On This Page
1. Controller and Contact Details
The controller for CrewCircuit account, billing, website, and support processing is Obeta Gregory Chukwuma, Amendestrasse 28, 13409 Berlin, Germany.
You can contact us at support@crewcircuit.de or by phone at +49 162 1612691.
2. Our Role as Controller and Processor
CrewCircuit acts as a controller when we decide why and how personal information is processed, for example for customer accounts, billing, security, support, and service administration. When a business customer uploads or manages worker data in CrewCircuit and decides the purposes of that processing, the customer is usually the controller and CrewCircuit acts as its processor.
Processor relationships are governed by the applicable customer agreement and, where required, a Data Processing Agreement under Article 28 GDPR. Customers should ensure that their own privacy notices and instructions cover the worker data they enter into CrewCircuit.
3. Information We Collect
We collect information you provide when creating an account, staffing shifts, or contacting support. This includes names, contact details, role assignments, availability, time and attendance records, payroll and billing information, and any content you submit. We also collect device and usage data such as IP address, browser type, app version, log files, and diagnostic events.
4. Purposes and Legal Bases
Where GDPR applies, we process personal information for the following purposes and legal bases. The exact data involved depends on your role, workspace settings, and how your organization uses CrewCircuit.
| Purpose | Data | Legal basis |
|---|---|---|
| Account creation and administration | Name, email address, account details, workspace role, authentication data | Art. 6(1)(b) GDPR for contract performance; Art. 6(1)(f) GDPR for workspace administration |
| Shift, attendance, and workforce management | Shift assignments, availability, time records, attendance events, role and team information | Art. 6(1)(b) GDPR where needed to provide the service; Art. 6(1)(f) GDPR for customer workforce coordination, or customer instructions where we act as processor |
| Authentication, security, and fraud prevention | Login events, device data, IP address, security logs, diagnostic events | Art. 6(1)(b) GDPR to provide secure access; Art. 6(1)(f) GDPR for platform security and abuse prevention |
| Customer support and communications | Contact details, support messages, issue history, notification preferences | Art. 6(1)(b) GDPR for service support; Art. 6(1)(f) GDPR for responding to requests and improving support |
| Billing, invoicing, and accounting | Billing contacts, payment status, invoices, tax and accounting records | Art. 6(1)(b) GDPR for billing; Art. 6(1)(c) GDPR for legal and tax obligations |
| Optional marketing | Email address, preferences, campaign interaction data | Consent where required under Art. 6(1)(a) GDPR; otherwise Art. 6(1)(f) GDPR for limited business communications where permitted |
5. Recipients and Service Providers
We share personal information only where needed to operate CrewCircuit, comply with law, protect the service, or follow customer instructions. Recipients may include hosting and database providers, authentication and security providers, analytics and diagnostics providers, email or notification providers, payment and billing providers, professional advisers, and public authorities where legally required.
CrewCircuit uses infrastructure and platform services such as Firebase/Google Cloud for core app operation. Service providers are required to process personal information only for the agreed service purposes and not for their own marketing. We do not sell personal data.
6. Cookies and Similar Technologies
We use cookies and similar technologies to remember preferences, keep you signed in, measure performance, and improve user experience. You can control cookies through your browser settings and, where available, our in-app preference controls. For details about browser and device storage on our marketing site, see the Cookie Policy.
7. International Transfers
CrewCircuit is operated from Germany, but our service providers may process personal information in other countries, including countries outside the European Economic Area. Where GDPR requires transfer safeguards, we rely on adequacy decisions, Standard Contractual Clauses, provider transfer addenda, or other lawful transfer mechanisms appropriate to the provider and data flow.
8. Data Retention
We retain personal information only for as long as needed for the purposes described in this policy, to provide the service, to follow customer instructions, or to meet legal obligations. When data is no longer needed, it is deleted, anonymized, or de-identified.
Retention criteria include: account data is kept while the account or workspace is active and for a reasonable period after closure; worker, shift, attendance, and workforce records are kept according to customer instructions, contract needs, and applicable retention requirements; invoices and accounting records are kept for the statutory periods required by German law; security and diagnostic logs are kept for the period needed to protect and troubleshoot the service; and support communications are kept as long as needed to resolve requests and maintain a support history.
9. Security
We use administrative, technical, and physical safeguards designed to protect personal information. No system is perfectly secure, but we continuously improve our controls.
10. Your GDPR Rights
Where GDPR applies, you may have the right to request access, rectification, erasure, restriction of processing, data portability, and objection to processing based on legitimate interests. Where processing is based on consent, you may withdraw consent at any time without affecting processing that happened before withdrawal.
To exercise these rights, contact support@crewcircuit.de. We may need to verify your identity and, where CrewCircuit acts as processor for a business customer, we may forward or refer your request to that customer as the controller.
11. Account and Data Deletion
Users can request account deletion or data removal at any time by contacting support@crewcircuit.de. Some information may need to be retained where required for legal, accounting, security, or dispute-resolution purposes, or where a business customer controls the relevant workforce record.
12. Children's Privacy and Eligibility
The Services are intended for adults and business teams. Users must be at least 18 years old to use CrewCircuit unless a separate customer arrangement expressly permits another lawful setup. We do not knowingly collect personal information from anyone under 18.
13. Complaints to Supervisory Authorities
If you believe our processing of your personal information violates data protection law, you have the right to lodge a complaint with a competent supervisory authority. In Berlin, the supervisory authority is the Berliner Beauftragte fuer Datenschutz und Informationsfreiheit. You may also contact the authority in your place of residence, workplace, or the place of the alleged infringement.
14. Changes to This Policy
We may update this policy to reflect changes in the Services or legal requirements. The "Last updated" date will reflect the most recent revision.