With this privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes, and to what extent.
This privacy policy applies to all processing of personal data carried out by us in connection with the use of the HealthCaters Business Platform. These are therefore not related to use by end users, but concern HealthCaters business partner companies or use by their employees, who typically work in personnel management or occupational health management.
The terms used are not gender-specific.
Scope of Data Processing
We generally only process personal data of our users insofar as this is necessary to provide our content and services. The processing of personal data of our users regularly takes place only with the user's consent. An exception applies in cases where obtaining prior consent is not possible for practical reasons and the processing of data is permitted by legal regulations.
As part of our processing of personal data, data may be transmitted to and disclosed to other entities or companies. In such cases, we observe the legal requirements and conclude appropriate agreements to protect your data with the recipients of your data.
Legal Basis for Processing
Insofar as we obtain consent from the data subject for processing operations of personal data, Art. 6(1)(a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis. For the processing of personal data necessary for the performance of a contract to which the data subject is party, Art. 6(1)(b) GDPR serves as the legal basis. This also applies to processing operations necessary for carrying out pre-contractual measures.
Insofar as processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6(1)(c) GDPR serves as the legal basis.
In the event that vital interests of the data subject or another natural person necessitate the processing of personal data, Art. 6(1)(d) GDPR serves as the legal basis.
If processing is necessary for the purposes of legitimate interests pursued by our company or by a third party, and if the interests, fundamental rights and freedoms of the data subject do not override those interests, Art. 6(1)(f) GDPR serves as the legal basis for processing.
Storage Period and Data Deletion
The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may also take place if provided for by European or national legislators in EU regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted when a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for contract conclusion or contract fulfillment.
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects affected.
4.1. Provision of Health Services
Scope of Data Processing
The evaluated health data is presented to business partner companies in anonymized and aggregated form. To view the evaluations, access to admin user accounts of the business partner companies is required.
The following categories of persons are affected by this data processing:
- Employees (administrators) of business partner companies
The following data is collected:
- User profile data (e.g., name, email address, device information, IP address)
Data transmission takes place to the following recipients outside our organization:
Legal Basis and Purpose of Data Processing
The collection and processing of user data is absolutely necessary to access company-specific evaluations. The legal basis for processing personal data is the existence of relevant user consent pursuant to Art. 6(1)(a) GDPR.
Storage Period and Objection
Data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. In the case of collection for the provision of health services, deletion is carried out immediately as soon as the user account is closed by the user. Further storage is possible; however, in this case, remaining data will be completely anonymized so that later assignment to the user is no longer possible.
4.2. Ensuring Availability and IT Security
Scope of Data Processing
The processing of additional data is necessary to monitor and ensure the availability and IT security of our IT infrastructure.
The following categories of persons are affected by this data processing:
- Employees (administrators) of business partner companies
The following data is collected:
- Meta/communication data (e.g., browser and browser version, operating system and device information, IP address)
- Usage data (e.g., date and time of access, error messages)
Data transmission takes place to the following recipients outside our organization:
- AppSignal B.V.:
Address: P.O. Box 10212, 1001EE Amsterdam, Netherlands
Purpose: AppSignal is used to monitor and improve the performance and security of web applications.
Privacy Policy: https://www.appsignal.com/privacy-policy
Legal Basis and Purpose of Data Processing
The temporary storage and processing of this data is necessary to enable the provision of services to users. For example, the user's IP address must remain stored for the duration of use. Further storage and processing takes place to ensure the functionality of the platform, for the purpose of technical optimization, or to ensure the information technology security of our systems (e.g., to prevent overloads during DDoS attacks). These purposes constitute the legitimate interest pursuant to Art. 6(1)(f) GDPR.
Storage Period and Objection
Data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. In the case of collection to ensure performance and IT security, deletion is automatically carried out after 12 months. Data collected by AppSignal is automatically deleted after 30 days.
4.3. User Communication and Service Improvement
Scope of Data Processing
The following data is processed to communicate with end users, to obtain user opinions, and to improve the usability of the platform.
The following categories of persons are affected by this data processing:
- Employees (administrators) of business partner companies
The following data is collected:
- User profile data (e.g., name, email address, language settings)
- Usage data (e.g., user ID, IP address, browser and browser version, device information)
Data transmission takes place to the following recipients outside our organization:
- Smartlook.com s.r.o.,
Address: Šumavská 524/31, Veveří, 602 00 Brno, Czech Republic
Purpose: Smartlook is an analytics tool used to understand user behavior (e.g., navigation and inputs) in web applications.
Privacy Policy: https://help.smartlook.com/docs/privacy-policy
- Brevo:
Address: Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany
Purpose: Brevo is a service used, among other things, to organize the sending of emails.
Privacy Policy: https://www.brevo.com/de/legal/privacypolicy
Legal Basis and Purpose of Data Processing
The temporary storage and processing of this data serves to obtain user opinions and feedback and is necessary for improving the usability of the application. For example, faulty functions or unused functionalities can be more easily identified and improved. These purposes constitute the legitimate interest pursuant to Art. 6(1)(f) GDPR.
Storage Period and Objection
Data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. In the case of collection for service improvement, deletion is carried out immediately as soon as the user account is closed by the user. Data collected by Smartlook is automatically deleted after 12 months. Further storage is possible; however, in this case, remaining data will be completely anonymized so that later assignment to the user is no longer possible.
If personal data concerning you is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller.
Right to Information
You may request confirmation from the controller as to whether personal data concerning you is being processed by us. If such processing is taking place, you may request information from the controller about the following:
The purposes for which the personal data is processed.
The categories of personal data being processed.
The recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed.
The planned duration of storage of the personal data concerning you or, if specific information is not possible, criteria for determining the storage period.
The existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing.
The existence of a right to lodge a complaint with a supervisory authority.
All available information about the source of the data if the personal data is not collected from the data subject.
The existence of automated decision-making, including profiling, pursuant to Art. 22(1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
You also have the right to request information about whether personal data concerning you is being transferred to a third country. In this context, you may request to be informed about appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.
Right to Rectification
You have the right to rectification and/or completion if the processed personal data concerning you is incorrect or incomplete. The controller must carry out the rectification without undue delay.
Right to Restriction of Processing
You may request the restriction of processing of personal data concerning you under the following circumstances:
If you contest the accuracy of the personal data concerning you for a period that enables the controller to verify the accuracy of the personal data.
If the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead.
If the controller no longer needs the personal data for the purposes of processing, but you need it for the establishment, exercise or defense of legal claims, or.
If you have objected to processing pursuant to Art. 21(1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override your grounds.
If the processing of personal data concerning you has been restricted, such data may – apart from being stored – only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another person or for reasons of important public interest. If processing has been restricted according to the above conditions, you will be informed by the controller before the restriction is lifted.
Right to Erasure
You may request that the controller delete personal data concerning you without undue delay, and the controller is obliged to delete this data without undue delay if one of the following grounds applies:
The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
You withdraw your consent on which the processing was based pursuant to Art. 6(1)(a) or Art. 9(2)(a) GDPR, and there is no other legal basis for the processing.
You object to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21(2) GDPR.
- The personal data concerning you has been unlawfully processed.
- The erasure of personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
- The personal data concerning you has been collected in relation to information society services offered pursuant to Art. 8(1) GDPR.
If the controller has made personal data concerning you public and is obliged to erase it pursuant to Art. 17(1) GDPR, the controller shall take reasonable steps, including technical measures, taking into account available technology and implementation costs, to inform controllers processing the personal data that you, as the data subject, have requested the erasure of all links to such personal data or of copies or replications of such personal data.
The right to erasure does not exist insofar as processing is necessary:
- For exercising the right of freedom of expression and information
- For compliance with a legal obligation requiring processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
- For reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) GDPR.
- For archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89(1) GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or.
- For the establishment, exercise or defense of legal claims.
Right to Notification
If you have exercised your right to rectification, erasure or restriction of processing vis-à-vis the controller, the controller is obliged to notify all recipients to whom personal data concerning you has been disclosed of this rectification or erasure of data or restriction of processing, unless this proves impossible or involves disproportionate effort. You have the right vis-à-vis the controller to be informed about these recipients.
Right to Data Portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, where:
- The processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9.
- (a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR, and (2) the processing is carried out by automated means.
In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another controller, where technically feasible. The freedoms and rights of other persons must not be adversely affected by this. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Right to Object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR.
The controller shall then no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.
Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing. If you object to processing for direct marketing purposes, the personal data concerning you shall no longer be processed for such purposes.
You have the right to withdraw your data protection consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Right to Lodge a Complaint with a Supervisory Authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes in legal provisions or in the data processing we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part or other individual notification.
