Privacy Policy

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:
WeSeeUs Operations UG (haftungsbeschränkt), Fischerinsel 10, 10179 Berlin
E-mail: datenschutz@weseeus.de

2. Purpose of Processing

WeSeeUs processes personal data solely for the purpose of conducting structured peer-review processes within teams. Data is processed specifically to:

  • create and manage user accounts for customers (team administrators),
  • send questionnaire invitations to participants,
  • generate feedback reports based on completed questionnaires,
  • produce feedback PDFs and deliver them by e-mail.

Legal basis for the processing of customer data: Art. 6(1)(b) GDPR (performance of a contract).

3. Participation in Feedback Processes

Personal data of participants is processed in connection with feedback processes. The following applies:

  • Participants provide structured feedback about other team members.
  • Multiple independent responses are used by AI-assisted methods to generate abstracted development reports and team analyses.
  • Participants initially receive access to their own abstracted feedback only.
  • If a participant activates a personal user account, their access within the existing feedback process is extended to read-only access to the abstracted development reports of all team members in this process and to the team analysis.
  • The person who initiates and administers the feedback process (customer/initiator) receives access to the abstracted development reports of all participants and the team analysis for the purpose of conducting the process.
  • Internal administrators may have access to personal data, raw responses, and assessment relationships for operational, support, and security purposes.
  • Customers and participants do not see raw responses or assessment relationships.
  • Access is restricted to the respective feedback process.

The processing in connection with feedback processes is carried out on the basis of Art. 6(1)(f) GDPR (legitimate interest). The legitimate interest consists in conducting structured, abstracted peer-review processes for personnel development within teams.

4. Categories of Data Processed

The following categories of personal data are processed:

  • Customers: name, e-mail address, encrypted password, registration timestamp, language preference.
  • Participants: name, e-mail address, position within the team, language preference, responses to peer-review questionnaires, generated feedback.

No special categories of personal data within the meaning of Art. 9 GDPR are processed.

5. Recipients of data / processors

To provide the service, WeSeeUs uses carefully selected processors with whom data processing agreements under Art. 28 GDPR are in place:

  • OpenAI (OpenAI, L.L.C., USA) – generation of AI-assisted feedback reports and translations from questionnaire responses.
  • Scaleway (Scaleway SAS, France) – delivery of system and feedback emails.
  • Hetzner (Hetzner Online GmbH, Germany) – hosting of the application and database.

Personal data is not sold or shared for advertising purposes.

6. Transfer to third countries

To generate the feedback reports, questionnaire responses are transferred to OpenAI in the USA – a third country outside the EU/EEA. Before transfer, participants' real names are replaced by pseudonyms (identifiers); the mapping back to real names happens exclusively locally after processing. The transfer is based on the EU Standard Contractual Clauses (Art. 46 GDPR) and, where the provider is certified, the EU-US Data Privacy Framework. The other processors (Scaleway, Hetzner) process data within the EU.

7. Retention Period

Personal data is stored for as long as the account is active or the processing purpose exists. After account deletion or expiry of the retention period, data is automatically anonymised or deleted:

  • Inactive teams are anonymised after 180 days.
  • Data is permanently deleted after 365 days.
  • Account deletion can be requested at any time and will be carried out within 14 days.

8. Rights of Data Subjects

You have the right to:

  • access to stored data (Art. 15 GDPR)
  • rectification of inaccurate data (Art. 16 GDPR)
  • erasure of your data (Art. 17 GDPR)
  • restriction of processing (Art. 18 GDPR)
  • data portability (Art. 20 GDPR)
  • objection to processing (Art. 21 GDPR)
  • lodging a complaint with the competent supervisory authority (Art. 77 GDPR)

9. Contact

For questions about data protection or to exercise your rights, please contact:
datenschutz@weseeus.de