When using Kara Connect ehf.’s (“Kara”) services, including the Wellbeing Hub and portals managed by Professionals (the “Services”), Kara processes personal data about you as a user. The conditions under which we process your personal data and your personal rights in this regard is described in this Privacy Policy according to the rules in the EU General Data Protection Regulation no. 2016/679 (“GDPR”) and Icelandic Act no. 90/2018 on Data Protection and the Processing of Personal Data, and related orders and instructions (together “Data Protection Law”).
At Kara, one of our main priorities is the privacy of our users and the protection of their personal data. Kara is a data controller regarding personal data that is necessary to access and use the Services, personal data collected through the provision of technical support, i.e. by using Kara’s chat box function, and information collected when you visit our website or interact with us on social media.
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If you have any questions about Kara’s collection, registration or storage of your personal data, or to the processing in general, or if you want to exercise your rights, please contact us by the information given below:
Kara Connect ehf.
Skipholt 25
105 Reykjavik
Iceland
Telephone: +354 433 8765
E-mail: kara@karaconnect.com
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Kara only collects and processes the personal data that is necessary to provide the Service for you and to make the website and related applications function, and we only process your data as set forth in this Privacy Policy. Below you can read more about what data we process, including the purpose and legal basis for the processing.
Kara offers professionals a subscription service, through which professionals provide services online to their clients. This section is therefore relevant only to professionals.
Data Processed: Contact information (full name, SSN, e-mail address, home or office address and phone number) and financial information (credit card information). Professional qualifications (licenses, registration) may also be requested.
Purpose: Create user account, identification, communication, processing payments, and ensuring professional quality.
Legal Basis:
Registration/Payment: Art. 6(1)b of the GDPR (necessary for the performance of a contract).
Professional Qualifications: Art. 6(1)a of the GDPR (your consent).
We may collect, use, and share Aggregated Data (statistical or demographic) for any purpose, without directly or indirectly revealing your identity. The names of professionals and the number of sessions they have conducted may be included in this Aggregated Data, but presented in a way that does not identify any individual user. These reports may be shared with the employer and used for external research/analysis.
Under the Wellbeing Hubs programme, professionals can be evaluated through a 5-question survey to measure the relationship and trust with their consumers. If Users choose to participate in the survey, Kara Connect will process personal data concerning their professional relationships.
Legal Basis: Consent of the Users, according to Article 9(2)a GDPR. Participation is voluntary.
Confidentiality: All personal identifiable information will be coded. The individual Professional Alliance Score is never shared with the employer, but the professional’s identity may be disclosed in reports. Depersonalised and aggregated scores may be shared with the employer.
By submitting content through our platform, you agree to the terms and conditions outlined in our Content Submission Terms and Conditions. This grants Kara Connect the rights to use, modify, and distribute your content for marketing and promotional purposes. Original ownership remains with you, but Kara Connect retains non-exclusive rights for usage and distribution. Content is subject to review and approval.
This section is relevant to end-users who access the Services through the Wellbeing Hub or as clients of professionals.
Data Processed: Full name, e-mail address, and phone number.
Purpose: Create a user account to identify you and enable access to the Services.
Legal Basis: Art. 6(1)b of the GDPR (necessary for the performance of a contract).
Note on Single Sign-on: If SSO is required/enabled, your employer may have access to the e-mail address used for authentication, but no information regarding the Services you obtain.
You have the option to complete a 5-question survey (“Wellbeing Index”) to provide quantifiable measures of your mental health and overall wellbeing. This is to provide personalised and effective support.
Legal Basis: Your consent, according to Article 9(2)a GDPR. Participation is voluntary.
Confidentiality: All personal identifiable information will be coded. The individual Wellbeing Index Score is **never shared with your employer** and your identity will not be disclosed in any reports. Depersonalised and aggregated scores may be shared with the employer.
You have the option to complete a 5-question survey (“Professional Alliance”) to measure your relationship and trust with your professional. This is to offer personalised and effective support.
Legal Basis: Your consent, according to Article 9(2)a GDPR. Participation is voluntary.
Confidentiality: All personal identifiable information will be coded. The individual Professional Alliance Score is **never shared with your employer** and your identity will not be disclosed in any reports. Depersonalised and aggregated scores may be shared with the employer.
When using customer support (e.g., chat box function), Kara processes your name, address, e-mail address, phone number, and any data you provide in the support function.
Purpose: To identify you, contact you, and assist with problems.
Legal Basis: Your consent, cf. Article 6(1)a, of the GDPR.
When visiting the website, Kara collects and processes personal data via **cookies** for proper function, statistics, and marketing. We also process **log files** (IP-address, browser type, ISP, timestamps, etc.) for trend analysis and administration.
Legal Basis: Your consent, cf. Art. 6(1)a, and Kara’s legitimate interest in generating statistics and optimizing the website/Service, cf. Art. 6(1)f of the GDPR.
When you interact with Kara on Platforms like Facebook and LinkedIn (reacting, commenting, sharing, liking, following), we process common profile information (identification, contact, profile picture, etc.).
Purpose: Branding and marketing of Kara.
Legal Basis: Kara’s legitimate interest in the marketing of Kara on social medias, cf. Art. 6(1)f of the GDPR.
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Kara primarily collects personal data directly from **you** as a user of the Service, visitor to the website, or user on social media. Additionally, we collect information from professionals, or a contact person related to you.
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Your personal data is not subject to any disclosures. Disclosure to a third party may only happen if Kara is obliged to by law, requested by public authorities, or if you give your consent.
Kara uses data processors who only process your personal data in accordance with documented instructions and agreed data processing agreements. Data processors are not allowed to use the data for their own purposes.
The data processors Kara uses to provide the Service are located within the EU/EEA. Kara does not transfer your personal data to a data processor outside the EU/EEA for the provision of the Service. The current list of sub-processors, with their function, is maintained at https://trust.karaconnect.com/subprocessors.
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All of Kara’s employees and sub-contractors are subject to full confidentiality regarding the processing of personal data.
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Kara processes your personal data only for as long as it is necessary to fulfil the purpose of the processing.
Subscribing to the Service: For up to 2 months after you have deleted your account. Account is deleted if inactive for 2 years (reminders will be sent).
Support: Information used for identification/communication will be deleted no later than 2 months after your use of the function.
Our Website (Cookies): Refer to our Cookie Policy for deletion periods.
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As a data subject, you have a variety of rights in pursuance of the GDPR and Data Protection Law. Please contact us using the information above to make use of your rights. You may be asked to further identify yourself. The exercise of your rights must not affect the rights and freedoms of others.
The right to access your personal data: Obtain information and a copy of the data we process about you.
The right to rectification: Have inaccurate data corrected, or incomplete data completed.
The right to erasure (“Right to be Forgotten”): In certain situations, have your personal data erased (e.g., when processing is no longer necessary or you withdraw consent).
The right to restriction of processing: In certain situations, have the processing of your personal data limited or restricted.
The right to object: Object to processing based on legitimate interests (Art. 6(1)f) or for direct marketing purposes.
The right to data portability: Receive your personal data in a structured, commonly used, and machine-readable format when processing is based on contract or consent.
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If you have any complaints about Kara’s processing of your personal data, you are welcome to contact us. Additionally, you can always complain to the supervisory authority of Iceland, the Icelandic Data Protection Agency:
Website: https://www.personuvernd.is/
Telephone: (+354) 510 9600
E-mail: postur@personuvernd.is
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This Privacy Policy will be updated continuously. Last updated: 15th July 2024.