Privacy policy of the platform www.careoline.life
We, Careoline.Life AG (Theilerstrasse 13, 6300 Zug, Switzerland) are the operator of the platform www.careoline.life (hereinafter referred to as “Website”, “Platform”) and are responsible for the data processing specified in this privacy policy, unless otherwise statedl. For data processing in the sole responsibility of the coaches who offer you services on our platforms, the data protection information of the coaches applies.
Your trust is important to us. That is why we take the issue of data protection seriously and take the necessary technical and organizational measures to ensure data security. For us, it goes without saying that we comply with the legal requirements of the Swiss Federal Data Protection Act (FADP), the Ordinance to the Federal Data Protection Act (FADP), the Telecommunications Act (TCA) and other provisions of Swiss data protection law. We also consider it a matter of course to comply with other regulations that may be applicable in individual cases, such as the EU General Data Protection Regulation (EU GDPR). .
In order for you to know what personal data we collect from you and for what purposes we use it, please take note of the information below. Please note that the following information will be reviewed and amended from time to time. We therefore recommend that you consultthis privacy statement regularly.
1. data processing when visiting our website
When you visit our website, our servers temporarily store each access in a log file. The following data is collected without your intervention and stored until automated deletion by us:
- the IP address of the requesting computer,
- the date and time of the access,
- the name and URL of the file accessed,
- the website from which the access was made,, if necessary with the search word used,
- the operating system of your computer and the browser you are using (including type, version and language setting),
- device type in the case of access by cell phones
- the city or region from where the access took place
- the name of your Internet access provider.
The data is collected and processed for the purpose of enabling the use of our website (connection establishment), to ensure system security and stability on a permanent basis, as well as for error and performance analysis and enables us to optimize our website.
In the event of an attack on the website’s network infrastructure or suspicion of other unauthorized or abusive website use, the IP address and other data will be evaluated for the purpose of clarification and defense and, if necessary, used in criminal proceedings to identify and take civil and criminal action against the users concerned.
In the purposes described above, there is our legitimate interest in data processing within the meaning of Art. 6 para. 1 lit. f EU-DSGVO. 1 .. .
Finally, when visiting our website, we use cookies as well as applications and tools that are based on the use of cookies. In this context, the data described here may also be processed. For more details, please refer to sections 8and9 of this Privacy Policy.
2. data processing when using the chat function and forms without registration
Upon arrival on our platform, you have the option of using our chat function, or a form, – to find out which offers might be of interest to you. In this context, in addition to the technical data mentioned in section 1 1 we only process the answers you provide and this exclusively in order to make you personalized suggestions for suitable services. A connection with your name will only be made if you register on our platform immediately after the chat,, or after sending the form., . Otherwise, your information will be deleted again after the browser session ends.
our legitimate interest within the meaning of Art. 6 para. 1 lit. f EU-DSGVO in providing that chat andform functionand, with regard to the linking of thedata with the Ecustomer account, the fulfillment of thecontract within the meaning of Art. 6 para. 1 1 lit. b EU-DSGVO.
3. Data processing when registering as an end customer.
The opening of a user account is required for the use of services on the platform. . In doing so, we collect the followinh data, within mandatory data marked with an asterisk (*) in the corresponing form:
Personal data:
- Name
- First name
- Residental address
- Birthday
- Company and company address for corporate clients
- legal representative incl. declaration of consent
Login data:
- E-mail address
- Password
Furhter data:
- Languages
- Gender
We use the personal data to clearly establish your identity before concluding the contract and to verify the requirements for registration as an end customer. The email address and password together serve as login data and thus to ensure that the correct person under your details is using the platform. We also need your email address for verification and confirmaition of the account opening and for future communication with you required for the execution of the contract. In addition, this data is stored in the customer account for future contract conclusions,especially with coaches as registered users,, in accordance with the goal of ourplatform.
We also use the data to provide an overview of the services received and a simple way to manage your personal data, to administer our website and the contractual relationships, i.e. to establish, define the content of, process and amend the contractual relationships concluded with you via your user account.
The legal basis for this data processing is in this respect the necessity for the implementation of pre-contractual measures and the necessity for the fulfillment of the contract between us and you within the meaning of Art. 6 para. 1 lit. b EU-DSGVO. 1 .. .
We process the informationon language and gender in order to show your offer suggestions on the platformthat are best tailoredto your profile or your personalneeds (matching)for the statistical collection and evaluation of the selected offers and thus for the optimization of our suggestions and offers.
The legal basis for for processing of your data for the preceding purpose lies in your consent pursuant to Art. 6 (1) lit. a EU-DSGVO. 1 .. . You can revoke your vonsent at any time by removing the information from the customer account again.
4. Data processing when registering as a coach
In order to offer services on our platform as a coach, it is necessary to open a user account. In doing so, we collect the following data, with mandatory data marked with a asterisk (*) in the corresponding form:
Personal and contact details
- Name
- First name
- Place of residence
- Birthday
- Gender
- Phone number
Company details
- Company
- Legal relationship to the company (owner/employee)
- Document (extracts from the commercial register/ confirmation of employer)
- VAT number
Furhter data:
- Languages
- Work topics
- Coaching methods
- Training
- Biography
- Certificates
- Vision
- Third party email address
- Means of payment/ settlement
We use this information to clearly establish your identity before entering into the contract and to verify the requirements for registration, in particular your qualifications, as a coach. The email address and password together serve as login data and thus to ensure that the corrects person under your details is using the platform. We also need your email address for VERIFICATION and confirmation of the account opening and for future communicaition with you required fot the execution of the contract.
In addition, this data is sored in the user account for future contract conclusions with end customer and thus in order to establish a simple and efficient connection between end customers and coches as registered users in accordance with the purpose of our platform. For this purpose, the information is displayed int he public profile of the coach, whereby a subsequent adjustment of the wording ny the coach is possible, as long as it is still in accordance with the specifications of the GTC.
We also use the data to provide an overview of the services and remuneration billed, as well as an easy way to manage your personal data, to administer our website and the contractual relationships, i.e. extablish, define the content of, process and change the contractual relationships concluded with you via your user account.
The legal basis for this data processing is in this respect the necessity for the implementation of precontractual measures and the necessity fot the fulfillment of the contract between us and your within the meaning of Art. 6 para 1 lit. b EZ-DSGVO. 1 .. .
We process the further informationon qualification in order to propose your offeredservices to those end customers for whom these appear to be interesting according to their profile or their personal needs( matching),for the statistical recording and evaluation of the selected offers and thus for the optimization of our proposals and offers. The specification of a possibly additional third-party e-mail address can be set up to enable synchronizationwith one of your other calendars..
The legal basis of the processing of your data for the aforementioned purposes lies in our legitimate interest within the meaning of Art. 6 1 (1) lit. f EU-DSGVO. in the provision of interesting product suggestions and a soímple appointment booking optioon for end customer.
5. Data processingg when using the services of the coaches.
5.1 Responsibility of the coaches
If you use or want to use services of coaches on our platform, the coaches are responsible for the data processing and their information on data protection is authoritative.
5.2 Service processing
In addition, in the case of a booking of a service by your the personal data from your customer account will ne transmitted to the coaches concerned. The data is subsequently stored in his user account, supplemented with the purchased and planned services and can be managed by the coach.
In order to process the contractual relationship and to determine the costs (including commission), we collect data about the services you have purchased (“service data”). This includes – depending on the service – the following information:
- Description of the booked or purchased service
- Date and time of booking
- Effective duration of the coaching session
- Price of the planned sessions
- Planned/actaual time and duration of the coaching session
- Duration of the coaching session entered manually by the coach
- VAT-liability of the coach
- VAT-liability of the client
The legal basis for this data processing is our legitimate interest within the meaning of Art. 6 (1) lit. 1 EU-DSGVO in providing our platfrom for connecting coaches and end customers and for nilling with a view to collecting commisions claims. 1 .. .
5.3 Payment processing
Depending on the offer, a request for payment of the amount owed is then made before or after the service is used. For the processing of payments we use the services of P Postfinance AG. (Mingerstrasse 20, 3030 Bern, Switzerland). As part of the payment process, personal data is collected in the Postfinance (esp. e.g. name and address of the user, account data, credit card data, invoice amount, currency, etc.).). The processing and any associated data collection is carriedoutforthe execution of the contract. Further information on this and on theguarantees measures taken by Postfinance to ensure adequate data protection can be found here: https://www.postfinance.ch/de/unternehmen/produkte/e-commerce/postfinance-checkout-all-in-one.html.
Your data will be stored as part of the payment process by the software provider customweb GmbH, Winterthur in the data cloud of Amazon Web Services EMEA SARL, Luxembourg (subsidiary of Amazon Web Service Inc., USA) on their servers in Ireland and checked by the firewall of Cloudflare Inc., USA.
The legal basis for any data processing hereby attributed to us is our legitimate interest in being involved in the use of an efficient payment service within the meaning of Art. 6 para. 1 lit. f EU-DSGVO. 1 .. .
5.4 Notes and tasks
On the platform, we offer coaches the possibilityto make notes on coachingsessions with end customers in a protected area, such as the need described by the end customer, the coach´s impressions and thoughts on possible measures. These notes can be provided to the end customer, depending on the agreement between the coach and end client. At the same time, a coach can define “tasks” and assign them to the end customer so that they can access them in their customer account.. The notes and tasks may only be passed on to other coaches with the express consent of the end customer. After a change of coach, the previous coach still has access to the data on the platformfor a transition period of a maximum of 14 days.
The legal basis for the processing carried out by us in this context is our legitimate in the provision and the legitimate interest of the coaches in the use of an efficient platform for the provision of services within the meaning of Art. 6(1) 1 .. f EU-DSGVO. Any storage of data requiring special protection or special categories of personal data will only take place with your express explicit consent within the meaning of Art. 9 (2) 2 lit.. a EU-DSGVO.
5.5 Video-telephony function
When services are used using the video telephony function, processing of further categories of data also takes place in addition to the above-mentioned data, whereby these depend on the respective service and the information exchanged by the users themselves in thecontextof thevideo sessions :
- Basic data of the Sessionandof the participants : e.g. name, participation- time, duration and subject of the ses sion etc.
- Communication content i.e. information in audio, video or text from that you yourself transmit to the participants by using the service and interacting, e.g. your statements in image and sound, chat content or screen presentations.
- Log data relating to the connection as listed in section 1(e.g. the IP address of the participants).
We process this data to establsih the connection between the individual participants and to offer an attractive opportunity for interaction between coaches and participants on the platform.. Our legitimate interest in using the tool toprovide an interactive service is the legal basis for the use of the tool and the data processing that takes place in the process (Art. 6. 1 lit. f EU-DSGVO). when using the video telephony tool, cookies are also. used. Please refer to the informationin section 8.
The posibility of accessing the personal data that accumulates is basically limited to the respective participants of the sessions. . In addition, we potentially have access to the data, but only process it if and to the extent, that this is necessary to rectify faults or for billing purposes. Finally, under certain circumstances, the provider of the “meet.jit.si“, 8×8, Inc. (675 Creekside Way, Campbell, CA 95008, USA), may also potentially have access to the data and process it to provide the video telephony tool.
More information about this and the safeguards taken by the provider to ensure adequate data protection in the USA can be found here: https://jitsi.org/meet-jit-si-privacy/. In addition, the infrastructure provider microsoft (One Microsoft Way, Redmond, WA 98052-6399, USA) may have access to certain data through its Azuge service. DetialsDetails about Miscrosoft´s data processing activities as described in the Privacy policy can be found here https://azure.microsoft.com/de-de/support/legal/. The legal basis for any data processing attributed to us in this context is our legitimate interest in providing an interactive service (Art. 6. 1 lit. f EU-DSGVO).
6. Data processing when ardering/booking services of the platform provider.
Insofar you wish to order or book services onthe platform that are offered by ourselves, , we require various data for the processing of the contract. we collect – depending onthe product or service – the following data, whereby mandatory data is marked with an asterisk (*) in the corresponding form:
- Data from the user account
The data will be subsequently be stored in your user account and our database (s. section 9.1). Insofar as this is necessary for the fulfillment of the contract, we will also pass on the required information to any third-party service providers ( e. g. event erganizers). The legal. basis for this ist processing is the fulfullment of the contract with you according to Art. 6.1 lit. b EU-DSGVO. Furthermore, for oayment processing, please note the information in section 5.3.
The provision of data that is not marked as mandatory is voluntary. We process this data in order to tailor our offer to your personal needs in the best possible way, to facilitate the processing of contracts, to contact you via an alternative communication channel if necessary with a view to fulfilling the contract, or for statistical collection and evaluation to optimize our offers. The voucher numberis the n used to redeem your voucherwhen ordering/ booking the services yourequested.The legal basis for this data processing is your consent within the meaning of. Art. 6 para. 1 1 lit. a EU-DSGVO.
7. data processing when submitting ratings
Whíthin the framework of the rating function on this platform , in adition to your rating and any comment , information on the time of creation of the rating and your name are stored and published b on the platform.. The lagal basis for the data processing is your consent within the meaning of Art. 6(1) 1 lit a EU-DSGVO.
We reserve the right to delete unlawful ratings and contact you in case of suspicion and . ask you to comment. The legal basis for these processing operations is our legitimate interest within the meaning of Art. 6(1) 1 lit. f EU-DSGVO in providing the comment and reting function and preventing abuse when using it.
8. Cookies
Cookies help in many aspects to make your visit to our platform easier, more pleasant and more meaningful. Cookies are information file that your web browser stores on your computer’s hard drive or memory when you visit our website. Cookies are assigned identification number that identify your browser and allow the information contained in the cookie to be read.
We use cookies for various purposes that are necessary for your desired use of the website. For example, we use cookies to be able to identify you as a registered user after you have logged in, without you having to log in again each time you navigate the various sub-pages. The provision of the function for booking services is also based on the use of cookies. The same applies to the use of thevideo telephony tool,in whichthe settings of your camera and microphoneare stored using cookies. The legal basis for this data processing is our legitimate interest within the meaning of Art. 6 (1) lit. f EU-DSGVO 1 in. providing a user-friendly up-to-date website.
In addition, we also use cookies for analysis/marketing purposes (please refer to section 9).
Most internet browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a message always appears when you receive a new cookie. On the following pages you will find explanations of how you can configure the processing of cookies in selected browsers.
Disabling cookies may prevent you from all features of our platform.
9. Use of your data for marketing purposes
9.1 Central data storage and analysis in the CRM system
Insofar as a clear allocation to your person is possible, we will store and link the data described in this data protection declaration, i.e. your personal detailsyour messages, your performance data as well as your click behavior on our websites in a central database. This serves the efficient administration of customer data and allows us to adequately respond to your requests and enables the efficient provision of the services you have requested and processing of the associated contracts. The legal basis for this data processing is our legitimate interest within the meaning of Art. 6 (1) lit. f EU-DSGVO in the efficient management of user data. .. . .
We evaluate this data in order to further develop our offers in a needs-oriented manner and to display and suggest . the most relevant informationand offers to you. We also use methods that predict possible future bookings based on your platform usage. The legal basis for this data processing is our legitimate interest within the meaning of Art 6(1) lit. f EU-DSGVO in carrying out marketing measures.
9.2 Tracking-Tools
9.2.1 General informations
For the purpose of demand-oriented design and continuous optimization of our pages, we use the web analysis services listed below. In this context, pseudonymized usage profiles are created and cookies are used (please also refer to section 8). The information generated by the cookie about your use of this website is usually transmitted together with the data listed in section 1 to a server of the service provider, where it is stored and processed; this may also involve transmission to servers in the USA. In the case, we ensure through contractual arrangements with these companies that your data is adequately protected atthese companies.
By processing the data, we obtain, among other things, the following information:
- Navigation path followed by a visitor on the site (including content viewed and products selected or purchased);
- the lenght of time spent on the website or sub-page,
- the sub-page on which the website is left,
- the country, region, or city from where an access is made,
- end service (type, version, color depth, resolution, width and height of the browser window) and
- returning or new visitors.
On our behalf, the provider will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for us and providing other services relating to website activity and internet usage for the purposes of market research and tailoring these internet pages to your needs. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf.
The legal basis for rhis data processing with the following tools is your consent within the meaning of Art. 6. 1 .. 1 lit a EU-DSGVO. You can revoke your consent at any time by rejecting orswitching off the relevant cookies in the menu bar of your web browser (see section 8) or by making use of the options described below.
9.2.2 Google Analytics
We use the web analysis service Google Analytics from Google Ireland Limited (Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland) bzw. Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) (“Google”).
In the process, the described data about the use of the website may be transmitted to the services of Google LLC. in the USA for the explained processing purposes ( see section 9.2.1). . The IP address is shortened by activating IP anonymization („anonymizeIP“) on this website before transmission within the Member States of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. In these case, we ensure through contractual guarantees that Google complies with a sufficient level of data protection. According Google, in no case will the IP address be associated with other data concerning the user.
Users can prevent the collection of the data generated by the cookie and related to the website use by the user concerned (including the IP address) to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de
http://tools.google.com/dlpage/gaoptout?hl=de
The legal basis of the ata processing mentioned here is your consent within the meaning of Art 6. 1 lit. a EU-DSGVO.
9.3 Affiliate-Marketing
We use so-called affiliate Marketingtechnologies on our platform. This involves analyzing your user behavior on partner websites in order to be able to suggest services tailored to you individually when you visit our platform. For this purpose, information stored in a cookie is read (see also section 8).
The legal basis for this data processing is your consent within the meaning of Art. 6 para. 1 1 .. 1 lit a EU-DSGVO. You can revoke your consent at any time by rejecting orswitching off the relevant cookies in the menu bar of your web browser (see also section8).
10. Disclosure to third parties and access ny third parties
Your data will not be resold by us. However, your personal data will be passed on ifthis is necessary for the fulfillment of the contract requested by you, i.e. for example to the coach who will conduct the requested coaching session. .. In the case of this disclosure, the fulfillment of the contract tithin the 1 meaning of Art. 6 (1). b EU-DSGOV is the legal basis.
A disclosure is further made to selected service providers and only to the extent necessary for the provision of the service. Furthermore, various third-partyservice providershave already been explicitly mentioned in this privacy policy, such as in the sections on marketing. Incidentally, these are e.g. IT support service providers, advertising agencies, consulting companies. . One service provider that may potentially have access to the personal data collected via the platform is microsoft our hosting provider cyon GmbH (Brunngässlein 12, CH – 4052 Basel),() as the provider of Azure Cloudservices , through which . , like us, we host our platform. The platform is hosted on servers in Switzerland.
In addition, your data may be disclosed , in particular to public authorities, legal advisors or collection agencies, if we are required to do so by law or if this is necessary to protect out rights, in particular to enforce claims arising from our relationship with you. Data may also be disclosed if another company intends to acquire our company or parts thereof and such disclosure is necessary to conduct due diligence or to complete the transaction.
Our legitimate interest within the meaning of Art. 6 (1) lit. f EU-DSGVO forms the legal basis for this data transfer. 1 .. .
11. Transfer of personal data abroad
We are also entitled to transfer your personal data to third parties abroad if this is necessary for the purposes stated in this data protection declaration (see esp. sections 5.3, 5.5, 9 and 10) 5.3, 5.5, 9 . 10). In doing so, the legal requirements for the disclosure of personal data to third parties will, of course, be complied with. If the country in question does not have an adequate level of data protection, we ensure through contractual arrangements with these, companies that your data is adequately protected at these companies.
12. Your rights
You can object to data processing at any time.. you also have the following rights:
Right to information: You have the right to request at any time, free of charge, to inspect your personal data stored by us when we process. This gives you the opporunity to check what personal data we are processing about you andthat we are using it in accordance with applicable data protecting.
Right to rectification: you have the right to have inaccurate or incompletepersonal data rectified and to be informed about the rectification. In this case, we will inform the recipients of the data concerned of the adjustments made, unless this is impossibleor involves disproportionate effort.
Right to deletion: you have the right to have your personal data deleted under: certain circumstances. In individual cases, particularly in the case of legal retention obligations, the right o deletion may be excluded. In this case, the deletion may be replaced by a blocking of the data if the condictions are met.
Right to restriction of processing: : You have, under certain conditions, the right to request that the processing of your personal data be restricted.
Right to data transfer: If the legal requirements are met, you have the right to receive from us, free of charge, the personal data that you have provided to us in a readable format.
Right of withdrawal: In principle, you have the right to withdraw aour consent at any time. However, processing activities based on your consent in the past will not become unlawful as a result of your revocation. To exercise yourrights , please
send us an e-mail to the following address:
Right to lodge a complaint: You have the right to lodge with a competent supervisory authority against the way in which your personal data is processed.
13. Data security
We use appropriate technical and organizational security measures to protect your personal data stored with us against manipulation, partial or complete loss and against unauthorized access by third parties. Our security measures are continuously adapted in line with technological developments. However, the transmission of information via the Internet and other electronic means always involves certain security risks and we cannot guarantee the security of information transmitted in this way.
When your registrer for a user account with us , access to your account is only possible after you have entered your personal login data. You should always treat your login data confidentially and close the browser window when you have finished communicating with us, especially if you share the computer with others.
We also take internal company data protection very seriously. Our employees and the service companies commissioned by us are obligated by us to maintain confidentiality and to comply with the provisions of data protection law. Furthermore, they are only granted access to personal data to the extent necessary.
14. retention periods
We store personal data only as long as it is necessary to carry out the above processing within the framework of our legitimate interest. Contractual data will be stored by us longer, as this is required by legal retention interest. Contractual data will be stored by us longer, as this is required by legal retention obligations. Retention obligations that require us to retain data result from accounting regulations and tax regulations. According to these regulations , business communication, concluded contracts and accounting vouchers must be kept for 10 years. As far as we no longer need this data to perform services for you, the data will be blocked. This means that the data may then only be used for accounting and tax purposes.
15. contact person
If you have any questions about data protection on our website or would like to exercise your rights, please contact our contact person for data protection by sending an e-mail to the following address:
