• The booked time and the counsellor are also stored.
• With your account, the platform stores the language in which you use it (German or English). At first, this is the language of the page on which you create your account. The pages after you sign in and the emails to you appear in this language. You can change it under “Account and security”.

To protect against spam bookings, your browser solves a small calculation (ALTCHA). This works without cookies and without third-party servers.

Some counsellors also show their free times on their own website. This element only loads the times when you click on it, directly from this platform and without cookies. The server sees your IP address, as with every page request (section 2). To book, you come to this platform.

While you are signed in, the platform stores your IP address and your browser identifier with your session. This makes it possible to detect misuse and to sign out other devices, for example when you change your password. The session ends when you sign out or are inactive for two hours, and is then deleted.

4. Your room

In the room, you write with your counsellor and see your appointments. Messages are stored encrypted. Each message shows who wrote it. If a co-counsellor from the same centre is also counselling you, they read all messages too. Their name is then shown at the top of your room and below the field for your message, and you get a notice by email if you have switched on emails (section 7). The platform's administration does not show any content.

In couples counselling, a second person can get their own account in the same room with their own code, with their own pseudonym and password. You both then see all messages, appointments and whiteboards of the room, and each message shows who wrote it. If one of you deletes their account, their messages go with it, and the room remains for the other person.

Your counsellor can keep case notes about your counselling. They are stored encrypted. Only your counsellor and a co-counsellor from the same centre, if one is assigned, can see them. The centre lead and the office never see them. If your counsellor leaves the centre, the centre lead hands your room over to a colleague without seeing any content. The colleague then sees the case notes.

Once the counselling has ended, you can still read and download your room for 30 days. The room with all messages, appointments and case notes is deleted after the centre's retention period: 6, 12, 24 or 36 months after it is closed. The centre decides which period applies and states it in its privacy notice. At your request, your counsellor can also delete a closed room earlier. Your account disappears with the last room.

You can delete your account yourself at any time, under “Account and security”. Your pseudonym, password, recovery code and email address are then deleted immediately, and you can no longer sign in. Upcoming appointments are cancelled. Your rooms remain closed with the centre, with messages, appointments and case notes, until its retention period ends. The centre sets this period as the controller (section 1). Your counsellor gets a notice about this without your pseudonym. If you want everything deleted earlier, contact the centre. If you share a room with a second person, what is said above about couples counselling applies.

Appointment in your calendar

You can download an appointment as a file to add it to your calendar. It contains “Appointment”, date and time, for in-person or phone appointments also the type, for in-person appointments the place, and a link to your room. Your name and your pseudonym are not in it, but the technical details of the file contain the name onlineberatung.digital. What your calendar does with the file, for example a calendar in the cloud, is outside the platform.

Fees and voluntary contributions

Some centres and practices do not counsel free of charge. Then a payment is due after each follow-up session, and you choose the amount from a sliding scale. For each session, the platform stores whether the payment is due, paid or waived, the amount, the reason (session, or a missed appointment after a short-notice cancellation), how it was paid and when. Your counsellor sees this, and it is deleted with the room. If they remind you of an outstanding payment, this appears as a message in your room. Here too, the centre is responsible (section 1). On the counsellor profile of some centres, you can also give a voluntary contribution.

Payments are to be made later via Stripe (Stripe Payments Europe, Ltd., Dublin, Ireland). This has not been set up yet. Until then, paying only works as a trial run: nothing is charged, and no data goes to Stripe. Before real payments start, I will add here which data Stripe receives for this.

5. In-person counselling

Counselling centres can also use the platform to document counselling that takes place in person or by phone. You do not need an account or a pseudonym for this. The centre creates a case. It can contain:

• a title for the case and the counselling field,
• for you and other people involved, for example your partner: name, role, phone number, email address, postal address, year of birth, gender and place of residence. All of this information is optional.
• appointments with date, time, duration and type (in person, phone, video), and for in-person appointments the place,
• your counsellor's case notes.

The title, the details of the people involved and the case notes are stored encrypted. Who sees what:

• Your counsellor and a co-counsellor from the same centre see everything.
• The centre's office, if there is one, sees the title, the counselling field, all details of the people involved, including year of birth, gender and place of residence, and the appointments. This allows it to create cases and arrange appointments. It never sees the case notes.
• The centre lead sees no cases, only anonymous figures (section 6).

Names of the people involved are never sent to an AI service. Appointments appear in your counsellor's calendar only as “Counselling” with type and place, without a title and without names (section 9).

Continuing online

If you want to write between appointments or continue by video, your counsellor gives you an invitation code, on paper or by phone. Only a check value of the code is stored. It is valid once and for 14 days. With the code you set a pseudonym and a password. After that, sections 3, 4 and 7 apply to you. The details from the case stay with your counsellor. You do not see them in your room.

Here too, the centre is responsible (section 1). In its privacy notice, it gives you the legal basis and its retention period. At your request, your counsellor can also delete a closed case earlier.

6. Centre statistics

Counselling centres need figures, for example for funding reports. That is why the platform records one statistics line per case and year: counselling field, whether in person or online, number, type and duration of contacts, whether the case is new or closed, and for each person involved the age group, gender and place of residence. Names, titles, contact details and content are not included. Gender and place of residence are stored encrypted.

Only the centre lead sees these figures, summarised for a year. Places of residence with fewer than three people appear as “other places”. The centre lead can download the totals as a table, but not individual cases. If a case is deleted, its line remains without any link to the case, so that the figures for the year stay correct. The statistics for a year are deleted ten years after the end of that year, so the figures for 2026 on 1 January 2037. The legal basis is the centre's legitimate interest in figures for its reports (Art. 6 Abs. 1 lit. f DSGVO), unless the centre states otherwise in its privacy notice.

7. Email notices (optional)

If you wish, you can add an email address. It is stored encrypted and only becomes active when you click the link in the confirmation email. You will then get reminders one day and one hour before an appointment, and notices about a cancellation, a new message, free times on the waiting list, and when another person from the centre continues counselling you or a second person from the centre joins your counselling.

The emails contain no name, no pseudonym and no content. However, the sender, header and footer of every email name onlineberatung.digital. Anyone who sees your inbox can tell from this that you use this platform, and perhaps also from the name what your counselling is about. So it is best to use an address that only you read. Every email has a link to unsubscribe. You can delete your address at any time under “Account and security”. The legal basis is your consent (Art. 6 Abs. 1 lit. a DSGVO), which you can withdraw at any time.

The emails are sent via Amazon Simple Email Service (Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg) with servers in the Frankfurt region. AWS sees your email address and the email itself, which only contains a time and a link. A data processing agreement is in place with AWS. AWS is certified under the EU-US Data Privacy Framework (Art. 45 DSGVO).

8. App for iPhone and iPad

You can also use your room in the “Beratungsraum” app. You download the app from Apple's App Store. Apple processes the download and your Apple account under its own responsibility, and Apple's privacy policy applies to this.

Signing in

You sign in with your pseudonym and your password, just like in the browser. The platform gives the app an access key for this. On your device, it is kept in the iOS keychain, only on this device and without iCloud backup. On the server, the platform stores it only as a hash, together with the device type, the iOS version and when it was last used. The key is valid until you sign out in the app, change your password or your account is deleted. If you do not use the app for 14 days, it expires and you sign in again.

The app loads messages and appointments over an encrypted connection. It only shows them while it is open and does not store them on your device. For video and whiteboard, the app opens the platform's appointment page. The same applies as in the browser (section 9). The app deletes this page's cookies as soon as you close the page. You allow access to camera and microphone in iOS when the app asks for it the first time. The app contains no trackers, no advertising and no analytics tools.

Notifications (optional)

If you allow notifications, the platform receives an identifier for your device from Apple. It stores this identifier encrypted, together with the time of the last notification and the language of your device (German or English), so that the fixed sentence comes in your language. For a new message, a new or cancelled appointment and before an appointment, the platform sends a notification to your device via Apple's push service. It only contains “Beratungsraum”, a fixed sentence such as “New message in your room”, a random identifier of your room and the number of unread messages. Names, pseudonym and content are never included. Apple sees the identifier, the notification and your device's IP address. The provider is Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland. Data may also go to Apple Inc. in the USA. Before launch, I will check how this transfer is safeguarded and add it here.

Anyone who sees your lock screen reads “Beratungsraum” there and may recognise from this that you use counselling. In iOS, you can set notifications not to appear on the lock screen. You can switch off notifications at any time in the app under “Settings” or in iOS. The platform then deletes the identifier. It is also removed when you sign out, when your sign-in expires after 14 days without use, or when Apple reports that the device no longer exists. The legal basis is your consent (§ 25 Abs. 1 TDDDG, Art. 6 Abs. 1 lit. a DSGVO), which you can withdraw at any time.

Lock with Face ID

If you wish, the app locks itself with Face ID, Touch ID or your device passcode. iOS checks this on your device. The app only learns whether it worked. Neither the app nor the platform receives data about your face or fingerprint. In the iOS app switcher, the app shows a cover instead of your chat.

Links from the calendar

Links to your room or appointment open the app if it is installed. iOS learns which links belong to it via Apple, from a file on the platform. This file contains no data about you.

Crash reports

If you have switched on “Share With App Developers” in iOS, Apple gives me reports about app crashes. They contain neither your name nor content from your room. You can switch this off in iOS under “Privacy & Security”, “Analytics & Improvements”.

9. Video sessions and calendars

Your counsellor's link

Many counsellors use their own video service, for example Zoom. The platform then only stores the link, encrypted. The centre or practice uses the service and is responsible for it. The video service sees your IP address and your device. What else it processes is stated in the privacy notice of the centre and of the service.

Centre Zoom

If the centre has connected its Zoom account, the platform creates a meeting for every video appointment on the centre's behalf. Zoom only receives the start time, the length and the topic “Appointment”, no pseudonym and no content. The platform stores the meeting ID and the join link, encrypted. If the appointment is cancelled, it also deletes the meeting at Zoom. You join in your browser, without a Zoom account of your own, and enter a name there. Your pseudonym is the best choice. The centre uses Zoom under its own contract and is responsible for it.

Video in the room

Some centres use video in the room. You then hold the session directly in your room. The technology for this is provided by Whereby AS, Gate 1 no. 107, 6700 Måløy, Norway, on behalf of the platform. Norway is part of the European Economic Area. A data processing agreement is in place with Whereby.

• There is a separate, closed room for each appointment. It opens 15 minutes before the appointment and closes 30 minutes after the end. Whereby deletes it one hour later, or immediately if the appointment is cancelled.
• You appear there with your pseudonym. Your counsellor lets you in.
• Whereby processes your IP address, details of your device and browser, and connection data. According to Whereby, in this type of room picture and sound go directly between your devices and are end-to-end encrypted. Nothing is recorded.
• According to Whereby, part of the usage data is also processed in the USA, safeguarded by standard contractual clauses of the EU Commission (Art. 46 Abs. 2 lit. c DSGVO).
• From Whereby's statistics, the platform only fetches the start, end, participant minutes and number of participants of each session. It does not fetch names or IP addresses.

You only allow camera and microphone when your browser asks for it.

Other people in a video appointment

If another person joins a video appointment, for example your partner, the counsellor can invite them with their email address. The person receives an email with only the time and a personal link, without names and without content, a reminder the day before, and a short message if the appointment is cancelled. The link only opens the video and the whiteboard of this appointment, not messages or the room, and only during the appointment window. The email address, a name for the video if wished, and the link for the reminder are stored, all encrypted. The language of the emails is stored too. This is the language in which the counsellor uses the platform when inviting. Everything is deleted one week after the appointment. The legal basis is the invitation at the request of those involved (Art. 6 Abs. 1 lit. b DSGVO).

Counsellors' calendars

Counsellors can connect their own calendar at Microsoft (Outlook, Microsoft 365) or Google. The platform then enters each appointment there, only as “Counselling” or “Counselling, first session” with the type (in person, phone), for in-person appointments with the place, with the name of the platform and a link to the room. Pseudonym, title, names and key points never appear there. A cancellation deletes the entry. So that only free times are offered, the platform only reads from these calendars when the counsellor is busy, without titles. The counsellor or their centre runs the calendar under their own contract with the respective provider. The platform stores the access data for the connection encrypted and deletes it when the calendar is disconnected.

For Google calendars, the following also applies: the platform uses data it receives through Google's interfaces only for the functions above, that is adding and deleting appointments in the counsellor's own calendar, listing calendars for selection and reading busy times without titles. The platform's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. The data is not used for advertising, not sold, not used to train AI and not read by humans, unless this is necessary for security, for legal obligations or with the counsellor's explicit consent.

10. Directory and accounts for professionals

The counsellor profiles are public. They show name, photo, profession, qualification, counselling fields, focus areas, languages, the centre and free times. The pages of the counselling centres are also public: name, town, counselling fields, catchment area, a text by the centre and the counsellors with a published profile. Such a page only exists once there is a contract. The content comes from the counsellors and their centres. On request, a page is taken offline immediately. When uploading a photo, counsellors confirm that they may use it, and the platform removes camera data and location information.

For a professional's account, the platform stores name, email address, the password as a hash, the key for two-factor sign-in (encrypted), recovery codes and, if wished, passkeys. The interface language (German or English) for pages and emails is stored too. When someone is invited, this is at first the language of the person who invites them, and when a centre registers itself, the language of the page. It can be changed under “Account and security”, and in the operations area under “My account”. For each session, the IP address and browser identifier are added. A private calendar subscription contains the times, the type of appointment (first session or follow-up session, in person or by phone), for in-person appointments the place and the link to the room, but no names and no content. Email notices, for example about a new booking or about cases in which nothing has happened for six months, are also sent via Amazon SES and contain no content, no names and no titles.

The same applies to accounts of a centre's office: name, email address, password as a hash and two-factor sign-in. The office has no public page.

When a professional sets a password, the platform checks whether it has already appeared in known data breaches. To do this, the server creates a check value of the password and sends only its first 5 characters to the “Pwned Passwords” service of Have I Been Pwned (Troy Hunt, Australia, delivered via Cloudflare). The service replies with all known check values that start the same way. The comparison happens on the server. The password, the full check value, name and email address never leave the server. The legal basis is my legitimate interest in secure accounts (Art. 6 Abs. 1 lit. f DSGVO).

If the lead of a centre connects Zoom, the platform stores, encrypted, the access data for the connection, the email address of the person who connected it and the users in the centre's Zoom account with name and email address. The centre lead needs this list to match the counsellors to their Zoom users. If the centre disconnects Zoom or removes the app in Zoom, the platform deletes all of this.

Important actions such as closing or deleting a room are logged, without content and without pseudonym. The log is deleted after 12 months.

The legal basis is the user agreement with the professional or their centre (Art. 6 Abs. 1 lit. b DSGVO) and my legitimate interest in secure operation (Art. 6 Abs. 1 lit. f DSGVO).

11. Contact and cancellation

If you send me an email, I process your address and your message in order to reply to you (Art. 6 Abs. 1 lit. b and f DSGVO). Please do not send any information about your health by email. For your counselling, your room is the protected way.

You can cancel a contract with the platform on the “Cancel a contract” page. For this, I process your name, your centre if you give it, your email address, the contract, the type and date of the cancellation and, for an extraordinary cancellation, the reason. You receive a confirmation by email, and I receive a message with the same details. The platform does not store these details in its database. I keep the two emails as proof until the limitation period has expired, usually three years. The legal basis is the legal obligation to enable and confirm cancellations via the website (§ 312k BGB, Art. 6 Abs. 1 lit. c DSGVO).

12. How long data is stored

13. Your rights

You have the right to

• access to your data (Art. 15 DSGVO),
• rectification (Art. 16 DSGVO),
• erasure (Art. 17 DSGVO) and restriction of processing (Art. 18 DSGVO),
• data portability (Art. 20 DSGVO),
• withdraw consent with effect for the future (Art. 7 Abs. 3 DSGVO),
• object to processing based on legitimate interest (Art. 21 DSGVO).

You can do a lot yourself: in your room you download your messages and delete your account. The centre deletes your rooms, after its retention period or earlier at your request. The counselling centre is responsible for questions about your counselling, including in-person counselling. If you write to me, I will forward your request to it. For everything else, an email to hallo@heinerfischer.de is enough.

You can complain to a data protection supervisory authority (Art. 77 DSGVO). The authority responsible for me is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia), Kavalleriestraße 2 to 4, 40213 Düsseldorf, ldi.nrw.de. For the counselling centres, their privacy notice names the responsible authority.

14. Data security and changes

The platform protects your data with measures including TLS, encrypted storage of content, passwords only as a hash, mandatory two-factor sign-in for all professionals, strict access rights and regular updates (Art. 32 DSGVO).

Backups

So that nothing is lost after an error or outage, the platform backs up the database and the uploaded files, for example profile photos, every night. The server encrypts each backup before it leaves the server. Only I have the key. Content that is already encrypted in the database, such as messages and case notes, stays encrypted in the backup too. A backup is kept for 7 days on the server and for 30 days at Amazon Web Services (Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg) in the Frankfurt region. AWS cannot read the backups. A data processing agreement is in place with AWS. AWS is certified under the EU-US Data Privacy Framework (Art. 45 DSGVO).

Anything deleted on the platform is gone from it immediately, but remains in the backups for up to 30 days. After that, these backups are deleted as well. The legal basis is the obligation to protect data against loss (Art. 32 DSGVO) and my legitimate interest in secure operation (Art. 6 Abs. 1 lit. f DSGVO). For data from your counselling, this is done on behalf of the centre (section 1).

I update this privacy notice when the platform, the services used or the legal situation change. The version currently published here applies.