Cultural Care Au Pair (“CCAP”) is committed to protecting the privacy of our potential and existing au pairs. The CCAP privacy policy (the “Privacy Policy”) applies to all Personal Data (as defined below) processed by us, including Personal Data collected or submitted through our websites, mobile applications or through our official social media pages or through other channels online and offline as further described below (collectively the “CCAP Products”).

If you cannot, or will not, provide us with the personal information we reasonably require, we may be unable to provide you with the information, goods or services you have requested. CCAP will never use your personal data for purposes other than providing you with the information, goods, or services you have requested. And we will never, ever, share your data with third party companies unassociated with CCAP. Your data will be in safe hands.

International Care AG, Selnaustrasse 30, 8001 Zürich, Switzerland, is the company that helps you qualify as an au pair, organizes your insurance coverage, helps you prepare for your stay abroad and makes your travel arrangements once you have found your host family. This company is data controller for the data you provide to us in connection with your contract with us.

“Personal Data” is information or pieces of information that could allow you to be identified. We may collect, store and use the following information about you:

Contact details

• Name and contact details (e.g. postal and email address, telephone number)

• Account information or user ID (e.g. user name, profile picture or social media account ID)

• Country of residence or citizenship

Background information

• Work experience, education, language proficiency, references

• Marital status

• Criminal background check

Other information collected or generated in connection with your application

• Birth date

• Gender

• Language proficiency

• Photos or video recordings of you

• Name and contact details of family members

• Communication history

• Medical condition (e.g. allergies or illness), dietary needs, smoking habits, immunizations

• Travel details, passport copy, visa information

• Driver’s license

• Insurance data

• Religious beliefs

• Logs on pre-travel education course completion

• Name of references and content of recommendations

• Personality Assessment

• Other information you or the interviewer provides during a phone-or video call or a chat, and recordings and/or transcripts of such calls or chats.

Internet browser data

• Technical information, e.g. screen/user name, IP address, browser and device data, information collected through cookies, pixel tags and other technologies, server log file data, app usage data and location data, page views and website navigation

• Preferences (e.g. language)

Payment details

• Credit and debit card number, payment data or bank account details

• In case of refunds: bank account details, full name, name of account holder, address, refund amount

We collect Personal Data in a variety of ways:

• Directly from you. Information is collected directly from you, either by you providing the information directly to us or you are acting in a manner that provides us with the information, for example:

  • Offline: We collect Personal Data from you offline, for example when you contact customer service, enroll in a product or service or provide information to us in writing, or during a phone or video call.

  • Online: We collect your Personal Data through the CCAP Products, for example when you sign up for a newsletter or a brochure, use our chatbot, enroll in a product or service. We also collect Personal Data:

    • Through cookies. Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/. For detailed information about the cookies we use and the purposes for which we use them, please see ours cookie policy.

    • Through your use of a mobile application. When you download and use one of our mobile applications, and to the extent allowed by your privacy settings in the application, we track and collect mobile application usage data, such as the date and time the mobile application on your device accessing our servers and what information and files have been downloaded to the mobile application based on your device number as well as statistics on malfunctions and crashes that the users experience.

    • Through your device. Provided that you have enabled that function on your device, we collect the physical location of it to provide you with personalized location-based services and content. Read more about such services under “How do we use Personal Data?”.

• From our corporate affiliates, business partners, assistance providers or claim handlers. We may receive Personal Data from other parties in conjunction with your course/program, including:

  • Our corporate affiliates, such as the local CCAP company that promotes our services and offers customer service in your country of residence and provides us with the Personal Data that is needed to come to an agreement with you, or Cultural Care Inc - a company incorporated in the Commonwealth of Massachusetts, USA which is designated by the US Department of State to sponsor J-1 Au Pair visas and it works with independent subcontractors known as Local Childcare Consultants to help you have great experience in the US.

  • Business partners, such as local sales agents, promote the sales of our services in your country of residence.

  • Claims handlers who receive information about your insurance claims in case of an insurance situation.

• From other sources. We may receive your Personal Data from other sources, such as public databases; joint marketing partners such as marketing agencies or providers of software and services for digital marketing automation and analytics; social media platforms, including but not limited to; Meta, Snapchat, LinkedIn, X, YouTube and messenger services such as WhatsApp or Facebook Messenger; from people with whom you are friends or otherwise connected with, as well as from other third parties. Furthermore, we use cookies to track members of social media networks as further explained in our cookie policy.

• If you browse our sites. We may also collect information about your use of our services through your browser to trace activity on our sites, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, service provider, and the name and version of the CCAP Product you are using. In addition, an IP Address is identified and logged automatically in our server log files whenever you visit the CCAP Products, along with the time of the visit and the page(s) that were visited. You can read more about collection of your IP address and other browsing data in our cookie policy.

We will use your Personal Data for the following purposes:

• Your Personal Data will be processed by CCAP for the purposes of evaluating and completing your application, providing you with the products and services that you have ordered (including travel insurance coverage), for customer service, administrative services or as otherwise necessary to perform the contract between you and us or as further described in this policy.

• We may also use Personal Data:

  • To establish the appropriate language level, analyse your skills and suggest improvements

  • For statistical purposes, system maintenance, backup, calculating usage levels, and helping diagnose server problems with the CCAP Products, for business development as well as to ensure that the CCAP Products function properly.

  • To analyze our interactions to improve our sales process, our product and quality control

  • To allow you to contact and be contacted by other users through the CCAP Products, as permitted by the applicable product.

  • To provide customer service or send service-related information, via various channels such as SMS, messenger services like WhatsApp, Facebook Messenger, chat bots or email.

  • To allow you to participate on message boards, chat, profile pages and blogs and use other services enabling you to post information and materials.

  • Where relevant, to establish, exercise or defend legal claims, or for debt collection.

  • To detect, investigate or prevent information security incidents, fraud, misrepresentation, security incidents or crime;

  • To meet applicable legal, regulatory and compliance requirements, including but not limited to sanctions laws.

  • To enable you to report a concern through our whistleblower channels.

  • If you have signed a photo release form or otherwise indicated your consent: photos or video recordings of you may be used in marketing material to promote CCAP’s products, and information/content from your profile may be displayed on our website.

  • For marketing purposes, including:

    • To analyse and improve our offers by identifying usage trends, determining the effectiveness of our promotional campaigns and tailoring the CCAP Products experience and content based on your past activities on the CCAP Products.

    • To provide you with personalized location-based services and content through the use of your device’s physical location. For example, you will be redirected to the local CCAP website in your language if your device indicates that you are browsing from that country, or you may be suggested at the nearest CCAP office to your location for visits or information.

    • To market our products and services, including special promotions based on your interests, for example through email marketing solutions such as Salesforce Marketing Cloud’s management software which maintains mailing lists and schedules and modifies email messages based on what recipients read, click-on or forward, or through other channels such as SMS, other instant messenger services or chat bots, telephone calls with operator (so-called telemarketing) or traditional mail. All such communication will include a clear unsubscribe link or offer another opt-out function.

    • For the transmission and communication to third-party companies or affiliates of CCAP for their marketing purposes, including direct marketing activities and telemarketing.

• We may offer a possibility to pay for the CCAP Products via payment solutions, including but not limited to, Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm (“Klarna”). In order to offer you Klarna’s payment methods, we might share your personal data in the form of contact and order details with Klarna, for Klarna to assess whether you qualify for their payment methods and tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.

We share your Personal Data as described in this Privacy Policy, and as permitted by applicable law:

• Corporate affiliates

  Our corporate affiliates include, for example, a local CCAP company that promotes the sales of our services and offers customer service in your country of residence, or Cultural Care Inc - a company incorporated in the Commonwealth of Massachusetts, USA which is designated by the US Department of State to sponsor J-1 Au Pair visas and it works with independent subcontractors known as Local Childcare Consultants to help you have great experience in the US. Your data may also be shared with CCAP affiliates that companies that provide internal service functions such as IT, legal or other shared services. If we have obtained your consent, we may also share your Personal Data with our CCAP corporate affiliates for their own marketing purposes. A list of those affiliates can be found here.

• Third party service providers

  We share Personal Data with third parties in connection with the delivery of services to you and the operation of our business. For example, we may share Personal Data to providers of IT systems in order to manage customer relations, process credit cards or other payment solutions, schedule meetings or match you with a host family; or to providers of software and services for digital marketing automation and analytics; to advertising platforms in order to serve you with advertising tailored to your interests; to other third parties to provide customer service, business analytics, fraud prevention and compliance services and to visa processing agencies. If you have not paid your bills to us in time, we may transfer some of your data to a debt collection provider. This includes your name, your date of birth and your contact. Personal Data collected under a photo release form may be shared with the photographer/production company. Where we offer the use of a chatbot on the CCAP Products through the latest AI technology, the questions that you ask the chatbot will be transferred to and temporarily stored by the AI technology provider, but will not be used to train or improve their AI models. No personal data will be transferred, unless you include personal data in your questions, You can read more here: https://cloud.google.com/terms/cloud-privacy-notice. The chat conversation and the personal data submitted in the designated fields of the chat will be stored by CCAP in our customer relations management system for the purpose of marketing or customer service purposes.

• Travel suppliers

  We share Personal Data with travel related suppliers, including hotels, airlines, bus or train service providers, as well as local childcare consultants or other contractors in connection with the management of our programs; or a travel insurance company that prepares the travel insurance for you. Please note that travel suppliers may contact you to obtain additional information if and as required to facilitate your booking or to otherwise provide the travel or associated services.

• Business partners

  We may share your Personal Data with business partners. This may happen, for example, when we promote a program or offer a service or product in conjunction with a third-party business partner or when we use local sales agents to promote our services in your country of residence. In most cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice.

• Other third parties

  If you log in to an CCAP product/service by using a single sign-on through a third-party app or platform, you will share certain information with that social media platform, such as the fact that you have visited or interacted with us.

• Corporate transactions

  If our business is directly or indirectly sold or combined with another business, your Personal Data may be disclosed to our advisers, a prospective purchaser and any prospective purchaser’s advisers and may be transferred to the new owners of the business.

• Legal rights and obligations

  We also share Personal Data as we believe to be necessary: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions or a contract; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

CCAP has business activities in several different countries, and your Personal Data may be shared with affiliates of CCAP or other recipients as described above that have a need to receive such data for the purpose of performing the services you have requested, or according to this policy. Such recipients may be located outside your own country, including countries outside the EEA/Switzerland that do not ensure the same level of protection as the country where you are domiciled, including to any of CCAP’s service providers located in USA, within EU or in India. Unless the European Commission has decided that a country ensures an adequate level of protection for personal data, CCAP will use contracts based on the European Commission’s standard data protection clauses for international transfers of personal data to ensure compliance with applicable law. You have the right to ask us for a copy of the standard data protection clauses (by contacting us as set out in the Contact Us section below).

We have documented the lawful bases for our processing activities in Annex 1.
On some occasions, we process your Personal Data based on your consent (for example, when you agree that we may set up cookies other than those that are strictly necessary). To the extent we use sensitive Personal Data, we base this on your explicit consent, unless the processing is otherwise permitted under applicable data protection laws. Sensitive data can for example be information about health, ethnicity or religious beliefs - read more under “Sensitive data”. Where we process data based on consent, your consent is revocable at any time.

The processing of some of your Personal Data is necessary to provide services to you pursuant to the agreement that you entered with us. Without this information, we would not be able to provide certain services to you.
On other occasions, we process your data when we are required by law (for example, if we are required by court order or any applicable law to process data).
We also process your Personal Data when it is in our, or a third party’s, legitimate interests to do so, provided that your data protection rights do not override these interests. This may be to market products or services like the one(s) you have already purchased from that same legal entity. Where we are not relying on consent, legal requirements or contractual necessity or vital interests, we process your Personal Data based on legitimate interests as described in this Policy.

We use appropriate organizational, technical and administrative measures to keep the Personal Data under our control accurate and up to date, as well as to protect the Personal Data against unauthorized or unlawful processing and the accidental loss, destruction or damage of the Personal Data.

If at any time you wish to stop receiving marketing communications from us, you can use the unsubscribe feature in the marketing communications you received or let us know by using the contact information listed in the “Contact Us” section. In your request, please indicate that you wish to stop receiving marketing communications from us. Please note that changes may not be effective immediately. We will endeavor to comply with your request(s) as soon as reasonably practicable.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating on any site to which the CCAP Product contains a link. The inclusion of a link on CCAP Products does not imply endorsement of the linked site by us or by our affiliates.
Additionally, we may provide you with access to third-party functionality that permits you to share your activities on CCAP Products to your social media account(s), for example Facebook or LinkedIn. Please note that any information that you provide through the use of this functionality is governed by the applicable third party’s privacy policy, and not by this Privacy Policy. We have no control over, and shall not be responsible for, any third party’s use of information that you provide through the use of this functionality.

We will only keep your Personal Data for as long as it is necessary for the purposes for which it has been collected or in accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims or unless a specific time period has been communicated.
We will keep limited parts of your Personal Data which are necessary for marketing purposes until you withdraw your consent, but in no event for longer than 10 years after your last completed service or delivery of product.

If you are under the age of 16, you should review this text together with your parents or guardians to make sure you both understand them. We are not responsible for checking your age but sometimes we still do verification checks. If we learn that you are under the age of 16 and that we have collected information about you without consent from your parent or guardian, we will delete the information as soon as possible and you will not be able to use CCAP Products.

Sensitive Personal Data is data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health or medical condition, criminal background or trade union membership. We may need to collect sensitive Personal Data in order to administrate your application and the au pair program, since being an au pair requires you to be in good physical and mental health. Therefore, we ask you in the application process to disclose all serious pre-existing medical conditions and current medications prior to departure. We may also request proof of vaccination and doctors’ certificates. We also ask you to continuously notify us any new developments in your physical or mental health until departure. This is required under the U.S. State Department’s governing regulations for cultural and educational exchange programs and is also necessary for us to be able to successfully prepare you for your program and to match you with a host family.
If you become ill or incapacitated after you have departed, we may take any action deemed necessary for your safety and well-being, including securing medical treatment and transporting your home. If that happens, CCAP may contact your emergency contact(s) with regard to the health issues that have occurred.
We base our processing of your sensitive personal data related to your health on your consent (unless processing is needed to protect your vital interests). You have the choice not to provide us with this information, but please be aware that we will not be able to proceed with your application in that case. You have the right to withdraw your consent at any time by contacting us using the details below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose of your application, unless we have another proper and legitimate basis for doing so.
If you agree to it, we will share the information we receive from you with matching host families.
We will store and share any sensitive Personal Data that we collect about you in an encrypted environment and will only provide access to those who have a need to know the information. The data will be kept only for as long as necessary to achieve the purposes it was collected for, or for longer if required to meet local statutory limitation periods for bringing legal claims.

Our Privacy Policy may change from time to time. We will not significantly reduce your rights under this Privacy Policy without informing you. We will post any Privacy Policy changes on this page, and, prior to implementing such changes, we will provide more prominent notice. Where required by law, we will seek your prior consent to any change.

We respect your rights to access and control your information and will respond to requests in accordance with applicable privacy and data protection legislation. We may ask you to verify your identity and provide other details to help us respond to your request.

Depending on the lawful basis for processing upon which we rely, you have a right to:

1. request access to your Personal Data;

2. request that we correct or complete Personal Data that is inaccurate or incomplete;

3. request that we erase your Personal Data, which we will do where required by applicable privacy and data protection legislation;

4. restrict our processing of your Personal Data, in certain circumstances;

5. request that we provide you with copies of your Personal Data in a machine-readable format or transfer it across different services;

6. object to certain types of processing, including where we process your Personal Data on the basis of our legitimate interests and for direct marketing purposes; and

7. where we have asked for your consent to process your data, to withdraw this consent.

These rights are limited in some situations under applicable privacy and data protection legislation – for example, where we can demonstrate that we are under a legal obligation or have other legitimate grounds to process your data.

If you wish to exercise these rights, please contact us using the contact details below. We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns, you also have the right to complain to data protection authorities.

If you have given your consent to marketing, CCAP may collect Personal Data for the purpose of profiling in order to serve promotional information tailored to your interests, for example to analyze or predict aspects concerning that your economic situation, health, personal preferences, interests, reliability, behavior, location or movements. This type of profiling does not produce legal effects on you.

We may also record and analyze sales calls with you with the help of machine learning technology, for the purpose of quality control and improving sales performance, as well as training our language models. Information from such calls, for example tone and key words, is also combined with other personal data we have collected in connection with our communications with you, such as meeting attendance, and meeting notes. This type of processing does not produce any legal effects on you.

If you would like to have a copy of the information CCAP holds about you; a copy of the standard data protection clauses or would like to exercise any of your rights, please contact us at the address International Care Ltd, Selnaustrasse 30, 8001 Zurich, Switzerland or click here.

If you have complaints about our handling of your Personal Data, please first contact our contact DPO by clicking here. You also have a right to contact the supervisory authority in the country where you live.