Privacy Policy
Careloop GmbH
Privacy Policy
The protection of your privacy is of particular importance to us.
Careloop GmbH (limited liabilty), Invalidenstr. 161, 10115 Berlin, Germany, e-mail: info@careloop.io (see also imprint), hereinafter referred to as “Careloop ” or “we”, as operator of the website www.careloop.io, is responsible for the use of the personal data of the users of the website in accordance with Art. 4 para. 7 EU Data Protection Basic Regulation (DS-GVO). Our data protection officer is heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, which can be contacted by email at datenschutz@heydata.eu.
It is important to us that you know at all times when we store your personal data and how we use it. We collect, process and use your personal data in accordance with the applicable European and German data protection regulations.
1. Introduction
In the following, we provide information about the collection of personal data when using
- our website careloop.io & careloop.academy
- our profiles in social media.
Personal data is any data that can be related to a specific natural person, such as their name or IP address.
1.1 Contact details
Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.
1.2 Scope of data processing, processing purposes and legal bases
We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:
- Art. 6 para. 1 s. 1 lit. a GDPR serves as our legal basis for processing operations for which we obtain consent.
- Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
- Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
- Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.
1.3 Data processing outside the EEA
In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has also certified itself under the EU US Data Privacy Framework.
In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.
1.4 Storage duration
1.5 Rights of data subjects
Data subjects have the following rights against us with regard to their personal data:
- Right of access,
- Right to correction or deletion,
- Right to limit processing,
- Right to object to the processing,
- Right to data transferability,
- Right to revoke a given consent at any time.
Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.
1.6 Obligation to provide data
Mandatory data are marked as such.
1.7 No automatic decision making in individual cases
1.8 Making contact
1.9 Customer surveys
2. Newsletter
Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.
Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.
We send newsletters with the tool HubSpot of the provider HubSpot Germany GmbH, Am Postbahnhof 17, 10243 Berlin . The provider processes content, usage, meta/communication data and contact data in the process in the EU. Further information is available in the provider’s privacy policy at https://legal.hubspot.com/privacy-policy.
3. Data processing on our website
3.1 Notice for website visitors from Germany
Our website stores information in the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). What information this is in detail can be found in the following sections.
This storage and access is based on the following provisions:
- Insofar as this storage or access is absolutely necessary for us to provide the service of our website expressly requested by website visitors (e.g., to carry out a chatbot used by the website visitor or to ensure the IT security of our website), it is carried out on the basis of Section 25 para. 2 no. 2 of the German Telecommunications Digital Services Data Protection Act (Telekommunikation-Digitale-Dienste-Datenschutzgesetz, “TDDDG”).
- Otherwise, this storage or access takes place on the basis of the website visitor’s consent (Section 25 para. 1 TDDDG).
The subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.
3.2 Informative use of our website
During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
These data are:
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Access status/HTTP status code
- Amount of data transferred in each case
- Website from which the request comes
- Browser
- Operating system and its interface
- Language and version of the browser software.
This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.
3.3 Web hosting and provision of the website
It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
We use the content delivery network Elementor for our website. The provider is Elementor LTD., Tuval St 40, Ramat Gan, Israel. The provider thereby processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the EU. Further information can be found in the provider’s privacy policy at https://elementor.com/terms/#elementor-toc__heading-anchor-47.
We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.
Legal basis of the transfer to a country outside the EEA are adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.
3.4 Contact form
3.5 Vacant positions
We ask applicants to refrain from including information about political opinions, religious beliefs, and similarly sensitive data in their CV and cover letter. Such information is not required for an application. Should applicants nonetheless include such details, we cannot prevent their processing in the course of reviewing the CV or cover letter. In that case, the processing is also based on the applicant’s consent (Art. 9(2) lit. a GDPR).
Finally, we process applicants’ data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6(1) sentence 1 lit. a GDPR.
We share applicants’ data with the responsible staff in the HR department, with our processors in the area of recruiting, and with other employees involved in the application process.
If we enter into an employment relationship with the applicant following the application process, we will not delete the data until after the employment relationship has ended. Otherwise, we will delete the data no later than six months after the rejection of an applicant.
If applicants have given us their consent to use their data for further application procedures, we will not delete their data until one year after receipt of the application.
Where applicants have given us their express consent to do so in the course of the application process, we will share their personal data (in particular contact details, CV, and qualifications) with our sister company, MEDWING International Recruiting GmbH. This is for the purpose of presenting applicants to MEDWING’s partner employers for suitable job openings. The legal basis for this data transfer is the applicants’ express consent (Art. 6(1) sentence 1 lit. a GDPR). This consent may be withdrawn at any time, informally and with effect for the future.
3.6 Customer account
3.7 Technically necessary cookies
Our website sets cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter “Technically Necessary Cookies”), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website.
Specifically, we set technically necessary cookies for the following purpose or purposes:
- Cookies
- to save login data
3.8 Third parties
3.8.1 HubSpot
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR . We have a legitimate interest in managing data in a simple and inexpensive way.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://legal.hubspot.com/de/privacy-policy.
3.8.2 Google Analytics
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR . The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The transfer of personal data to a country outside the EEA takes place on the legal basis adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://business.safety.google/privacy/.
3.8.3 YouTube Videos
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR . The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The transfer of personal data to a country outside the EEA takes place on the legal basis consents.
Further information is available in the provider’s privacy policy at https://policies.google.com/privacy.
3.8.4 Vimeo Videos
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR . The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The transfer of personal data to a country outside the EEA takes place on the legal basis adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider’s privacy policy at https://vimeo.com/privacy.
3.8.5 Facebook Conversion API
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR . The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The transfer of personal data to a country outside the EEA takes place on the legal basis adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.facebook.com/policy.php.
3.5.2. Google Ads
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR . The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The transfer of personal data to a country outside the EEA takes place on the legal basis adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider’s privacy policy at https://business.safety.google/privacy/.
3.8.7 synthesia
The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR . The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The transfer of personal data to a country outside the EEA takes place on the legal basis adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.synthesia.io/legal/privacy-policy.
3.8.8 Google Classroom
The legal basis for processing is Art. 6 Para. 1 Sentence 1 lit. a GDPR. Processing is carried out on the basis of consent. Data subjects can revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing up to the point of revocation.
The transfer of personal data to a country outside the EEA takes place on the legal basis of an adequacy decision. The security of the data transmitted to the third country (i.e., a country outside the EEA) is guaranteed because the EU Commission has decided, within the framework of an adequacy decision according to Art. 45 Para. 3 GDPR, that the third country offers an adequate level of protection (EU-U.S. Data Privacy Framework).
We delete the data once the purpose for its collection has ceased to exist (e.g., after termination of the course relationship) and no legal retention obligations prevent deletion. Further information can be found in the provider’s privacy policy at https://policies.google.com/privacy.
3.8.9 heyData
The legal basis of the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing website visitors with confirmation of our data privacy compliance. At the same time, the provider has a legitimate interest in ensuring that only customers with existing contracts use its seals, which is why a mere image copy of the certificate is not a viable alternative as confirmation.
As the data is masked after collection, there is no possibility to identify website visitors. Further information is available in the privacy policy of the provider at https://heydata.eu/en/privacy-policy.
4. Data processing on social media
If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
4.1 Facebook
https://www.facebook.com/settings?tab=ads. We are joint controllers for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 GDPR with Facebook. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data.
Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.