I. Controller, Scope

Klein Keepers is a service provided by Klein Keepers UG (hereinafter also referred to as “Klein Keepers” or “Provider”), acting as Controller in accordance with relevant data protection provisions. Please find full company and contact details on the website.

The protection of personal data has the highest priority for us. We would therefore like to inform you about which data we collect when, and how we process your personal data. This privacy notice describes the collection and processing of personal data on the website (desktop app) www.website.web (hereinafter referred to as "Website") and our mobile app (“App”). To the extent this privacy notice doesn’t explicitly discriminate, it applies both to the Website and the App (together “Service”).

II. General information about data processing

1. Purposes of processing

In principle, we only process personal data of users as necessary to provide a functional Service, our contents and to provide our services.

2. Legal basis for the processing of personal data

We mostly process personal data according to on one of the following legal bases:

3. Data erasure and retention time

In principle and unless otherwise stated, your personal data will only be stored until the purpose of the collection and storage is achieved. If the storage is based on your consent, personal data can be stored as long as you do not revoke such consent.

Furthermore, data may be stored if it is required by European or national legal provisions, laws or regulations which we are subject to. Personal data will be blocked or deleted if the retention period set forth by the any such regulations expires, unless further storage is necessary for the conclusion or fulfilment of a contract.

4. Processors

In order to provide our services, we may cooperate with selected third-party providers who process data on our behalf (“Processors”). This applies for instance to hosting providers, authentication service providers, technical security and debugging providers, e-mail and messaging services providers, video streaming providers, payment services providers. Such Processors shall only process your personal data on our behalf. As far as legally required, we have entered into agreements pursuant to art. 28 GDPR with Processors processing your personal data on our behalf.

5. Transfer to third countries

Unless otherwise stated, all data processing operations take place within the EU or the EEA countries.

Data processing operations carried out by third-party providers established outside the mentioned geographical area may be carried out in part or in full in the countries the respective providers are based in, in accordance with the relevant and applicable data protection regulations.

A transfer of personal data outside the EU or the EEA shall only take place on the basis of on an adequacy decision of the European Commission or subject to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. A list of current adequacy decisions is available on the European Commission's website.

III. Processing of personal data in general

Regardless of whether you take advantage of any of our services we automatically collect data about your use of the Website. This includes in particular the accessed URL, access date and time, transferred data volume, http status code of the access reply, web browser type and operating system, HTTP referrer, as well as IP address. This information is not associated with your person.

We collect and process such data to ensure Website operation and availability. In addition, it is used to analyse, store and evaluate information about user behaviour anonymously and to continuously improve and further develop our service. We only store your IP address in the log files for a limited period of time, if this is necessary for security purposes.

These purposes constitute our legitimate interest, which justifies data processing pursuant to art. 6 par. 1 lit. f) GDPR.

IV. Processing of personal when creating an account as legal guardian

When creating a User account, we store the following data: username, password, e-mail, profile picture. We need this information in order to assign your account uniquely to yourself and make sure no duplicate accounts are created. The provision of all mentioned data is required to perform the contract you close with us regarding the use of our services. Failure to provide it so will result in unavailability of our services. Once you’ve created an account, you may provide further information and data, such as a family description, phone number, a video presentation on a voluntary basis.

The legal basis for processing is art. 6 par. 1 lit. b) GDPR.

V. Processing of personal when creating an account as child carer

Once you’ve created an account, you may provide further information and data, such as information about personal experience, profile pictures, phone number, a video presentation, certificates and qualifications, references or recommendations, on a voluntary basis

The legal basis for processing is therefore art. 6 par. 1 lit. b) GDPR.

Third-party login

On our Service, you can sign in via your third-party account. The legal basis for the use of such plug-ins is Art. 6 para. 1 lit. a) GDPR, i.e. the integration only takes place with your consent. The plug-in provider processes the data collected about you as usage profiles and uses them for advertising, market research and/or the needs-based design of its Service. Such evaluation is carried out in particular (even for users who are not logged in) to display needs-based advertising and to inform other users of the social network about your activities on our Service. You have the right to object to the creation of these user profiles by contacting the respective plug-in provider. The data is transferred regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in to the plug-in provider, the data collected about you will be directly associated with your existing account with the plug-in provider. You can withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. The easiest way to withdraw your consent is via our consent manager or via the functions of the social media providers. Further information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the privacy policies of these providers listed below:

Apple: https://www.apple.com/legal/privacy/en-ww/

Google: https://policies.google.com/privacy?hl=en

VI. Processing of personal when submitting a booking request

When legal guardians request the services offered by child carers on our Service, we will collect the following data: booking details, service address, date and time. Should you have already specified such information within your account, we will extract it from there. While we collect information about which payment method you choose, we do not collect payment data.

The legal basis for processing is therefore art. 6 par. 1 lit. b) GDPR.

Video Stream

If legal guardians and child carers decide to share a video stream (e.g. to introduce themselves to each other or to check in with the child carer during the assignment) we make this option available by cooperating with Twilio, a service provided by Twilio Ireland Limited, a company registered in the Republic of Ireland, whose registered address is 70 Sir John Rogerson’s Quay, Dublin 2, D02 R296, Ireland. Twilio thereby acts as our processor and has entered into the relevant contractual agreements with us. Neither Twilio nor we access, filter, monitor or otherwise take notice of the data (including but not limited to video footage, sound, metadata, names, email addresses etc.) exchanged via video stream. Such data may be temporarily stored on Twilio’s servers within the European Union / EEA or in the USA. Twilio is certified under the US/EU and US/CH Privacy Framework.

The legal basis for processing is therefore art. 6 par. 1 lit. a) GDPR.

VII. Processing in compliance with a legal obligation

Please note that, in addition to what specified in this privacy notice, your data may be processed in compliance with legal obligations which we are subject to. For instance, we may be obliged to store your data for a legally determined period to comply with tax law provisions. Please contact us in case you want to learn further details about such processing activities.

In such cases the legal basis of the processing is art. 6 par. 1 lit. c) GDPR.

VIII. Direct e-mail marketing (DEM)

You can subscribe to our newsletter by entering your e-mail address in the respective form. You will then receive an automatic confirmation e-mail to the address you entered, which contains a link. The registration process is only completed once you confirm it by navigating to that link. We use your email address to send you updates, information and content related to our own services and programs. The data will not be passed on to third parties.

You can withdraw your consent to receive newsletters at any time without stating reasons by following the instruction provided in each newsletter sent, or by sending us an unambiguous notice at info@kleinkeepers.com. We will inform you about the right to withdraw your consent upon subscription to the newsletter service and within each newsletter sent.

The legal basis for processing your personal data is art. 6 par. 1 a) GDPR.

IX. Cookies and Trackers

In order to improve user experience of our Website and to enable selected functions, we implement cookies or other tracking technologies (hereinafter jointly referred to as “Cookies”) on various pages. These are small data sets being stored on your device. Some of the Cookies we use expire after the end of the browser session, i.e. after closing your browser (so-called session Cookies). Other Cookies remain on your device and enable us or our partner companies to recognize your browser or device on your next visit (persistent Cookies).

You can set your browser preferences in order to be notified about the setting of Cookies and decide individually about accepting or refusing them in certain cases or generally. You can also manually delete Cookies from your device at any time.

Failure to accept Cookies may result in minor limitations in our service’s functionalities. Cookies are stored on the user's computer and from there transmitted to our site. Therefore, you as a user have full control over the use of Cookies. You can deactivate or restrict the transmission of Cookies by adjusting the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If Cookies are deactivated for our Website, it may no longer be possible to use all functions of the Website in full. You can also manage your cookie preferences via recognized third-party services such as http://www.youronlinechoices.eu/ (if you’re based in the EU).

2. Strictly necessary Cookies

Some of the Cookies we use are strictly necessary to allow us to deliver the service you requested or to operate our Website. Some elements of our Website require that your browser be identified after page changes. Such technical Cookies may collect personal information about you, such IP address, log-in information, etc.

The processing of personal data through strictly necessary cookies – if any – is art. 6 par. 1 lit. f) GDPR. In case such cookies are necessary as a pre-contractual measure or for performing a contract with you, the legal basis is art. 6 par. 1 lit. b) GDPR.

3. Other Cookies

In addition, we use third-party Cookies to monitor and evaluate user behaviour for statistics and market analysis purposes. Such Cookies are provided by third parties and implemented in our Website. Please refer to the following sections for details. Such Cookies allow us to analyse your use of our service and improve it continuously. Analytics allow us to offer you a better service that meets your interests better.

Unless otherwise specified, the legal basis of processing through other Cookies mentioned below is your consent pursuant to art. 6 par. 1 lit. a) GDPR (consent). Unless otherwise specified, the lifetime of Cookies used based on your consent expires upon withdrawal of your consent.

GOOGLE ANALYTICS

We implement "Google Analytics". Google Analytics is a web analysis service provided by Google Inc. The information generated by the Google Analytics Cookie about your use of our Website is generally transmitted to and stored by Google on servers in the United States. IP anonymization has been activated on our Website: this means that the IP address of users based within the European Union or the European Economic Area is abridged, and therefore anonymized, before being transferred abroad. Only in exceptional cases is the unabridged IP address transferred to a Google servers in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Website, to draft reports about Website activity and to provide us with other services relating to Website and Internet use. The IP address transmitted by your browser in the context of Google Analytics is not put in relation with other Google data. You may object to the use of Cookies by selecting the appropriate settings on your browser, however please note that doing so may result in limited functionality of this Website. You can also prevent Google from collecting the data generated by the Cookie and relating to your use of the Website (including your IP address) and processing this data by installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en. To find out further information about how Google handles personal data, please refer to Google's privacy policy: https://policies.google.com/privacy?hl=en.

X. Data Subjects’ rights

As a data subject, you have the following rights pursuant to the GDPR:

Your right of access - You have the right to ask us for copies of your personal information. Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances. Your right to notification - If you have exercised your right to have the Controller rectify, erase or limit the processing, the Controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data concerning you have been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients. Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances. Please find further details in the box below this section. Your right to withdraw consent - You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances. You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please reach out for us at the contact details indicated on the Service if you wish to make a request. Your right to file a complaint You can also complain to a data protection authority if you do not agree on how we have used your data.

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 Article 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.