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Privacy Policy

Privacy Notice for the TruVenturo application system

Last amended: May 2018

We have created this privacy notice to inform you about how personal data is collected, processed and used in the context of our online application process.

 

1. Contact

The application system is provided by TruVenturo GmbH, Große Reichenstraße 27, D-20457 Hamburg, Germany (hereinafter referred to as: “TruVenturo” or “we”). TruVenturo is also the controller according to the EU General Data Protection Regulation (GDPR) for the collection, processing and use of personal data of applicants who participate in our application process (hereinafter referred to as “you”). Should you have any questions or suggestions regarding data protection in the application process, please do not hesitate to contact us. You are welcome to direct your data protection concerns to our data protection officer by sending an email to (applications@truventuro.com). 


2. Data processing in the context of the application process

2.1 Application in response to vacancies posted on our Homepage. 

You can apply for the vacancies advertised on our homepage exclusively via email. The purpose of data collection in this context is for the selection of candidates for possible employment with TruVenturo or one of our portfolio companies. In order to receive and process your application, we collect the following applicant data: first and last name, email address, telephone number and application documents such as curriculum vitae and cover letter. You also have the option of giving us further details that we may need to consider when applying (such as your salary expectations, availability, place of residence or additional documents).

We will check your application and contact you as part of the application process, in particular to schedule interviews or to clarify any questions that may arise from the data you provided.


2.2 Data processing of direct applications

We use the support of our portfolio company CareerTeam GmbH to process applicant data. Pursuant to Article 6 paragraph 1 lit. b) of GDPR, your information is processed and stored in their Customer Relationship Management System ("CRM System"). In connection to this, CareerTeam GmbH uses the Customer Relationship Management System of eRecruiter GmbH (eRecruiter GmbH, Am Winterhafen 4, A-4020 Linz, Universitätsring 8 / Stg. II / 1A, Austria). Your application will be redirected to their server, therefore invoking the data protection conditions of eRecruiter GmbH, which can be found at https://www.erecruiter.net/en/terms-of-use/. The privacy policy of CareerTeam GmbH can be found at https://www.careerteam.de/datenschutz.


If you apply for a TruVenturo position advertised on our homepage, your application may be forwarded to our portfolio companies if justifiable by the existence of a relevant job opening at one of the companies. If you do not want this, please let us know in your application. For all privacy queries regarding the application process (for example regarding your privacy rights) you can contact us using the contact details mentioned in point 1 above.


For portfolio company job offers on our homepage, we forward your application directly to the respective contact person in the respective portfolio company. To this end, your application will be included in the talent pool of TruVenturo and the respective portfolio company.


2.3 Data processing in case of direct contact

In addition, we use the services of recruiting tools to source, research and approach potential applicants for inclusion in the talent pool. In these cases, candidates voluntarily leave contact details for establishing future dialogue and therefore become applicants. Generating high quality applicants is a fundamental task in filling key positions at TruVenturo and our portfolio companies. We contact most of the researched candidates immediately, the others being placed as leads in our Customer Relationship Management System for contact at a future date if suitable positions arise. For the latter, we store the name as well as the publicly accessible link to the respective profile for the legally permitted period of time.


One of the services we use is "LinkedIn Professional Recruiter" offered by the LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. LinkedIn is a professional network and is certified under the Privacy Shield Agreement and guarantees the European data protection principles. In this context, we also use the LinkedIn Recruiting Tool. The privacy policy of LinkedIn can be found here.


As a further recruiting tool we use the service "Xing Premium" offered by XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Xing is a professional network. Xing's privacy policy can be found here.


The legal basis for the processing of your applicant data is Art. 6(1) Sentence 1(b) and Art. 88(1) GDPR in conjunction with Section 26(1) Sentence 1 of the German Federal Data Protection Act (BDSG). We store your applicant data upon receipt of your application. If we accept your application and subsequently employ you, we will store your applicant data for as long as the data is necessary for your employment and as far as we are legally required to retain it. If we reject your application, we will store your applicant data for a maximum of six months after rejection of your application, unless you give us your consent to longer storage (TruVenturo talent pool). 


2.4 TruVenturo talent pool

Through your application you consent to become part of our talent pool and that, once the application process is complete, we will store the data you submitted for your application in our TruVenturo talent pool for a further 24 months which will allow us to identify any further jobs at TruVenturo or the ventures in our portfolio which may be of interest to you and, if necessary, to contact you again using the stored contact details. From time to time, but usually not more than once a quarter, we may then send you information about vacancies at TruVenturo and/or the ventures in our portfolio which may be suitable for you. After this period, the data will be anonymised, unless you have given further consent separately. You may revoke your consent at any time in the future by contacting the contact details mentioned in point 1 above.


2.5 Data processing by Lever

We use the Customer Relationship Management System by Lever, Inc., 989 Market St, # 500, San Francisco, CA 94103 to process applicant data. Your application will be redirected to its server. To this end, the data protection conditions of Lever, Inc., which can be found at https://www.lever.co/terms-of-service, apply. We may contact you using the data provided by you. This data usage serves to fulfill the purpose of the contract in accordance with Art. 6 para. 1 lit. b EU Data Protection Regulation and our legitimate interest in the processing of data according to Art. 6 para. 1 lit. f GDPR.


2.6 Use of additional services

As part of our application process, we use the Google GSuite service of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, ("Google"). Google is certified under the Privacy Shield Agreement and guarantees the European data protection principles https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.


For internal communication with employees of TruVenturo and the portfolio companies, we use the services of Slack Technologies Limited, 4th Floor, One Park Place, Hatch Street Upper, Dublin 2, Ireland ("Slack"). Slack is certified under the Privacy Shield Agreement and guarantees the European data protection principles https://slack.com/intl/en/privacy-policy


In addition, we use  Microsoft Corporation's cloud service "Skype", One Microsoft Way. Redmond, WA 98052-6399, USA ("Microsoft") for internal communication with TruVenturo employees and the portfolio companies, as well as external communications for job applications with applicants, provided that the applicant's explicit consent has been obtained. Microsoft is certified under the Privacy Shield Agreement and guarantees the European data protection principles https://privacy.microsoft.com/en-US/privacystatement


3. Links to other websites and online content

Our website may contain links to websites and online content of other providers not affiliated with us. If you activate these links, we naturally no longer have any influence on which data is collected by the respective providers and which data they record. For more detailed information on data collection and use, please refer to the privacy policies of the respective providers. Since the collection and processing of data by third parties is beyond our control, we cannot assume any responsibility for this.

 

4. Disclosure of data

In principle, we will only pass on the data we collect if: 

  • You have given your express consent to this pursuant to Art. 6(1) Sentence 1(a) GDPR (e.g. in connection with the TruVenturo talent pool);
  • You have given your express consent to this pursuant to Art. 6(1) Sentence 1(a) GDPR (e.g. in connection with the TruVenturo talent pool);
  • We are legally obliged to do so under Art. 6(1) Sentence 1(c) GDPR; or
  • This is permitted by law and is required under Art. 6(1) Sentence 1(b) GDPR for the processing of contractual relationships with you or for taking steps at your request prior to entering into a contract. 

Pursuant to Art. 7(3) GDPR, you have the right to withdraw the consent you gave us at any time. As a result of this, we will cease the data processing based on this consent with future effect. This withdrawal of your consent will not affect the lawfulness of the processing carried out on the basis of the consent prior to the withdrawal.

 

Part of the data processing described in this data protection notice may be carried out by our service providers. In addition to the service providers mentioned in this data protection notice, this may in particular include data centres that store our website and databases, IT service providers that maintain our systems, and consulting firms. If we pass data on to our service providers, they may use the data exclusively for the fulfilment of their tasks. We have carefully selected and commissioned the service providers. They are contractually bound by our instructions, have implemented appropriate technical and organisational measures to protect the rights of data subjects, guarantee an appropriate level of data protection and are carefully monitored by us.

 

5. Your rights

You have the right to information about how we process your personal data at any time. When providing this information, we will explain the data processing to you and provide you with an overview of the data stored about you. If data stored by us is incorrect or no longer up to date, you have the right to have this data corrected. You may also demand that your data be erased. Should the erasure not be possible in exceptional cases due to other legal regulations, the data will be blocked so that it is only available for that legal purpose. You are also entitled to have the processing of your data restricted, e.g. if you believe that the data we have stored is incorrect. You also have the right to data portability, which means that on request we will send you a digital copy of the personal data you have provided.

In order to assert your rights described here, you can contact us at any time using the contact details provided in Section 1 above. This also applies if you wish to receive copies of safeguards in order to prove an adequate level of data protection.

In addition, you have the right to object to data processing if it occurs based on Art. 6(1) Sentence 1(e) or (f) GDPR or for direct marketing purposes. Finally, you have the right to lodge a complaint with our competent data protection supervisory authority. You can assert this right by contacting a supervisory authority in the Member State of your habitual residence, your place of work or the place of the alleged infringement. The competent supervisory authority in Hamburg is: Hamburg Commissioner for Data Protection and Freedom of Information, Kurt-Schumacher-Allee 4 20097 Hamburg.

 

Right of withdrawal and objection

If we process your data on the basis of legitimate interests pursuant to Art. 6(1)(f) GDPR, you have the right under Art. 21 GDPR to object to the processing of your data, and to give us reasons which arise from your particular situation which, in your opinion, show that your legitimate interests override ours. If your objection is to data processing for direct marketing purposes, you have a general right of objection, which we will implement without requiring you to give reasons.


If you would like to make use of your right of withdrawal or objection, it is sufficient to simply notify us using the contact details provided above.


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