Privacy Policy

Privacy Policy www.thecarehub.ro
This policy is designed to tell you, the visitor to the site, how, why and for how long we process your personal data. The document has been drafted in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“GDPR – General Data Protection Regulation”).
Please note that this policy will be revised from time to time in order to comply with the legal provisions and recommendations of the National Authority for the Supervision of Personal Data Processing (“ANSPDCP”).  You will be informed of the updated version by email notification and/or by posting on the website when you access the website.
This policy applies to all visitors to our website, whether they have a registered account on The Care Hub mobile apps or not.
Personal data controller: THE CARE HUB SRL, having its registered office at Zăvoi Street no 1, SAD 7 and SAD 8, trade register number J35/4519/13.12.2018, tax identification code 40299417.
As an operator, we collect data:

  • through our website www.thecarehub.ro (“the website”), by filling in forms or by using cookies
  • on The Care Hub platform, through the partner and customer applications available (details of data processing are available in the privacy policies of the two applications)
  • through the pages of social networks affiliated to the platform
  • offline – through forms distributed at our events or when you contact us directly.
    Categories of personal data processed:
    Name, first name
    E-mail
    Phone
    Information collected by cookies: location, browser and electronic device used to log in: IP address, MAC address, Google ad code, pages accessed on the site, date and time of activity, frequency of visits.
    Purposes of processing personal data
    To provide intermediary services for personal services at home through The Care Hub platform and to create user accounts on The Care Hub platform
    To customise the services offered and improve the platform;
    To respond to requests from you and the users of the platform;
    To enable participation in surveys, competitions, promotions, etc.
    To provide technical support related to the use of “The Care Hub” platform
    To recognise the devices used and associate them with the user profile, where applicable
    To use certain technologies on social networks according to your expressed consent.
    For marketing purposes, to send information about products, services, events and promotions related to The Care Hub or other companies with which THE CARE HUB SRL works, exclusively based on your consent.
    In order to fulfil the legal obligations of THE CARE HUB SRL.
    Basis of processing of personal data
    Your consent
    In order to conclude or execute a contract for the use of the platform between THE CARE HUB SRL and you as a user
    For compliance with legal obligations
    The legitimate interest of THE CARE HUB SRL
    Situations where we disclose your data
    THE CARE HUB SRL may disclose your personal data in certain situations to:
  1. Service providers for the purpose of performing certain functions of the website and THE CARE HUB SRL’s business, such as conducting marketing or retention campaigns, participating in contests or events, etc.
    Social networks. You may interact with certain features of The Care Hub platform that may result in the publication of personal data (name, first name) on the user page or The Care Hub page on various social networks.
  2. Mobile, electronic or other device applications. THE CARE HUB SRL may share certain personal data (including how the user uses mobile or other electronic device applications) with mobile operators, technology providers, analytics providers, etc.
  3. Sale of THE CARE HUB SRL’s business or assets. In the event of the sale of all or part of THE CARE HUB SRL’s business or assets, visitor information may, at THE CARE HUB SRL’s discretion, be transferred in whole or in part to third parties as part of or in connection with that transaction. In this event, the policies of third party entities may govern the use and collection of information.
  4. Third party companies that hold The Care Hub platform user data separately. THE CARE HUB SRL may share visitors’ personal data with third parties to whom the visitor has separately provided certain personal data (e.g. by creating a user account on those third parties’ platforms). In these cases, THE CARE HUB SRL may supplement the data that the third parties hold about users by sharing a common identifier that in itself does not constitute personal data.
  5. Affiliated entities. THE CARE HUB SRL may share personal data about visitors collected through The Care Hub Platform with affiliated entities (either companies in the same group or companies with common shareholders/associates with THE CARE HUB SRL).
  6. Legal grounds. THE CARE HUB SRL may disclose, in whole or in part, personal information in order to cooperate with or assist law enforcement, governmental or regulatory agencies, content protection organizations, or legal actions in connection with or to prevent suspected or possible fraud. THE CARE HUB SRL may also use or disclose information it deems appropriate to the extent requested by an official address or in connection with pending or potential litigation or to enforce or protect the rights or safety of visitors.
    Storage period
    We store personal data only for as long as necessary to fulfil the purposes, but no longer than 5 years after the termination of the contract or the last interaction on The Care Hub platform. Certain categories of data will be stored for longer periods where the period is required by law, regulation or applicable rules on record retention obligations.
    Data transfer
    In using the platform, your personal data may be transferred to or stored on the servers of our providers in countries outside the EU/EEA, depending on the resources available to those providers.
    In all cases where data is transferred to a non-EU/EEA country, we enter into a data processing agreement with the providers, which contains the contractual clauses recommended by the European Commission, in order to obtain adequate guarantees regarding data security and protection.

Your rights regarding personal data
Right of access Following your request, we can confirm that we are processing your data and provide you with access to that data (by providing you with a copy of the personal data and additional information about the processing).
Right to rectification Following your request, we will promptly rectify inaccurate data and complete incomplete data we hold about you.
Right to erasure of data Following your request, in certain circumstances we will delete your personal data (e.g. if it is no longer necessary for the purposes for which it was collected or if you withdraw your consent and there is no other basis for processing).
Right to restrict processing Following your request, we will restrict the processing of your data when you dispute its accuracy or if you have objected to its processing. We will inform you without delay of the lifting of any processing restrictions.
Right to data portability Following your request, we will transmit your personal data processed on the basis of your consent in a structured, commonly used and machine-readable format. You can also ask us to transmit the data to another controller.
The right to oppose Following your request, we will stop processing your data based on the legitimate interest of THE CARE HUB SRL, when your interests and rights prevail over our interests.
Right to withdraw consent Where your data is processed solely on the basis of consent, you have the right to notify THE CARE HUB SRL of the withdrawal of consent. Withdrawal will not affect the lawfulness of the previous processing.
The right to lodge a complaint with the supervisory authority Updated information on how to lodge a complaint with the National Supervisory Authority for Personal Data Processing can be found at www.dataprotection.ro

Contact
In order to answer any questions you may have regarding this information or in relation to the processing of personal data by THE CARE HUB SRL, as well as to exercise your rights mentioned above, please contact us by sending an e-mail to [email protected]
Privacy policy – mobile app customers

  1. Relevant definitions
  2. Personal data – any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity;
  3. Processing – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  4. Controller – the legal person that determines the purposes and means of processing personal data;
  5. Processor – the natural or legal person or other body that processes personal data on behalf of the controller;
  6. Supervisory Authority – means the National Supervisory Authority for Personal Data Processing (“Authority”), having its registered office at B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania;
  7. The Care Hub platform consists of
  8. “Website” – means the website www.thecarehub.ro.
  9. “Partners Mobile App” – means the mobile, tablet and other mobile device application “Partners The Care Hub”, in the version for iOS and Android operating systems or any other versions available in other operating systems, used by the Partner to market the services provided
    “Customers Mobile App” – means the application for mobile phones, tablets and other mobile devices “The Care Hub Customers”, in the version for iOS and Android operating systems or any other versions available in other operating systems, used by the Buyer to procure the services offered by the Partner
  10. “User interaction management information systems” means customer and customer relationship management systems, billing systems, online payment systems, systems for marketing campaigns and management of SC THE CARE HUB SRL profiles on social networks, etc.;
  11. The User is any natural or legal person who is the holder of one or more accounts on The Care Hub platform. Users can be:
  12. Partners – authorised or legal persons (PFA, SRL, NGO, etc.) providing personal services at home
  13. Customers or Buyers – natural or legal persons who purchase the services provided by the Partner for their own benefit or for the benefit of a third party
    Beneficiaries – people benefiting from the personal home services provided by the Partner.
  14. Personal data controller
    SC THE CARE HUB SRL, having its registered office at Zăvoi Street no 1, SAD 7 and SAD 8, trade register number J35/4519/13.12.2018, tax identification code 40299417, legal representative SILVIA MONICA MOLDOVAN, administrator, is the controller of personal data processed through The Care Hub platform and is legally obliged to process such data in compliance with the security measures recommended by the legislation in force.
  15. Personal data processed through The Care Hub platform
    Clients will need an account on “The Care Hub” platform in order to book visits for personal services at home, to receive notifications about the booked visit (details of the Partner who will perform the visit, changes, cancellations, start visit, end visit, visit assessment, etc), to receive notifications about other personal services at home (if the Client has opted to receive this information, with the possibility to opt out of receiving this information at any time).
    For the registration of a Customer account and during the use of “The Care Hub” platform, we process the following data:
    Full name;
    E-mail address;
    Phone number;
    Sex;
    Date of birth;
    Domicile;
    The data from the identity card;
    Details required for payment of services received;
    IP address;
    Geographical location;
    Profile picture.
    Refusal to provide the above categories of data will prevent successful registration on The Care Hub platform and therefore the possibility to benefit from the services provided by the Partners.
    When using the platform, we will process the following data:
    Data necessary for the provision of services (which may or may not be of a personal nature)
    Qualifications and comments given by Partners;
    Messages between Partner and Client within the application;
    Beneficiary profile(s) – optional, if filled in voluntarily by the Client.
  16. Purposes and legal basis of data processing
    SC THE CARE HUB SRL processes personal data for the following purposes:
    To provide intermediary services for personal home services requested by Clients and offered by Partners (booking visits, accepting visits, changing or cancelling visits, viewing Client and Partner profiles within a booked visit, viewing payment documents, etc.).
    To create user accounts on “The Care Hub” platform
    To personalise the services offered
    To respond to user requests
    To allow users to participate in surveys, contests, promotions, etc.
    To provide technical support related to the use of “The Care Hub” platform
    To be able to communicate administrative messages
    To recognise the devices used and associate them with the user profile
    To use certain technologies on social networks according to your expressed consent.
    To send information about products, services and promotions related to The Care Hub or other companies with which SC THE CARE HUB SRL works, exclusively based on your consent.
    To respond to your requests and those of other users of the platform;
    For marketing purposes only with your prior consent;
    In order to fulfil the legal obligations of SC THE CARE HUB SRL.
    SC THE CARE HUB SRL processes data on the following legal grounds:
    the conclusion or execution of a contract between you and SC THE CARE HUB SRL for the use of the platform;
    your consent for data processing;
    fulfilling our legal obligations;
    for our legitimate interests or those of another party;
    to protect your vital interests or those of another person.
  17. Categories of recipients of personal data
    SC THE CARE HUB SRL may disclose personal data collected from users of The Care Hub platform in certain situations to:
  18. Other users of the platform, natural or legal persons, e.g. sharing the Client’s personal data with more than one Partner in order to accept a requested visit, to enable personal home services requested through The Care Hub platform, etc. If you complete the Beneficiary profile, it will be made available to Partners.
  19. Service providers for the purpose of fulfilling certain features of The Care Hub platform, such as issuing invoices, processing payments, conducting marketing or retention campaigns, participating in contests or events, etc.
  20. Social networks. Users may interact with certain functionalities of The Care Hub platform that may lead to the publication of personal data (name, surname) on the user’s page or on The Care Hub page on various social networks.
  21. Mobile, electronic or other device applications. SC THE CARE HUB SRL may share certain personal data (including how the user uses mobile or other electronic device applications) with mobile operators, technology providers, analytics providers, etc.
  22. Sale of the business or assets of SC THE CARE HUB SRL. In the event of the sale of all or part of the business or assets of SC THE CARE HUB SRL, user information may, at the discretion of SC THE CARE HUB SRL, be transferred in whole or in part to third parties as part of or in connection with that transaction. In this event, the policies of third party entities may govern the use and collection of information.
  23. Third party companies that hold The Care Hub platform user data separately. SC THE CARE HUB SRL may share users’ personal data with third parties to whom the user has separately provided certain personal data (e.g. by creating a user account on the respective third parties’ platforms). In these cases, SC THE CARE HUB SRL may supplement the data the third parties hold about the users by sharing a common identifier which in itself does not constitute personal data.
  24. Affiliated entities. SC THE CARE HUB SRL may share personal data about users collected through The Care Hub Platform with affiliated entities (either companies in the same group or companies with common shareholders/associates with SC THE CARE HUB SRL).
  25. Legal grounds. SC THE CARE HUB SRL may disclose, in whole or in part, personal data in order to cooperate with or assist law enforcement, governmental or regulatory agencies, content protection organizations, or legal actions in connection with or to prevent suspected or possible fraud. SC THE CARE HUB SRL may also use or disclose information it deems appropriate to the extent requested by an official address or in connection with pending or potential litigation or to enforce or protect the rights or safety of users.
  26. Transfer of data to third countries or international organisations
    In using the platform, your personal data may be transferred to or stored on the servers of our providers in countries outside the EU/EEA, depending on the resources available to those providers.
    In all cases where data is transferred to a non-EU/EEA country, we enter into a data processing agreement with the providers, which contains the contractual clauses recommended by the European Commission, in order to obtain adequate guarantees regarding data security and protection.
  27. Storage period
    We store personal data only for as long as necessary to fulfil the purposes, but no longer than 5 years after the termination of the contract or the last login on The Care Hub platform.
    The obligatory accounting records and supporting documents that are the basis for the entries in the financial accounting of SC THE CARE HUB SRL are kept in the archives for 10 years, starting from the end of the financial year in which they were drawn up, according to the legislation in force.
    After the end of the period, personal data will be destroyed or deleted from computer systems or rendered anonymous for use for scientific, historical or statistical research purposes.
    To the extent that current legal provisions are updated, we will update this policy and store data for the period required by law.
  28. User rights and preferences
    Right of access Following your request, we can confirm that we are processing your data and provide you with access to that data (by providing you with a copy of the personal data and additional information about the processing).
    Right to rectification Following your request, we will promptly rectify inaccurate data and complete incomplete data we hold about you.
    Right to erasure of data Following your request, in certain circumstances we will delete your personal data (e.g. if it is no longer necessary for the purposes for which it was collected or if you withdraw your consent and there is no other basis for processing).
    Right to restrict processing Following your request, we will restrict the processing of your data when you dispute its accuracy or if you have objected to its processing. We will inform you without delay of the lifting of any processing restrictions.
    Right to data portability Following your request, we will transmit your personal data processed on the basis of your consent in a structured, commonly used and machine-readable format. You can also ask us to transmit the data to another controller.
    The right to oppose Following your request, we will stop processing your data based on the legitimate interest of SC THE CARE HUB SRL, when your interests and rights prevail over our interests.
    Right to withdraw consent Where your data is processed solely on the basis of consent, you have the right to notify SC THE CARE HUB SRL of the withdrawal of consent. Withdrawal will not affect the lawfulness of the previous processing.
    The right to lodge a complaint with the supervisory authority Updated information on how to lodge a complaint with the National Supervisory Authority for Personal Data Processing can be found at www.dataprotection.ro
    To exercise any of the above rights, as well as to request information about the processing of your data, you may contact SC THE CARE HUB SRL at [email protected]
    Communication preferences and unsubscribe options:
    Users of The Care Hub platform have control over the methods (SMS, email, notifications via apps) and types (visit-related messages, promotion-related messages, account policy and support messages, etc.) of communication by selecting (opt-in) preferred options both during the registration process on The Care Hub platform and afterwards by accessing the “My Account” -> “Settings” -> “Communication Preferences” section.
    The only communication setting from which the user cannot be unsubscribed is the communication via email of policy and account support messages, due to the legal and technical implications of providing intermediary services, which require the user’s attention. If the user does not wish to receive such communications, the user will be able to delete his/her user account from The Care Hub platform or communicate his/her desire to delete his/her user account via email to [email protected], which will have the effect of deleting his/her user account.
    Please note that uninstalling the app from mobile devices does not automatically delete personal data provided through The Care Hub platform.
    If SC THE CARE HUB SRL will process personal data made available through The Care Hub platform for a purpose other than that for which it was collected under this policy, SC THE CARE HUB SRL will inform you prior to such further processing and request your consent where required.
    Privacy policy verification process
    PRIVACY POLICY – Partner Verification
  29. Relevant definitions
  30. Personal data – any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity;
  31. Processing – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  32. Controller – the legal person that determines the purposes and means of processing personal data;
  33. Processor – the natural or legal person or other body that processes personal data on behalf of the controller;
  34. Supervisory Authority – means the National Supervisory Authority for Personal Data Processing (“Authority”), having its registered office at B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, postal code 010336, Bucharest, Romania;
  35. The Care Hub platform consists of:
  36. “Website” – means the website www.thecarehub.ro.
  37. “Partners Mobile App” – means the application for mobile phones, tablets and other mobile devices “Partners The Care Hub”, in the version for iOS and Android operating systems or any other versions available in other operating systems, used by the Partner to market the services provided
    “Customers Mobile App” – means the application for mobile phones, tablets and other mobile devices “The Care Hub Customers”, in the version for iOS and Android operating systems or any other versions available in other operating systems, used by the Buyer to procure the services offered by the Partner
  38. “User interaction management information systems” – means customer and customer relationship management systems, billing systems, online payment systems, systems for marketing campaigns and management of THE CARE HUB SRL profiles on social networks, etc.;
  39. The User is any natural or legal person who is the holder of one or more accounts on The Care Hub platform. Users can be:
  40. Partners – authorised or legal persons (PFA, SRL, NGO, etc.) providing personal services at home
  41. Customers or Buyers – natural or legal persons who purchase the services provided by the Partner for their own benefit or for the benefit of a third party
    Beneficiaries – people benefiting from the personal home services provided by the Partner.
  42. The applicant is any natural person who applies to provide services through The Care Hub platform as a PFA, employee of an LLC, etc.
  43. Personal data controller
    THE CARE HUB SRL, having its registered office at Zăvoi Street no 1, SAD 7 and SAD 8, trade register number J35/4519/13.12.2018, tax identification code 40299417, legal representative SILVIA MONICA MOLDOVAN, administrator, is the controller of the personal data processed in the recruitment process for registration as a partner on The Care Hub platform and has the legal obligation to process such data in compliance with the security measures recommended by the legislation in force.
  44. Personal data processed
    In order to be able to register a user-partner account on The Care Hub platform, each Candidate must be declared admitted following the recruitment process carried out by THE CARE HUB SRL.
    We process the following data for the recruitment process:
    Full name;
    E-mail address;
    Phone number;
    Sex;
    Date of birth;
    Domicile;
    Identity card data – only with your consent;
    Data from your criminal record certificate – only with your consent.
    Data on the Candidate’s state of health;
    Assessment outcome (consisting of 1 psychological assessment and 2 interviews)
    Preferences regarding preferred program and services;
    IP address;
    Geographical location.
    Refusal to provide all the above categories of data will prevent the successful completion of the recruitment process.
  45. Purposes and legal basis of data processing
    THE CARE HUB SRL processes personal data for the following purposes:
    In order to sort Candidates and allow only those who can provide services through the platform in accordance with the principles of THE CARE HUB SRL to register on the platform
    In order to maximise the comfort and security offered to Clients and Beneficiaries by pre-screening Candidates, in consideration of the fact that they will interact directly with Beneficiaries, both at home and during visits to other locations.
    To respond to your and other applicants’ requests;
    In order to fulfil the legal obligations of THE CARE HUB SRL.
    THE CARE HUB SRL processes data on the following legal grounds:
    conclusion of a contract between the Partner and THE CARE HUB SRL for the use of the platform and the provision of services by you as a Candidate;
    your consent to the processing of data from your criminal record certificate and medical certificate;
    fulfilling our legal obligations;
    for the purposes of our legitimate interests, Customers and/or Beneficiaries;
    to protect the vital interests of Clients and/or Beneficiaries.
  46. Categories of recipients of personal data
    THE CARE HUB SRL may disclose personal data collected from Candidates in certain circumstances to:
  47. Its employees, responsible for the recruitment process. The Care Hub, etc.
  48. Service providers, for the purpose of outsourcing certain verification and scoring activities of the Candidate profile.
  49. Sale of THE CARE HUB SRL’s business or assets. In the event of the sale of all or part of THE CARE HUB SRL’s business or assets, Candidate information may, at THE CARE HUB SRL’s discretion, be transferred in whole or in part to third parties as part of or in connection with that transaction. In this event, the policies of third party entities may govern the use and collection of the information.
  50. Legal grounds. THE CARE HUB SRL may disclose, in whole or in part, personal data in order to cooperate with or assist law enforcement, governmental or regulatory agencies, content protection organizations, or legal actions in connection with or to prevent suspected or possible fraud. THE CARE HUB SRL may also use or disclose information it deems appropriate to the extent requested by an official address or in connection with pending or potential litigation or to enforce or protect the rights or safety of users.

As THE CARE HUB SRL does not allow the provision of services through the platform by Candidates who have criminal offences on their criminal record certificate or who are not in an adequate state of health, we mention that your Partner profile will display to Clients a confirmation that these two conditions have been met.

  1. Transfer of data to third countries or international organisations

In using the platform, your personal data may be transferred to or stored on the servers of our providers in countries outside the EU/EEA, depending on the resources available to those providers.
In all cases where data is transferred to a non-EU/EEA country, we enter into a data processing agreement with the providers, which contains the contractual clauses recommended by the European Commission, in order to obtain adequate guarantees regarding data security and protection.

  1. Storage period
    We store personal data depending on the outcome of the checks carried out in the recruitment process:
    If you are approved as a Partner, after confirmation of the fulfilment of the conditions we will store the data for the execution of the intermediation contract.
    If your Partner application is rejected, we will store your name and surname and the reason for rejection for a period of 5 years from the date of rejection. After the expiry of the 5-year period, your data will be deleted from both THE CARE HUB SRL system and THE CARE HUB SRL suppliers.
    After the end of the periods set out above, personal data will be destroyed or deleted from computer systems or rendered anonymous for use solely for scientific, historical or statistical research purposes.
    To the extent that current legal provisions are updated, we will update this policy and store data for the period required by law.
  2. Candidates’ rights and preferences
    Right of access Following your request, we can confirm that we are processing your data and give you access to that data (by providing you with a copy of the personal data and additional information on the processing).
    Right to rectification Following your request, we will promptly rectify inaccurate data and complete incomplete data we hold about you.
    Right to erasure of data Following your request, in certain circumstances we will delete your personal data (e.g. if it is no longer necessary for the purposes for which it was collected or if you withdraw your consent and there is no other basis for processing).
    Right to restrict processing Following your request, we will restrict the processing of your data when you dispute its accuracy or if you have objected to its processing. We will inform you without delay of the lifting of any processing restrictions.
    Right to data portability Following your request, we will transmit your personal data processed on the basis of your consent in a structured, commonly used and machine-readable format. You can also ask us to transmit the data to another controller.
    The right to oppose Following your request, we will stop processing your data based on the legitimate interest of THE CARE HUB SRL, when your interests and rights prevail over our interests.
    Right to withdraw consent Where your data is processed solely on the basis of consent, you have the right to notify THE CARE HUB SRL of the withdrawal of consent. Withdrawal will not affect the lawfulness of the previous processing.
    The right to lodge a complaint with the supervisory authority Updated information on how to lodge a complaint with the National Supervisory Authority for Personal Data Processing can be found at www.dataprotection.ro
    To exercise any of the above rights, as well as to request information about the processing of your data, you may contact THE CARE HUB SRL at [email protected]

If THE CARE HUB SRL will process personal data made available through The Care Hub platform for a purpose other than that for which it was collected under this policy, THE CARE HUB SRL will inform you prior to such further processing and request your consent where required.

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