Privacy Policy

HarzPflege is currently in the pre-establishment phase (Vorgründungsphase). Services will commence following official business registration.

Last Updated: June 27, 2026

1. Introduction

HarzPflege (“we”, “our”, or “us”) is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, store, disclose, and protect your personal information when you visit our website or use our recruitment services.

We process personal data in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679, applicable German data protection laws, and where applicable, the Digital Personal Data Protection Act (DPDP Act 2023), India.

2. Data Controller

HarzPflege (Vorgründungsphase) Address: 38640 Goslar, Germany (Vorgründungsphase)

Email: info@harzpflege.de

Telephone: +49 177 2462350

Website: www.harzpflege.de If a Data Protection Officer (DPO) is appointed, their contact details will be published here.

3. What Personal Data We Collect

Depending on how you use our website, we may collect:

A. Contact Information

  • ​ Full name
  • ​ Email address
  • ​ Telephone number
  • ​ Country of residence

    • B. Candidate Application Information

  • ​ Curriculum Vitae (CV)
  • ​ Nursing qualifications
  • ​ Professional registration details
  • ​ Employment history
  • ​ Educational certificates
  • ​ Language certificates (e.g., German B1/B2)
  • ​ Passport copy (where required)
  • ​ Supporting documents provided during recruitment

    • C. Employer Enquiries

  • ​ Company name
  • ​ Contact person
  • ​ Position
  • ​ Email address
  • ​ Telephone number
  • ​ Recruitment requirements

    • D. Technical Information

  • ​ IP address
  • ​ Browser type
  • ​ Device information
  • ​ Website usage information
  • ​ Cookies (where applicable)

    • 4. Purposes of Processing

    We process personal data for the following purposes:

  • ​ Responding to enquiries
  • ​ Assessing candidate suitability
  • ​ Matching candidates with healthcare employers
  • ​ Arranging interviews (including via Microsoft Teams)
  • ​ Supporting qualification recognition procedures
  • ​ Visa and relocation assistance
  • ​ Communicating recruitment updates
  • ​ Improving our services
  • ​ Complying with legal obligations

    • 5. Legal Basis for Processing

    Depending on the activity, we rely on one or more of the following legal bases under Article 6

    GDPR:

  • ​ Your consent
  • ​ Performance of a contract
  • ​ Legitimate interests
  • ​ Compliance with legal obligations

    • Where special categories of personal data are processed, we rely on your explicit consent or another applicable legal basis under Article 9 GDPR.

    For individuals located in India, processing may also be carried out in accordance with the Digital Personal Data Protection Act (DPDP Act 2023), based on consent or legitimate uses as defined under the Act.

    6. Sharing Your Information

    Your personal data may be shared with:

  • ​ German hospitals
  • ​ Nursing homes
  • ​ Healthcare providers
  • ​ Government authorities where legally required
  • ​ Visa and recognition authorities
  • ​ Professional advisers
  • ​ IT service providers (including IONOS for hosting)
  • ​ Recruitment software providers
  • ​ Secure cloud hosting providers

    • We only share information necessary for the recruitment process.

    7. International Data Transfers

    As part of our recruitment services, personal data may be transferred between countries, including transfers from India or other non-EU countries to Germany, and vice versa.

    Where personal data is transferred outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place in accordance with Articles 44–49 GDPR. These

    safeguards may include:

  • ​ Standard Contractual Clauses (SCCs) approved by the European Commission
  • ​ Transfers to countries with an adequacy decision by the European Commission
  • ​ Binding contractual obligations with service providers and partners
  • ​ Additional technical and organisational measures where necessary

    • For transfers involving India or other jurisdictions without an adequacy decision, we rely primarily on Standard Contractual Clauses and ensure that recipients implement appropriate data protection measures.

    Where required under applicable law, we will obtain your explicit consent before transferring your personal data internationally.

    8. Third-Party Service Providers

    We use trusted third-party service providers, including:

  • ​ IONOS (website hosting provider)
  • ​ Email service provider (IONOS Webmail)
  • ​ Microsoft Teams (interviews during recruitment)
  • ​ Tally Forms (application and enquiry forms)
  • ​ Cookiebot (consent management platform)
  • ​ Recruitment management software (if applicable)

    • These providers process data only on our instructions and under appropriate data processing agreements.

    9. Data Retention

    We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy or to comply with legal obligations.

    If your application is unsuccessful, your data may be retained for up to 24 months, unless you request earlier deletion or applicable law requires otherwise.

    Retention periods for other categories of data are determined based on several criteria, including the nature and sensitivity of the data, the purpose for which it was collected, applicable legal or regulatory requirements, and our legitimate business needs. For example, contact and enquiry data may be retained for shorter periods to respond to follow-up communications, while contractual or compliance-related records may be retained longer to meet statutory retention obligations under German law (such as tax or commercial record-keeping requirements).

    Technical data, such as website usage information, is typically retained for limited periods necessary for security, analytics, and system performance purposes. We regularly review stored data and securely delete or anonymise it when it is no longer required.

    10. Your Rights

    Under GDPR, you have the right to:

  • ​ Access your personal data
  • ​ Correct inaccurate information
  • ​ Request deletion of your data
  • ​ Restrict processing
  • ​ Object to processing
  • ​ Withdraw consent
  • ​ Receive your data in a portable format
  • ​ Lodge a complaint with the competent supervisory authority

    • The competent supervisory authority in Germany is:

    Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI)​

    Graurheindorfer Straße 153​

    53117 Bonn​

    Germany​ Telephone: +49 (0)228 997799 0​

    Email: poststelle@bfdi.bund.de​

    Website: https://www.bfdi.bund.de For individuals in India, you may also have rights under the DPDP Act 2023 of India, including the right to access, correct, and erase personal data, and to withdraw consent.

    Requests may be submitted by contacting us using the details provided above.

    11. Security

    We implement appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction.

    Measures include encryption, secure hosting (including IONOS infrastructure), restricted access, and regular security reviews.

    12. Cookies

    Our website may use cookies and similar technologies to improve functionality, enhance user experience, and analyse website traffic.

    Types of Cookies We Use

  • ​ Strictly Necessary Cookies: These cookies are essential for the operation of the

    • website and enable core functionalities such as page navigation and access to secure areas. These cookies do not require user consent.

  • ​ Functional Cookies: These cookies allow the website to remember choices you make

    • (such as language preferences) and provide enhanced, more personalised features.

  • ​ Analytics Cookies: These cookies help us understand how visitors interact with our

    • website by collecting information such as pages visited, time spent on the site, and error messages. This helps us improve website performance and usability.

  • ​ Marketing or Tracking Cookies (if applicable): These cookies may be used to track

    • users across websites to display relevant advertisements. We will only use such cookies if applicable and with your explicit consent.

    Purpose of Cookies

    Cookies are used to:

  • ​ Ensure the proper functioning of the website
  • ​ Improve user experience and website performance
  • ​ Analyse usage patterns and optimise content
  • ​ Support security and prevent misuse

    • Duration of Cookies

    Cookies may be stored for different durations:

  • ​ Session Cookies: These are temporary and are deleted when you close your browser.
  • ​ Persistent Cookies: These remain on your device for a defined period or until you

    • delete them manually. The duration depends on the specific cookie and its purpose.

    Managing and Withdrawing Consent

    Where required by law, non-essential cookies will only be used after obtaining your consent through a cookie banner or consent management tool.

    You have the right to:

  • ​ Accept or reject non-essential cookies
  • ​ Withdraw your consent at any time
  • ​ Change your cookie preferences via the cookie settings on our website (if available)

    • Additionally, you can manage or delete cookies through your browser settings. Most browsers

    allow you to:

  • ​ View stored cookies
  • ​ Delete cookies
  • ​ Block cookies from specific websites
  • ​ Block all cookies

    • Please note that disabling certain cookies may affect the functionality and performance of the website.

    13. Children’s Privacy

    Our recruitment services are intended for individuals aged 18 years or older.

    We do not knowingly collect personal data from children.

    14. Changes to this Privacy Policy

    We may update this Privacy Policy from time to time.

    The latest version will always be published on our website together with the revision date.

    15. Contact

    If you have any questions regarding this Privacy Policy or our processing of personal data,

    please contact:

    HarzPflege (Vorgründungsphase)

    Email: info@harzpflege.de

    Telephone: +49 177 2462350 Address: 38640 Goslar, Germany (Vorgründungsphase)

    Consent

    For transparency, you may review the data processing terms of our service providers here:

  • ​ Tally Forms Data Processing Agreement: https://tally.so/help/data-processing-agreement
  • ​ IONOS Data Processing Agreement: https://www.ionos.com/terms-gtc/terms-privacy
  • ​ Cookiebot Privacy Policy: https://www.cookiebot.com/en/privacy-policy/

    • Where we rely on your consent as the legal basis for processing your personal data (in accordance with Article 6(1)(a) GDPR and, where applicable, Article 9(2)(a) GDPR for special categories of data), you provide such consent by submitting an application or enquiry through our website (including via Tally Forms). By doing so, you confirm that you have read and understood this Privacy Policy and agree to the processing of your personal data for the specified recruitment purposes.

    You have the right to withdraw your consent at any time, without affecting the lawfulness of any processing carried out prior to the withdrawal. To withdraw your consent, you may contact us using the details provided in this Privacy Policy.