Privacy Policy

Privacy Policy for our Website

1. Introduction

In the following, we provide information about the collection of personal data when using our mobile or web app (hereinafter only "App").

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1. Contact details

The controller within the meaning of Art. 4 (7) EU General Data Protection Regulation (GDPR) is Sharpist GmbH, Karl-Marx-Straße 58, 12043 Berlin, Germany.  ​For customers in the United Kingdom, the responsible party is Sharpist Ltd, 102 Puller Road, Barnet, UK. Our e-mail address in each case is mail@sharpist.com. We are legally represented by Hendrik Schriefer, Fabian Niedballa.

Our data protection officer is Martin Bastius, heyData GmbH, Schützenstr. 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.

For data subjects in the United Kingdom, the EU General Data Protection Regulation (hereinafter "GDPR") information in this privacy policy refers to the UK GDPR.

1.2. Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

  • Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
  • Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a user purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
  • Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
  • Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our App.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA (or for data subjects in the UK: outside the EEA or the United Kingdom), the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Canada and Israel) (Art. 45 para. 3 GDPR).

If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

  • Right of access,
  • Right to correction or deletion,
  • Right to limit processing,
  • Right to object to the processing,
  • Right to data transferability,
  • Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data.

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

2. Data processing in the App

2.1. Downloading the mobile app

Our mobile app is ready for download at ​Apple's App Store und Google's Play Store​ (hereinafter "Stores"). When users download the mobile app, the necessary information is transmitted to the stores, i.e. in particular user name, e-mail address and customer number of the account, time of download, payment information and the individual device identification number. We have no influence on this data collection and are not responsible for it. We process the data only insofar as it is necessary for downloading the mobile app to the user's mobile device.

2.2. Hosting

Our App is hosted by Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen. The provider thereby processes the personal data transmitted via the app, e.g. on content, usage, meta/communication data or contact data. It is our legitimate interest to provide an app, so that the legal basis of the data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

2.3. Informative use of our App

When users use our App, we collect the data that is technically necessary for us to offer users the functions of our app and to ensure stability and security. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

The data processed to this extent are:

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Browser
  • Operating system and its interface
  • Language and version of the browser software

2.4. Access to functions or data

The App requests the user's access to functions of the end device or to data of the device in order to be able to execute functions of the App. By allowing access, the user gives consent to the associated data processing, so that the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR. Users can revoke their consent at any time by terminating access in the settings of their end device. The revocation does not affect the lawfulness of the processing until the revocation.

The functions or data processed to this extent are

  • camera
  • microphone​
  • ​push notifications

2.5. Data processing for the provision of functions

In the App, we process data in order to provide the user with functions of the App. The legal basis for the processing is to perform the contract concluded with our customer. For this reason is the legal basis is art. 6 Abs. 1 S. 1 lit. b GDPR.

The data processed to this extent are only the data entered into the App by the user.

Coaches & Lerners

We call our customers' employees, who use our Sharpist App "Learners". When we recommend you as a Coach for to a Learner, we share your following information with them via the Sharpist App: 

  • first name, 
  • last name, 
  • photo, 
  • language skills, 
  • education, 
  • work experience.

When a learner chooses you for coaching, we will share the following information about the learner: 

  • first name, 
  • last name, 
  • gender, 
  • academic title, 
  • associated company, 
  • the role of the learner in the company, 
  • information on the learner's personal goals ("Goals"), 
  • details of topics to be excluded from coaching ("No-Gos"),
  • preferred language.

The above-mentioned data may only be used for the fulfillment of the specific coaching assignment; any processing beyond this is not permitted. After the coaching session has ended, all personal data of the learner must be deleted.

After a coaching session, keywords may be selected that outline the topic of the session. We share these keywords with the learner and may also share them with our client in certain cases. In no case will we share with our client which coach selected which keywords to which learner. The selected list of keywords can be found in the appendix "Keywords related to the session topic".

The data will be forwarded to the clients only if at least 5 learners have completed at least 10 coaching sessions in total. Otherwise, only the number of registered learners is provided.

2.6 Statistical data analysis and evaluation

For statistical data analysis and evaluation, we use the following contract processors:

  • Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland).
  • y42 (DATOS Intelligence GmbH, Lohmühlenstraße 65, 12435 Berlin, Germany).

The legal basis for the processing is our legitimate interest in improving our product for our users (Art. 6 para. 1 p. 1 lit. f GDPR).

2.7 Emails

For receiving, storing and sending emails, we use the following order processors:

  • Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) and. 
  • Twilio with the Sendgrid service (Twilio Inc., 375 Beale Street, Suite 300, San Francisco, CA 94105, USA). We only use Twilio to send service notifications to learners, such as the session access code for the next session. The only processing is logging the message delivery to verify that it is correct. We do not store any information with Twilio.

The legal basis of the transfer to a country outside the EEA (or for data subjects in the UK: outside the EEA or the UK) is standard contractual clauses. The security of the data transferred to the third country (i.e., a country outside the EEA) is guaranteed by standard data protection clauses adopted in accordance with the review procedure under Article 93 para. 2 GDPR (Article 46 para. 2 lit. c  GDPR), which we have agreed with the provider.

2.8. Third-party tools

2.8.1. ​Intercom​

We use Intercom for engagement with the users. The provider is R&D Unlimited Company 2nd Floor, Stephen Court, 18-21 St. Stephen's Green, Dublin 2, Ireland. The provider processes content data (e.g. entries in online forms), contact data (e.g. e-mail addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses), and master data (e.g. names, addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.intercom.com/de/legal/privacy.

2.8.2. ​Firebase

We use Firebase for logging events on the app. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes meta/communication data (e.g. device information, IP addresses) and log data in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in logging events in our app for accounting and operational purposes.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.

3. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

4. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.