Data protection information for the app Barmer Teledoktor

The German version is the authoritative version. The English version is provided for comprehension and translation purposes only.

1. Introduction 

We want you to feel safe when using the app Barmer Teledoktor. The protection of your personal data is of highest importance to us.

Barmer cooperates with SHL Telemedizin GmbH on the Barmer Teledoktor.

As a matter of principle, Barmer only receives anonymized data. This data does not allow any conclusions to be drawn about the identity of the person or their state of health. The only exception is the transfer of data as part of reporting a barrier (see also 12.) from SHL Telemedizin GmbH to Barmer.

For further information, please refer to the following data protection declaration of SHL Telemedizin GmbH.

SHL Telemedizin GmbH takes the protection of your personal data very seriously. All personal data that you transmit or make available to us will be treated in strict confidence and will be collected, processed, and stored in compliance with the statutory data protection provisions exclusively for the purpose and as described below.

The user assumes responsibility for the personal data of third parties that he or she transmits via this application and declares that he or she is authorized to provide or disclose said data. Thus, SHL Telemedizin GmbH is exempt from any responsibility and liability in this regard. 

Contact details of the responsible entity  

SHL Telemedizin GmbH
Balanstraße 69 b
81541 München
Tel +49 89 48059-0

For further information please refer to our imprint at https://www.shl-telemedizin.de/impressum/. 

2. What is the app Barmer Teledoktor?

With the app Barmer Teledoktor, Barmer offers its health insured persons the Barmer Teledoktor services as a mobile version. You can get medical advice on many health topics via different channels. For example, the Barmer Teledoktor answers your questions about medications, therapies, diseases, and many more all year round.

The app is also the gateway to digital forms of care, such as the Video Consultation and the Digital Skin Check. The digital care services are what is known as Special Care in accordance with Section 140a of the German Social Code, Book V (SGB V). This means that insured persons can conveniently and comfortably use, among other things, remote medical treatment in the form of the Video Consultation or obtain an assessment from a doctor for skin problems in the Digital Skin Check. You can receive treatment via Video Consultation call or in the Digital Skin Check as part of an asynchronously generated report within the medically possible scope. These are voluntary and optional services. 

3. Is the use of the app Barmer Teledoktor voluntary?

Yes, the use of the app Barmer Teledoktor is voluntary. Personal data is either voluntarily provided by the user of the app or automatically collected by the function of the app. If certain data is not provided, the app may not be fully functional. The provision of data is not required by law or contract.

Participating in the Special Care services as Video Consultation or Digital Skin Check is also voluntary. Barmer Teledoktor functions independently of the Video Consultation or Digital Skin Check. These are additional, optional services. By voluntarily declaring participation and consenting to data processing, it is possible to participate in the form of care pursuant to § 140a SGB V. If the insurance or medical requirements are not met, it may not be possible to use the services. 

4. Who is the app Barmer Teledoktor for? 

The app Barmer Teledoktor is a free service offered by Barmer. In principle, all Barmer insured persons are entitled to use the Barmer Teledoktor services. For the optional and voluntary use of the Video Consultation and the Digital Skin Check, additional requirements must be met. Insured persons aged 16 and above (on turning 16) can use the offers independently. For insured persons under 16 years of age, it is necessary for parents or guardians to give consent to data processing in accordance with data protection regulations. Parents or legal guardians give consent for their children before the age of 15 to participate in the Special Care services, to the conditions of use of the Video Consultation and to the respective data protection provisions. Parents or legal guardians must be present during the Video Consultation to the necessary extent. 

5. What steps are required to use the app Barmer Teledoktor? 

1. Download the app Barmer Teledoktor from the app stores.
2. Registration procedure: To protect your personal data, unique authentication in the member area Meine Barmer is required. Login to Barmer Teledoktor is only possible with the credentials for the Barmer user account. If you do not yet have credentials for the Barmer user account, you must first log in and register on the page Meine Barmer.
3. When registering to use the application, personal data is collected, such as first name, last name, date of birth, insurance number, as well as telephone number and e-mail address. After successful registration, content and services can be accessed that are available exclusively to registered users.
4. In order to be able to use the Video Consultation and the Digital Skin Check, the electronic declaration of participation and the necessary data processing for Special Care must be voluntarily agreed to beforehand. For the use of the Video Consultation, the terms of use and the privacy policy of the Video Consultation portal must also be agreed to. The consents can be given within the app.

6. What permissions and functions does Barmer Teledoktor require on the device? 

• Technical requirements:
  • Internet-enabled smartphone (iOS or Android) with camera and microphone
  • Login with Touch ID and Face ID (iOS) or fingerprint (Android) (optional)
• Recommendations for a secure execution environment:
  • Operating system security check (Android)
  • Login via biometric data of the operating system

Note: The operation and use of Barmer Teledoktor takes place on your private end device. For this purpose, the following data will be stored and processed on your private device. SHL Telemedizin GmbH cannot take any responsibility for the security on the device. Depending on the device used, the configuration of the device and the individual use of the device, it may be a potentially insecure operating environment with which various security risks are associated that cannot be fully addressed by the manufacturer of the Barmer Teledoktor. 

Firebase Cloud Messaging
The app uses push services provided by operating system manufacturers. These are short messages that can be displayed on the user's device screen and actively inform them of warnings.

When using the push service, a device token from Apple or a registration ID from Google is assigned. These are encrypted, anonymised device IDs. The purpose of their use is solely to provide the push services. It is not possible to trace them back to individual users. The push service can be adjusted or deactivated in the app as required. We use the Firebase Cloud Messaging service.

No other Firebase services are used. 

Further information on the terms of use of Firebase Cloud Messaging can be found on the Firebase website: https://firebase.google.com/terms/.

Google also processes your data in the USA, among other places. Firebase and Google are participants in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA.

In addition, Google uses standard contractual clauses (Art. 46(2) and (3) GDPR). Through the EU-US Data Privacy Framework and the standard contractual clauses, Google undertakes to comply with European data protection standards when processing your relevant data, even if the data is stored, processed and managed in the United States.

The Data Processing Agreement, which refers to the standard contractual clauses, can be found at https://firebase.google.com/terms/firebase-sccs-eu-c2p.
 

7. What kind of data is processed by the app Barmer Teledoktor?

• Inventory data
• Contact data
• Photo and video data
• Meta data
• Health data
• (App) usage data
• Location data
• Application log data 

8. Access authorization of the mobile application to mobile devices 

This mobile application requires the following permissions to provide full functionality:

• Call telephone number directly - after confirmation by the user, the application can be connected directly to the Barmer Teledoktor telephone number.
• Access to photos and camera - for the Appointment Service for doctor's appointments, as well as in the chat and messages, the user has the option of photographing documents and having them processed by SHL Telemedizin GmbH. For the Digital Skin Check, the user has the option of photographing affected skin areas and having them processed further by Dermanostic GmbH.
• Access to the phone's SD card or local memory - needed to store encrypted local data in order to view information offline on the mobile device.
• Network status, Internet and WLAN access - is required to check the availability of an Internet connection and to establish an encrypted, secure connection to the servers of SHL Telemedizin GmbH.
• Location - when using the Appointment Service, the app offers the user to use their current location as the starting address of a search. The localization function is only activated if the user actively selects the localization function at this point instead of entering the address manually. The location will be used exclusively for the purpose specified in the function and stored on the servers of SHL Telemedizin GmbH. The app's authorization for localization services can be deactivated at any time via the device settings.

9. What data is stored in the device memory of the local device? 

• Photo and video data from the app
• Encrypted authentication data (offline token)
• Optional: Appointments in the calendar of the operating system 

10. What is the legal basis for the processing? 

• Provision of the app Barmer Teledoktor
• Collection of health data for the provision of health care advice
• Inventory data:
  • Necessary for the functionality of the application
  • Correct addressing and identification of the insured person
• Contact data:
  • Necessary for the insured person to make an appointment
  • Necessary for Barmer to review a reported barrier
• Photo and video data:
  • Uploading documents such as referrals or photos
  • Video data for the conduction of the Video Consultation
• Meta data:
  • Ensuring error-free functionality of the application
  • Transparency of the application functions
• Health data:
  • Necessary for the insured person to make an appointment and for any necessary symptom check to be made beforehand
• (App) usage data:
  • Billing for chat and message usage 

Legal basis:

The processing of the data entered during registration is based on your consent in accordance with Art. 6 para. 1 lit. a GDPR. We process your personal data during registration in accordance with Art. 6 para. 1 lit. b GDPR. According to Art. 6 para. 1 lit. a GDPR, your personal data may be processed if you have given your consent.

If we collect and process special categories of data, in particular health data, this requires explicit consent in accordance with Art. 9 para. 2 lit. a GDPR, which in this case forms the basis for the processing of this special category of data.

When you access the app, i.e., even if you do not register or otherwise transmit information, information of a general nature is automatically collected. This information (server log files) includes, for example, the time and date, the operating system used, the domain name of your Internet service provider, your IP address and the method accessed. It is processed in particular for the following purposes:

• Ensuring a smooth connection setup of the app,
• Ensuring smooth usage of our app,
• Evaluation of system security and stability. 

We also reserve the right to check the server log files retrospectively if there are concrete indications of unlawful use. Processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR based on our legitimate interest in improving the stability and functionality of the app.

The processing of personal data for the Video Consultation and the Digital Skin Check is based on Sections 140a (5), 284 (1) No. 13 and 295a SGB V. We process your email address in order to send you information about the Video Consultation or the Digital Skin Check, for example regarding your appointment, in the event of any follow-up questions, or if new documents are available for you.

Art. 8 para. 1 GDPR is also used for consent to data processing for children. In this context, all patient information, information on the (electronic) declaration of participation, data processing and the respective revocation options are stored in the app Barmer Teledoktor. 

11. How is the data secured?

SHL Telemedizin GmbH complies with generally accepted security standards to ensure the security of data during and after transmission. The security measures implemented by SHL Telemedizin GmbH ensure that the transmitted data is only used for the intended purpose, i.e. for the function of the services offered in the application. SHL Telemedizin GmbH takes strict security precautions to protect personal data from loss, misuse, unauthorized access or disclosure, (manipulative) changes or destruction.

To ensure compliance with the statutory provisions of the German Federal Data Protection Act (BDSG) and the General Data Protection Regulation (GDPR), SHL Telemedizin GmbH has taken appropriate technical and organizational measures. Data processing is carried out by means of computer or IT-based systems, following an organizational procedure and mode strictly aimed at the purpose of health advice and remote treatment.

Your personal data will be processed exclusively within the European Union. 

12. Is data passed on to third parties? 

At SHL Telemedizin GmbH, access to data is granted exclusively to the specialist departments involved in the operation of the application.

External parties (such as third-party providers of technical services, delivery companies, hosting providers, IT companies) are used by SHL Telemedizin GmbH as subcontractors if necessary to provide the services made available within the application and are equally subject to all data protection obligations outlined here. If processing takes place on behalf of the service provider, we have concluded an order processing agreement with the service provider.

During the appointment service, master data is transmitted to service providers (e.g. doctors in private practice) exclusively by telephone.

To carry out the optional Digital Skin Check, the data required for the procedure is transmitted to Dermanostic GmbH, Merscheider Str. 1, 42699 Solingen via a secure (encrypted) channel. Dermanostic GmbH processes personal data exclusively on behalf of the respective responsible cooperating practice on the basis of a data processing agreement (controller-processor contract) in accordance with Article 28 GDPR. This includes, in particular, the technical provision of the application environment, the structured receipt of the transmitted data, and support for medical case processing and documentation of results. SHL Telemedizin GmbH provides the required technical infrastructure for this purpose and acts as a processor for Dermanostic GmbH. Processing is carried out exclusively according to the existing data protection law agreements in accordance with Article 28 GDPR. 

Dermanostic GmbH can be contacted via e-mail at info@dermanostic.com. 

If you report a barrier by using other channels than the relevant contact form, SHL Telemedizin GmbH will transmit the data you provide in this context to Barmer.

Any transmission and processing of personal data to/by third parties beyond the declared purposes, for example for advertising purposes, will generally not take place or requires separate consent. 

Conducting the Mental Health Check

If you wish to use the Mental Health Check and therefore contact us by phone, we will use your email address to send you a link to the Mental Health Check provided by Klenico Health AG, Förrlibuckstrasse 190, 8005 Zurich, Switzerland. Your data is processed solely for the purpose of enabling you to complete a digital Mental Health Check via the Klenico Health AG platform. The legal basis for sending you the link is your consent in accordance with Article 6 (1) (a) of the GDPR. Consent is voluntary and may be withdrawn at any time with effect for the future. The lawfulness of the processing carried out up to the point of withdrawal remains unaffected.

Klenico Health AG processes your personal data in connection with the Mental Health Check as an independent controller within the meaning of Article 4 (7) of the GDPR. Klenico Health AG’s own data protection provisions apply to the processing of your data by Klenico Health AG.

13.How can you delete your data in the app Barmer Teledoktor?

SHL Telemedizin GmbH adheres to the principles of data avoidance and data minimization. SHL Telemedizin GmbH only stores personal data for as long as it is necessary in order to implement the services available in the application and for the purposes stated here and for the storage periods stipulated by law. Once the respective purpose no longer applies or the statutory periods have expired, the corresponding data is routinely blocked or deleted in accordance with the statutory provisions.

14.What data protection rights do you have? 

Every person affected has the right of information under Art. 15 GDPR, the right to rectification under Art. 16 GDPR, the right to erasure under Art. 17 GDPR, the right to restriction of processing under Art. 18 GDPR, the right to object under Art. 21 GDPR, and the right to data portability under Art. 20 GDPR.

The restrictions under Sections 34 and 35 BDSG apply to the right to information and the right to erasure.

You can withdraw your consent for the processing of personal data at any time. This also applies to the revocation of declarations of consent given to us before the General Data Protection Regulation came into force, i.e. before May 25, 2018. Please note that the revocation is only effective for the future. Processing that took place before the withdrawal is not affected by this. 

In addition, you have the right to lodge a complaint with a competent data protection supervisory authority (Art. 77 GDPR in conjunction with Section 19 BDSG). A list of supervisory authorities (for the non-public sector) with addresses can be found at: Landesdatenschutzbehörden

15. Contact details of the data protection officer 

Questions about data protection can be sent by e-mail to SHL Telemedizin GmbH or directly to the responsible data protection officer:

Datenschutzbeauftragter der SHL Telemedizin GmbH
c/o activeMind.legal Rechtsanwaltsgesellschaft m. b. H.
Potsdamer Str. 3
80802 München
E-Mail: datenschutz@shltm.de

16. Changes to the privacy policy 

SHL Telemedizin GmbH reserves the right to make changes to this privacy policy at any time. Users are therefore advised to visit this page regularly and to check the date of the last change indicated at the bottom of the page. The new privacy policy will then apply to your next visit.

Last modification date: 09.06.2026