Legal
Privacy Policy
Last updated: 7 October 2026
Data Collection on Our Website
Who is responsible for the data collection on this website?
The data processing on this website is carried out by the website operator. You can find their contact details in the imprint of this website.
How do we collect your data?
Your data is collected on the one hand by you communicating it to us. This can be, for example, data that you enter in a contact form.
Other data is collected automatically when you visit the website by our IT systems. This is primarily technical data (e.g. internet browser, operating system or time of page view). This data is collected automatically as soon as you enter our website.
What do we use your data for?
Part of the data is collected to ensure the error-free provision of the website. Other data can be used to analyze your user behavior.
What rights do you have regarding your data?
You have the right at any time to receive free information about the origin, recipient, and purpose of your stored personal data. You also have a right to demand the correction, blocking, or deletion of this data. For this purpose, as well as for further questions on the subject of data protection, you can contact us at any time at the address given in the imprint. Furthermore, you have a right to lodge a complaint with the competent supervisory authority.
Analysis Tools and Third-Party Tools
When you visit this website, which pages you open and where you came from can be evaluated — but only once you have agreed. Before you answer, none of it happens. You are asked on your first visit and can change your decision at any time via the "Change measurement" link in the footer. Details in the section Measurement and advertising.
General Notes 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 are collected. Personal data are data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this happens.
We point out that data transmission on the Internet (e.g. when communicating by email) can have security gaps. Complete protection of data against access by third parties is not possible.
Information on the Responsible Party
The controller is Alexandrit Aesthetics GmbH, represented by Magdalena Graml, Südliche Münchner Str. 46, 82031 Grünwald, Germany. Email: kontakt@alexandrit-aesthetics.de.
The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).
Revocation of Your Consent to Data Processing
Many data processing operations are only possible with your express consent. You can revoke consent already given at any time. An informal email communication to us is sufficient for this purpose. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
Right to Lodge a Complaint with the Competent Supervisory Authority
In the event of violations of data protection law, you have the right to lodge a complaint with the competent supervisory authority. The authority responsible for us is the Bavarian Data Protection Authority (BayLDA), Promenade 18, 91522 Ansbach, Germany.
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. If you request the direct transfer of the data to another responsible party, this will only be done as far as technically feasible.
SSL or TLS Encryption
This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Information, Blocking, Deletion
Within the framework of the applicable legal provisions, you have the right to free information at any time about your stored personal data, their origin and recipient, and the purpose of the data processing and, if applicable, a right to correction, blocking, or deletion of this data. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time at the address given in the imprint.
Objection to Promotional Emails
The use of contact data published under the imprint obligation to send unsolicited advertising and information materials is hereby rejected. The operators of the pages expressly reserve the right to take legal steps in the event of unsolicited sending of advertising information, such as spam emails.
Data Collection on Our Website
Cookies
The internet pages partly use so-called cookies. Cookies do not harm your computer and do not contain viruses. Cookies serve to make our offer more user-friendly, effective, and secure. Cookies are small text files that are stored on your computer and saved by your browser.
Most of the cookies we use are so-called session cookies. They are automatically deleted after your visit. Other cookies remain stored on your device until you delete them. These cookies enable us to recognize your browser on your next visit.
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for specific cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.
What is needed to run the site — such as your decision about measurement — is stored in your browser on the basis of Art. 6(1)(f) GDPR. Everything beyond that, in particular anything analysing your behaviour, happens only after your consent and is dealt with separately below.
Processing of Data (Customer and Contract Data)
We collect, process, and use personal data only to the extent necessary for the establishment, content design, or amendment of the legal relationship (master data). This is done on the basis of Art. 6 Para. 1 lit. b GDPR, which permits the processing of data to fulfill a contract or pre-contractual measures. We collect, process, and use personal data about the use of our internet pages (usage data) only to the extent necessary to enable the user to use the service or to bill for it.
The collected customer data will be deleted after completion of the order or termination of the business relationship. Statutory retention periods remain unaffected.
Data Transmission upon Contract Conclusion
We transmit personal data to third parties only if this is necessary within the framework of contract execution, such as to the credit institution commissioned with payment processing.
A further transmission of the data does not take place or only if you have expressly consented to the transmission. A passing on of your data to third parties without express consent, such as for advertising purposes, does not occur.
The basis for data processing is Art. 6 Para. 1 lit. b GDPR, which permits the processing of data to fulfill a contract or pre-contractual measures.
Measurement and advertising
Your consent is the legal basis
On your first visit we ask whether we may measure how this site is used. We do not load analytics or advertising pixels without your consent. Storing or accessing information on your device for these purposes is based on Section 25(1) TDDDG; the subsequent processing of personal data is based on Art. 6(1)(a) GDPR. Processing necessary to operate the website and services you choose to open are explained in their respective sections.
Your decision is stored in your browser and is not transmitted to us. You can change it at any time using the "Change measurement" link in the footer of every page. A withdrawal takes effect immediately; the lawfulness of processing carried out up to that point is unaffected.
The same applies to what a page otherwise loads from outside in passing: the map in the footer is an image on our own server, created from open map data (OpenStreetMap) — Google Maps only opens when you click it. The fonts are on our server as well.
Google Analytics
After your consent we load Google Analytics 4 via the Google tag. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Analytics sets an identifier in your browser in order to group repeated requests within one session. Collected are the pages requested, the source of the visit, an approximate location, the device type and the browser language.
A transfer to the USA cannot be ruled out. Google relies for this on the EU-US Data Privacy Framework and on standard contractual clauses. Further information in Google's privacy policy: policies.google.com/privacy.
Google Ads — measuring enquiries
Also after your consent, we report to Google Ads when you tap a phone number, open WhatsApp or begin a booking. This tells us which advert led to an enquiry. What is transmitted is the type of action, not its content — for a call, that a call was made, not what was said.
From these visits, Google Ads additionally builds audience lists and measures whether someone who saw an advert later comes back on their own. This means our advertising may reach you again on other sites. It addresses groups, not individuals; we receive no names and no addresses.
Meta Pixel (Facebook and Instagram)
With your consent, we use the Meta Pixel to measure the effectiveness of our Facebook and Instagram ads and improve their delivery. The provider is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. Data transmitted to Meta may include the page address, time, IP address, browser and device information, cookie and advertising identifiers, and actions such as opening a contact option, submitting an enquiry or starting a booking. Our own event transmission sends the type of action, not the content of your message or conversation.
Meta may link this information to a Facebook or Instagram account and use it for advertising measurement and personalisation. We receive reports on advertising effectiveness; a website visit alone does not disclose your Meta profile or name to us. Contact through an enquiry form is a separate process.
The legal bases are your consent under Section 25(1) TDDDG and Art. 6(1)(a) GDPR. You can refuse or withdraw website measurement at any time using “Change measurement” in the footer. This stops future pixel events initiated by us; it does not affect the lawfulness of processing that has already taken place. You can also delete existing cookies in your browser.
We and Meta are joint controllers under Art. 26 GDPR for the collection of event data and its transmission to Meta. Meta's Controller Addendum describes the allocation of responsibilities. Meta is responsible for subsequent processing for its own purposes. You may exercise your data protection rights with us or Meta.
Meta companies and service providers may process data outside the EU, particularly in the United States. Meta describes the transfer mechanisms it uses, including the EU-US Data Privacy Framework for certain transfers and standard contractual clauses, in its privacy information. Meta's retention periods depend in particular on the purpose and legal obligations; we cannot determine them through our website. Further information, contact options and settings are available in the Meta Privacy Policy and Meta Cookies Policy.
Further processing
Consultation enquiries through Facebook and Instagram
Our ads may open an enquiry form directly on Meta. When you submit it, Meta sends the information you have confirmed to Alexandrit Aesthetics. The current form asks for your name, telephone number, whether the Grünwald location suits you, and your preferred callback time. Technical information about the enquiry, such as its time and the associated ad, is also included. Please do not submit medical information in this form.
Magdalena Graml personally handles enquiries in Meta Leads Center. We use your details to provide the requested consultation, call you back and arrange a possible appointment. Processing your pre-contractual enquiry is based on Art. 6(1)(b) GDPR; where separate consent is applicable, on Art. 6(1)(a) GDPR. The form includes an express callback consent. An enquiry is not an appointment booking or a newsletter subscription.
You can cancel your callback request or withdraw consent at any time for the future by emailing kontakt@alexandrit-aesthetics.de. Providing the information is voluntary; without the required contact details we cannot call you back. You may contact us directly instead.
We retain your enquiry only as long as necessary to handle it and, where applicable, to prepare or perform a contract. When this purpose no longer applies, the details are deleted unless legal retention obligations or necessary evidence require continued storage. The automatic 90-day deletion described for our website contact form does not automatically apply to Meta enquiries.
Meta also processes data arising on its platform under its own Privacy Policy; the information above about international processing also applies. Our website's consent setting controls website measurement, not the processing of a form you submit directly on Facebook or Instagram.
Consultation enquiries through TikTok
Our TikTok ads may open an enquiry form directly within TikTok. When you submit it, we receive your confirmed name, telephone number, answer about travelling to Grünwald and preferred callback time, together with information about the enquiry and associated ad. The form does not request health data; please do not submit medical information.
Magdalena Graml personally handles enquiries in TikTok Leads Center. We use your details solely for the initial consultation you request, your requested callback and arranging a possible appointment. The legal basis for this pre-contractual enquiry is Art. 6(1)(b) GDPR. Where you provide separate consent, Art. 6(1)(a) GDPR applies. Submission is voluntary and is neither a binding appointment booking nor a newsletter subscription. Without a telephone number we cannot call you back; you may contact us directly instead.
You may cancel your callback request and withdraw any consent for the future by emailing kontakt@alexandrit-aesthetics.de. We retain enquiries only as long as needed to handle them or perform a subsequent contract, unless legal obligations or necessary evidence require continued retention. The automatic deletion of our website contact enquiries does not apply to TikTok enquiries.
TikTok and Alexandrit Aesthetics each process lead data as controllers. TikTok may also process information for its own platform purposes, such as prefilling future forms. In the European Economic Area, TikTok Technology Limited (Ireland) and TikTok Information Technologies UK Limited (United Kingdom) are responsible for the platform. Details about their processing, international storage, transfer mechanisms, retention and your rights are available in the TikTok Privacy Policy.
The form is processed directly by TikTok. Our website's “Change measurement” setting does not control this form processing. If you subsequently visit our website, the website measurement consent settings described above apply there.
Contact form
What you enter into the form — name, e-mail address and your message — is stored on our server and forwarded to us by e-mail. Storage happens first so that your enquiry is not lost if the e-mail delivery fails. The legal basis is Art. 6(1)(b) GDPR (steps preparatory to a contract), or (a) insofar as you expressly consent.
Stored enquiries are deleted automatically after 90 days. To protect against automated submissions, your IP address is evaluated in shortened form and is not stored.
Appointment booking until 30 September 2026
Until 30 September 2026, appointments could also be booked through an embedded calendar on our “Book an appointment” page. That calendar is no longer on our website; since then, bookings are made exclusively through our own booking form, described in the following section.
The calendar belonged to a CRM system operated for us by our agency InfiniteLeads (Wiener Neustadt, Austria). It appeared as an embedded frame at link.alexandrit-aesthetics.de. The details of bookings you made there remain in that system and are processed there on our behalf.
A data processing agreement under Art. 28 GDPR is in place with InfiniteLeads. The software itself is hosted by HighLevel Inc. in the USA as a sub-processor, so a transfer there takes place. It rests on the European Commission adequacy decision for the EU-US Data Privacy Framework, in which HighLevel Inc. is listed.
Booking the free consultation with trial treatment
You can book the free consultation with trial treatment through our own booking form (Free consultation booking). For this we process your name, telephone number and email address, the areas you select, your note, the appointment you choose, the language of the page and your choices regarding the appointment reminder and appointment messages via WhatsApp.
We use these details to arrange and carry out the appointment, send you a confirmation, remind you of the appointment, let you reschedule or cancel it, and keep your customer record. The legal basis is Art. 6(1)(b) GDPR (the contract for the booked appointment and the steps leading up to it). Without your name, telephone number and email address we cannot accept the booking.
We match the booking against our customer records using your telephone number or email address together with your name. If you are already a customer, we add the appointment to your existing customer record; otherwise we create a new one. Where the match is not clear, we create a new record and check the assignment by hand.
The details are stored in Google Cloud Firestore (Firebase) in Frankfurt am Main, Germany (region europe-west3). The provider is Google Ireland Limited, acting as our processor. The emails about your appointment — confirmation with calendar invitation, reminder, rescheduling and cancellation — are sent through the outgoing mail server of our email provider, IONOS SE.
We remind you by email 24 hours before your appointment. If the appointment is booked or moved less than 24 hours in advance, there is no reminder. The reminder is part of the booked appointment. You can opt out when booking by ticking “I don't want a reminder”, switch it off and on again via your personal link (see below) until 24 hours before the appointment, or tell us at any time by email to kontakt@alexandrit-aesthetics.de or by phone that you do not want a reminder. If you cancel the appointment, the reminder is cancelled too.
With the confirmation you receive a personal link to view, reschedule or cancel your appointment. It contains a random key that only you receive; please do not pass the link on.
To stop anyone from blocking appointments in bulk, we form a shortened check value from your IP address and browser identification when you reserve or reschedule a time or switch the reminder, which expires after fifteen minutes. We also count how many visitors open the booking page and reach the further steps of the booking (page opened, areas chosen, time chosen, booked), in total and per channel (see the next paragraph); so that the same step is not counted twice, we form a check value by the same method, which expires after 30 minutes. The check values are held only in the server's working memory and are not written to any database; the server removes expired check values at the next opportunity; the database holds only daily counts with no link to any person. The legal basis is Art. 6(1)(f) GDPR in each case; our legitimate interest is protecting the booking from misuse and knowing at which step bookings are abandoned.
When you open the booking page, we assign one of a small fixed set of channels from the address you used to open it (for example an ad identifier or campaign details in the link) and from the page you came from (referrer) — for example Google ad, Google search, Instagram, our own website or direct — and, if the link contains one, the campaign name. We include the channel in the daily counts mentioned above and store it, together with the campaign name, with your booking. We do not store the ad identifier itself or the full address of the referring page. Without your consent to measurement, nothing is stored in your browser for this; the channel is only sent along with the booking requests. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is knowing which advertising and which routes lead to bookings.
If you have consented to measurement (see “Your consent is the legal basis”), your browser keeps the channel of the page on which your visit began in session storage (sessionStorage). If you then reach the booking via another page of our website, we store that channel with your booking instead of “own website”. The entry is deleted when you close the window or tab, and immediately if you decline measurement. The legal basis is your consent under Section 25(1) TDDDG and Art. 6(1)(a) GDPR.
In the booking form we ask, on a voluntary basis, how you heard about us. If you answer, we store your answer with the appointment and, if none is recorded there yet, in your customer record. You can book just the same without answering. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is knowing how clients find us.
We keep the appointment and your customer record for as long as this is necessary to look after you and to meet statutory retention obligations.
Messages via WhatsApp
By default, we send the messages about your appointment — confirmation, reminder, rescheduling and cancellation — via WhatsApp to the phone number you gave when booking, in addition to e-mail. The booking form says so right next to the phone field, and you can opt out there with “No thanks”. For this we process your phone number, your first name, the date and time of the appointment, the language of your booking and the personal link to your appointment. With the appointment we also store whether you receive WhatsApp messages and, for an online booking, when you saw the notice and its wording, and for each message an identifier and whether it was delivered or read.
We send and receive WhatsApp messages via the WhatsApp Business Platform (Cloud API) of Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland, acting as our processor. Processing by Meta companies outside the EU, in particular in the USA, is possible; Meta bases such transfers on the EU-US Data Privacy Framework and standard contractual clauses. Your use of WhatsApp itself is governed by the WhatsApp Privacy Policy and your agreement with WhatsApp.
The legal basis is Art. 6(1)(b) GDPR: the messages are part of performing the contract for your booked appointment. You do not need them to attend the appointment; without WhatsApp you receive all messages by e-mail as before. You can unsubscribe from the WhatsApp messages at any time by e-mail to kontakt@alexandrit-aesthetics.de, by phone or with a short WhatsApp message to us. We additionally keep an appointment message's identifier and delivery status without name or phone number and delete that entry after 30 days; in the chat (below), the message remains as long as the chat. We keep your choice and the notice you saw with the appointment (see above).
If you write to us via WhatsApp — in reply to one of our messages or on your own initiative — we store the chat in the studio's administration so that we can reply and link your request to your customer record. This includes your phone number, the name from your WhatsApp profile, the text, time and delivery status of each message, photos, voice messages and files you send us, and our replies. If the studio's WhatsApp Business app is connected to our number, this also includes the messages we write there and the history of the last six months that WhatsApp transfers when connecting. The messages are stored in Google Cloud Firestore in Frankfurt am Main (region europe-west3); photos, voice messages and files are stored in Google Cloud Storage at locations within the European Union (EU multi-region) and are not publicly accessible. The provider is Google Ireland Limited as our processor. Only studio staff who may also see your customer record can read the chat. The legal basis is Art. 6(1)(b) GDPR where your appointment or treatment is concerned, otherwise Art. 6(1)(f) GDPR — our legitimate interest in answering your request and keeping arrangements traceable. We keep the chat for as long as your customer record exists and delete it together with the record; if there is no customer record for your number, we delete the chat 24 months after the last message.
Partner programme
When you provide a partner code during online booking of the free consultation, we check your email address and telephone number against our customer records. If you are new to us, we assign your customer record to the partner who issued the code. If you are already a customer or the code is invalid, we make no assignment; we only note the code you provided on the appointment itself, so it remains clear at checkout that no discount applies. In their account, the partner sees only your name masked (the first and last letter of each name part), the month of redemption and whether you attended an appointment — not which treatment you booked or what you paid. They see their commission only as a monthly total, never per customer. The legal basis for the assignment is Art. 6(1)(b) GDPR (providing the benefit under your booked contract); for calculating their commission from the amounts actually paid, Art. 6(1)(b) and (f) GDPR (performing our contract with the partner).
If you apply to become a partner, we process the details from the form together with your consent, its time and wording, in order to review your application (Art. 6(1)(b) GDPR). After approval, we set up an account for you using your email address, through which you can sign in and view your redemptions and commission. We delete rejected applications after 90 days.
Server log files
This website runs on Firebase App Hosting (Google Ireland Limited). Each request generates technical logs containing the IP address, the time, the address requested and the browser identification. These serve the operation of the site and the prevention of attacks; the legal basis is Art. 6(1)(f) GDPR.