Privacy Policy of Good Souls Pflegevermittlung GmbH
We are pleased that you are visiting our website and thank you for your interest in our company and our services. Protecting your privacy while you use our website and services is very important to us. We strive to establish and maintain a trusting business relationship with our caregivers, those seeking care, business partners, cooperation partners, and other interested parties.
The confidentiality and integrity of your personal data is of utmost importance to us. We therefore process your data carefully, for specific purposes, and only to the extent necessary, in accordance with your consent and applicable data protection regulations, in particular the General Data Protection Regulation (“GDPR”), the German Federal Data Protection Act (“BDSG”), and the regulations governing cookies and similar technologies. If cookies or similar technologies that are not technically necessary are used on our website, this will only occur after you have given your consent via the consent management or cookie banner on our website.
The following data protection information explains how good souls Pflegevermittlung GmbH collects, processes, uses, stores and, if necessary, passes on the personal data of its users, prospective customers, customers, cooperation partners and website visitors.
1. Who is the responsible body for the data processing operations?
Responsible party within the meaning of the General Data Protection Regulation is:
good souls Pflegevermittlung GmbH
Brunowall 28
59494 Soest
Germany
Managing Director:
Michael Karl Bogensperger
Andrei Valentin Serban
Email: [enter]
Phone: [enter]
Hereinafter also referred to as “good souls,” “we,” or “us.”
good souls operates a digital platform for the collection, processing, and mediation of data related to care and support services. The platform is particularly aimed at:
natural persons who wish to be placed as carers or nursing assistants, natural or legal persons who are looking for care or support staff, companies and cooperation partners who wish to enter into business contact with good souls.
As far as this privacy policy does not expressly provide otherwise, good souls Pflegevermittlung GmbH is the controller for the personal data processed through this website, via online forms, in the context of contact, during the execution of placement processes, and in the context of business communication. The contents that a privacy policy must include are particularly derived from Art. 13 GDPR.
2. Data Protection Officer
As far as legally required, we have appointed a data protection officer. He can be reached at the following contact details:
Data Protection Officer
good souls Pflegevermittlung GmbH
Brunowall 28
59494 Soest
Germany
Email: [enter]
If no data protection officer has been appointed, you can contact the details mentioned under item 1 for data protection enquiries.
3. When does good souls collect and process personal data?
good souls collects and processes your personal data, particularly in the following cases:
- when you visit our website,
- when you visit our website,
- if you contact us directly, for example through our website, by email, by phone, or through other communication channels, if you register as a carer or nursing assistant or transmit data to us for this purpose,
- if you, as a family, a person seeking care staff, a company, a care facility, a hospital, a home, or any other organization, make a request for care or support staff, if you, as a company or cooperation partner, contact us to enquire about our services or a collaboration,
- if you send us documents, proofs, certificates, or other mediation-relevant documents,
- if you subscribe to our newsletter or other information,
- if you provide us with additional information in the context of ongoing mediation or business processes,
- when data is transmitted to us by third parties, such as legal representatives, relatives, authorised persons, cooperation partners, or business partners, provided that the necessary data protection legal requirements are met, if we need to process or disclose personal data for legal reasons,
- if we need data to assert, exercise, or defend legal claims.
Please help us keep your information up to date by promptly notifying us of any changes to your personal data, especially your contact details, availability, or any other information relevant to mediation.
4. What data can be collected about you?
The following categories of personal data can be collected through the numerous services, contact methods, and usage situations described in these privacy notices:
A. Contact Information A. Contact Information
Name, first name, address, email address, phone number, mobile number, postal code, country, state, and if applicable, company name and contact person.
B. Additional Personal Data Information provided by you regarding date of birth, language skills, household size, family composition, nationality, educational background, training, qualifications, previous activities, work experience, driver’s license, residency or deployment possibilities, as well as other personal data that may be relevant for the mediation or processing of your request.
C. Health-related data / special categories of personal data
Insofar as you provide us with such data or our forms include corresponding input fields, we can process the following health-related data in particular:
Care level, health situation, care needs, dementia, Parkinson’s, palliative care, chronic diseases, physical limitations, mental illnesses, regular medication intake, smoking behaviour, alcohol consumption, drug use, and other health or care-related information.
Such data falls under the special categories of personal data as defined by Art. 9 GDPR and is subject to a higher level of protection. Their processing is generally prohibited unless a legal exception applies, particularly if explicit consent is given.
D. Social Preferences and Matching Data
Information on hobbies, interests, habits, daily preferences, communication preferences, desired personal traits, and social constellations, as far as these are queried within the framework of your social analysis or matching logic.
E. Mediation, Inquiry, and Contract Data
Contents of your enquiries, mediation-relevant search profiles, care requirements, work or deployment preferences, communication histories, information on the status of a mediation, notes on handling enquiries, feedback, complaints, and other interaction data.
F. Company and Cooperation Data F. Company and Cooperation Data
Company name, VAT ID number, contact person, business address, communication data, content of cooperation requests, contract reference, and other business-related information.
G. Usage, Communication, and Technical Data G. Usage, Communication, and Technical Data
Information about how you use our website, IP address, browser type and version, operating system used, referrer URL, hostname of the accessing computer, date and time of access, visited subpages, duration of stay, if applicable, information from cookies or similar technologies, as well as communication metadata.
5. For what purpose is your data processed?
A. Fulfilment of contractual obligations, pre-contractual measures, and initiation of mediation, Art. 6 para. 1 lit. b GDPR A. Fulfilment of contractual obligations, implementation of pre-contractual measures, and initiation of mediation, Art. 6 para. 1 lit. b GDPR
good souls collects, processes, and uses personal data in the context of initiating, preparing, conducting, and supporting mediation processes.
In the context of these processes, we process personal data, in particular:
- for the collection and management of carer profiles,
- for the collection and processing of enquiries from carer seekers,
- for the execution of matching processes,
- for contacting suitable parties,
- for organising and accompanying the placement process,
- for transmitting information related to contract initiation.
In the context of these activities, the following categories of data are particularly processed:
Contact details, personal information, qualification data, mediation data, and – as far as necessary and legally permissible – health-related data.
We use your personal data within the framework of contract initiation and mediation, as well as to process a request you have formulated. For all aspects of mediation or the processing of a concern, we can contact you in writing, by phone, or by email without separate additional consent, as far as this is necessary for the implementation of pre-contractual measures or for contract fulfilment.
B. Processing of special categories of personal data, Art. 9 para. 2 lit. a GDPR
Insofar as health data or other special categories of personal data are processed within the framework of our forms or mediation processes, this is done exclusively on the basis of explicit consent or another legally valid basis in the individual case.
The processing of such data serves, in particular:
- the appropriate assessment of care and support situations,
- the selection of suitable carers or appropriate placements,
- the avoidance of inappropriate or unreasonable placements,
- the consideration of health or socially relevant requirements in the matching process.
Without the provision of certain health-related information and without the necessary consent, an appropriate mediation may be entirely or partially impossible. Explicit consent is a central legal exception to the processing prohibition under Art. 9 GDPR for health data.
C. Customer support, processing of enquiries, and quality assurance, Art. 6 para. 1 lit. b and f GDPR
We also use your personal data to process enquiries, manage ongoing placements, communicate with you, handle complaints, document relevant processes, and ensure the quality of our services.
good souls processes personal data on this basis also to optimise internal processes, to check the quality of our services, to improve the user experience, and to clearly identify you in the context of your contact.
Insofar as this is done in anonymised or depersonalised form, data can also be used for internal analysis, quality assurance, and further development of our services. The legal basis in this respect is regularly Article 6(1)(f) GDPR. Our legitimate interest lies in the proper organization, quality assurance, security, and further development of our business operations.
D. Advertising communication and newsletters based on consent, Art. 6 para. 1 lit. a GDPR
If you have separately given your consent for the further use of your personal data, your personal data may be used for advertising purposes, for sending newsletters, for contacting you with information about our services, and, if applicable, for creating an interest-based communication profile, as described in the consent.
If you have given the corresponding consent to commercial communication, we process in particular:
- Contact information,
- Information about your relationship with our company,
- Information about your interest in our services,
- Status of your consent,
- Communication channels and communication history.
The revocation of your consent is possible at any time with effect for the future. The requirements for valid consent and the right to withdraw arise from the GDPR.
E. Fulfilment of legal obligations, Art. 6 para. 1 lit. c GDPR
We also process personal data when there is a legal obligation to do so. This can lead to
6. Who will your data be shared with?
A. In the context of mediation To care-seeking natural or legal persons, institutions, companies, or other suitable requesters, as far as this is necessary for mediation. According to your model, the introduction of carers is generally done anonymously at first, meaning without full disclosure of identifying data. If a specific interest arises or if disclosure is necessary to achieve the purpose of mediation, personal data can be transmitted to a greater extent. Accordingly, data from individuals seeking carers can also be shared with suitable carers or cooperation partners to the necessary extent.
B. A Data Processor B. A Data Processor To carefully selected service providers who act as processors for us, particularly in the areas of hosting, IT operations, maintenance, email, form processing, consent management, newsletters, or support. With such service providers, we conclude contracts for data processing as required under Art. 28 GDPR.
C. Other Third Parties C. To other third parties To consultants, lawyers, tax advisors, insurers, authorities, courts, or other public bodies, insofar as this is legally required or necessary to protect our rights.
7. How do we protect your data?
- strict criteria for access authorisation to your data based on the need-to-know principle,
- Sharing of data only to the necessary extent,
- encrypted data transmission,
- protection of sensitive data sets,
- access restrictions,
- organizational processes for confidentiality,
- measures to detect and prevent unauthorised access.
8. How long do we keep your data?
We only retain your data for as long as necessary for the respective purposes. If data is processed for multiple purposes, it will be deleted or anonymised as soon as the last processing purpose ceases, provided there are no legal retention obligations to the contrary.
The following principles apply in particular:
A. Use for the fulfilment of a contract or for initiating mediation
To fulfil pre-contractual and contractual obligations, data collected from you can be stored as long as the mediation or business relationship exists or is being prepared.
B. Data from carers
Data from carers are generally stored for the duration of their willingness to be placed and beyond, as long as a new placement is desired or legally permissible, until a deletion is requested or good souls initiate the deletion.
C. Data from those seeking carers
Data from those seeking carers are stored for the duration of processing the search request and the placement. In the case of active placement, the data can be stored for an appropriate period, for example, for quality assurance, follow-up care, or satisfaction checks.
D. Use for the examination, defence, or enforcement of claims
Data that we deem necessary to review, defend, or assert claims may be stored by us for as long as a corresponding procedure or claim review is expected.
E. Legal Retention Obligations
As far as commercial or tax law retention obligations exist, we store the affected data for the legally required duration.
F. Marketing and newsletter data
Data processed based on consent for newsletters or promotional communication is generally stored until you withdraw your consent or unsubscribe, unless another legal basis applies.
9. Who do we grant international access to your data and how do we protect it?
In principle, we prefer to store and process personal data within the European Union or the European Economic Area.
In the context of IT services, support, hosting, communication, or marketing tools, it may happen that commissioned service providers based outside the EU access personal data or that a transfer to a third country cannot be completely ruled out. In such cases, we carefully select the service providers and ensure an appropriate level of data protection through contractual, technical, and organisational measures, particularly through suitable guarantees such as standard contractual clauses, where necessary. The GDPR requires appropriate safeguards for transfers to third countries when no adequacy decision is in place.
As soon as you use specific tools, this section should be supplemented with the respective providers.
10. Contacting us, your data protection rights and your right to lodge a complaint with the data protection authority
If you have questions about the use of your personal data by us, please first contact:
good souls Pflegevermittlung GmbH
Brunowall 28
59494 Soest
Email: [enter]
Phone: [enter]
Furthermore, you can contact our data protection officer if appointed.
The GDPR provides extensive rights for affected individuals. You have, in particular, the following rights:
A. Right of access, Art. 15 GDPR
You have the right to obtain information about the personal data we process as well as the information mentioned in Art. 15 GDPR.
B. Right to rectification, Art. 16 GDPR
You have the right to request the correction of inaccurate or the completion of incomplete personal data.
C. Right to Erasure, Art. 17 GDPR
Provided that the legal requirements are met, you can request the deletion of your personal data.
D. Right to restriction of processing, Art. 18 GDPR
Under the legal requirements, you can request the restriction of processing.
E. Right to data portability, Art. 20 GDPR
As far as the legal requirements are met, you have the right to receive the data concerning you in a structured, commonly used, and machine-readable format or to have it transmitted to another controller.
F. Right to object, Art. 21 GDPR
Insofar as we process personal data based on Art. 6 para. 1 lit. f GDPR, you have the right to object to the processing for reasons arising from your particular situation. If data is processed for direct marketing, you can object to this at any time.
G. Right to withdraw data protection consent
Insofar as processing is based on consent, you have the right to withdraw this consent at any time with effect for the future. The legality of the processing carried out until the revocation remains unaffected. The GDPR expressly provides for revocation.
H. Right to lodge a complaint with a supervisory authority
Furthermore, you have the right to lodge a complaint with a competent data protection supervisory authority.
11. General information on data processing on the website
The following information applies to the data processing operations on our website in general. If, in individual cases, further or more specific processing takes place that deviates from this, it will be supplemented in the corresponding sections.
A. Information on Data Security
We secure our website and other systems through technical and organisational measures against loss, destruction, unauthorised access, alteration, or dissemination of your data by unauthorised persons. Where technically feasible, we use SSL/TLS encryption for secure transmission.
B. Legal bases for processing
We process personal data in accordance with the GDPR requirements, depending on the type and purpose of the processing, particularly based on:
Consent, Art. 6 para. 1 lit. a GDPR, Contract fulfilment and pre-contractual measures, Art. 6 para. 1 lit. b GDPR, Legal obligation, Art. 6 para. 1 lit. c GDPR, Legitimate interest, Art. 6 para. 1 lit. f GDPR, For health data additionally Art. 9 para. 2 lit. a GDPR.
Our legitimate interest
Our legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR is based in particular on maintaining our business operations, the security and functionality of our systems, processing enquiries, quality assurance, preventing misuse, and further developing our mediation services.
C. Collection of General Data and Information
As soon as you visit our website, some general data and technical information will be collected by our web server or our hosting provider. This includes, in particular:
Browser type and version, operating system used, referrer URL, hostname of the accessing computer, date and time of access, IP address, as well as other technical information that may be required for the stability and security of website operation.
This data is processed in particular for the purpose of correctly displaying the content of our website, ensuring the functionality of our IT systems, detecting misuse, and, if necessary, providing relevant information for legal prosecution.
D. Obligation to Provide Personal Data
Under certain circumstances, you are obligated to provide us with personal data, for example, if it is necessary for processing your request, conducting a mediation process, or fulfilling contractual or legal obligations.
Failure to provide such data may result in the respective request or mediation not being processed or not being fully processed.
12. Information about specific data processing on the website
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B. Forms for Families / Care Seekers The purpose of the processing is the recording and handling of care requests, the determination of care needs, the execution of the matching process, and the initiation of placement. Depending on the case, health-related data of the affected person in need of care may also be processed. For this, a viable data protection legal basis must exist; this is usually an explicit consent or a lawful representation or disclosure authority.
C. Forms for Companies / Collaborations The purpose of processing is to handle business enquiries, initiate collaborations, and conduct or prepare business relationships.
D. Contact Form If you send us enquiries via the form, your information, including the contact details provided there, will be stored with us for processing the inquiry and in case of follow-up questions.
E. Newsletter If you subscribe to our newsletter, we will process your data for sending the newsletter and documenting your subscription. The dispatch should be secured via double opt-in.
F. Cookies On our website, we use cookies and similar technologies. These are small files or identifiers that are stored in the browser or on the device or allow access to information stored there. Technically necessary cookies may be used as far as they are required for the operation of the website or the expressly requested digital service. Non-technically necessary cookies, particularly for analysis, comfort, or marketing purposes, require prior consent. According to the opinion of the BfDI and the Data Protection Conference, cookies that require consent must not be set before consent is given; consent must be informed and effectively obtained. Since you will be adding a cookie banner, your specific consent tool should be named here later.
G. Analysis, Marketing, and Third-Party Services Insofar as analysis, marketing, mapping, video, chat, font, or social media services are integrated on the website, they must be specifically named in their own section, including:
- Provider,
- Purpose,
- Legal basis,
- Recipient,
- if applicable, third country reference,
- revocation/opt-out information.
13. Automated individual decision-making, including profiling
To the extent that we collect or process personal data, there is no decision based solely on automated processing within the meaning of Article 22 GDPR that produces legal effects concerning you or similarly significantly affects you.
To the extent that matching criteria, filters, or structured selection mechanisms are used, these serve to support internal placement processes and not a purely automated individual decision within the meaning of Article 22 GDPR. The GDPR governs specific rights of the data subject in this regard.
14. Changes to this Privacy Policy
We reserve the right to amend this privacy policy as necessary for legal, technical, or organizational reasons. The version published on our website at any given time shall apply.
This is now the legally drafted long version in the Promedica style, but neatly tailored to Good Souls.
The next logical step is for me to create the publication-ready final version for you, including:
- your actual contact details,
- sections for the cookie banner,
- your specific WordPress/form/newsletter tools,
- and separate consent texts for health data.