PRIVACY POLICY
Release November 2018
This data protection notice informs you how personal data is collected, processed and used when you visit our website.
1. CONTACT PERSON
The provider of the website is TruVenturo GmbH, Große Reichenstraße 27, 20457 Hamburg (hereinafter: "TruVenturo" or "we"). TruVenturo is also responsible for the collection, processing and use of personal data of those (hereinafter "you") that visit our website, contact us or participate in our application process according to the EU Basic Data Protection Regulation (DSGVO). If you have any questions or suggestions regarding data protection, please do not hesitate to contact us. You are welcome to contact us at (privacy@truventuro.com ) if you have any questions about data protection.
2. GENERAL INFORMATION
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and according to the legal data protection regulations as well as this data protection explanation.
3. DATA ACQUISITION ON OUR WEBSITE
SERVER LOG FILES
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
Browser type and browser version used operating system Referrer URL Hostname of the accessing computer Time of the server request IP address This data will not be merged with other data sources.The basis for data processing is Art. 6 para. 1 lit. f DSGVO, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.
Our legitimate interest is based on the purposes of data collection listed below. We would like to point out that we are unable to draw any direct conclusions regarding your identity from the data that is collected, and that we refrain from doing so.
We use the IP address of your device and the other data listed above for the following purposes:
ensuring that a trouble-free connection is established ensuring the comfortable use of our website/application the evaluation of system security and stability The data will be erased as soon as it is no longer required for the purpose of its initial collection. In the case of data collection to enable making the website available, this is the case when the respective session ends. The data is stored in log-files for a period of up to 6 weeks and is then deleted automatically so that it is no longer possible to allocate the user. We also use what are known as cookies for our website/application, as well as tracking tools, targeting methods and social media plug-ins. The exact procedures used and how your data are used for this purpose are explained in more detail below.
4. DATA PROCESSING AS PART OF THE APPLICATION PROCESS
4.1 Application for advertised vacancies
You can apply for the positions advertised on our homepage by post or via email. The purpose of the data collection is to select applicants for possible employment with TruVenturo or one of the companies in our portfolio. To receive and process your application, we collect the following applicant data: First and last name, e-mail address, telephone number and application documents (CV and cover letter, if applicable). You also have the opportunity to provide us with further information that we may need to consider when submitting your application (e.g. your salary expectations or additional documents).
4.2 DATA PROCESSING FOR DIRECT APPLICATIONS
Your application documents will be processed to the required extent by us in accordance with Art. 6 Para. 1 lit. b) DSGVO and can be stored in our Customer Relationship Management System ("CRM System") for this purpose.
4.3 DATA PROCESSING FOR DIRECT CONTACT
In addition, we use the services of so-called recruiting tools to address potential applicants. Recruiting tools are used to research and approach potential candidates for the purpose of inclusion in the talent pool. The candidate provides contact data of their own initiative for further dialogue and is therefore highly likely to become an applicant. Generating high-quality applicants is a fundamental task for filling key positions at TruVenturo and our portfolio companies. We contact the majority of the researched candidates directly, the remainder are stored as leads in our Customer Relationship Management System in order to contact them for future suitable positions. 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.
4.4 TRUVENTURO TALENT POOL
You can agree to be included in our talent pool. We will store the data you provide as part of your application in our TruVenturo Talent Pool for a further 24 months after completion of the application process in order to identify any other interesting positions at TruVenturo or the portfolio companies in our group of companies for you and to contact you again using the stored contact data if necessary. We will then, usually no more than once a quarter, send you information about open and potentially suitable vacancies at TruVenturo and/or the companies in our portfolio. After the deadline has expired, the data will be anonymized unless you have separately given us new consent. You can revoke your consent at any time for the future by contacting us at the contact details listed in section 1 above.
4.5 DATA PROCESSING BY LEVER
We use the Customer Relationship Management System of Lever, Inc., 989 Market St #500, San Francisco, CA 94103 for processing applicant data. Your application will be redirected to their server. To this extent, the Lever, Inc. Privacy Policy, which can be found at https://www.lever.co/terms-of-service , applies. We may contact you using the information you provide, if necessary. This use of data serves the purpose of fulfilling the contract pursuant to Art. 6 Para. 1 lit. b EU Data Protection Basic Regulation and there is also our legitimate interest in data processing pursuant to Art. 6 Para. 1 lit. f DSGVO.
4.6 USE OF FURTHER SERVICES
As part of our application process, we use the "Google GSuite" service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google"). Google is certified under the Privacy Shield Agreement and thereby provides a guarantee of compliance with European privacy laws https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active . We also use the cloud service "Skype" of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA ("Microsoft") for external communication for job interviews with applicants, provided that the applicant has given his explicit consent. Microsoft is certified under the Privacy Shield Agreement, thereby providing a guarantee of compliance with European data protection law https://privacy.microsoft.com/de-DE/privacystatement .
5. Cookies – general information
We use cookies on our website on the basis of Article 6 (1) (f) GDPR. Our interest in optimizing our website is deemed to be legitimate within the meaning of the aforementioned provision.
Cookies are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our website or use our app. Cookies do not harm your device, do not contain viruses, Trojans or other malicious software. The information stored in the cookie is tied to the specific device used. However, this does not mean that we are immediately aware of your identity. In part, cookies are used to make the use of our service more pleasant for you. For example, we use what are known as session cookies to detect that you have already visited individual pages on our website or that you have already logged in to your user account. These are automatically deleted after you leave our website. In addition, to ensure user-friendliness we also use temporary cookies, which are stored on your device for a specific period of time. If you visit our website again to use our services, it is automatically detected that you have already visited us, as well as what information you entered and the settings you used, so that you do not have to reenter them.
If you already have an account and are logged in or activate the "Stay logged in" feature, the information stored in cookies will be added to your user account.
On the other hand, we use cookies to statistically record the use of our website, to optimize our services, and to display information tailored to your specific needs. These cookies enable us to automatically detect that you have previously visited us when you return to our website. These cookies are automatically deleted after a defined period of time. Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or to make sure that a message always appears before a new cookie is created. However, disabling cookies completely may mean that you will not be able to use all the features of our website. The storage period of cookies depends on their purpose and therefore varies.
6. Analytical tools
In order to customize and continuously optimize our websites in line with users’ needs, we deploy tools on the basis of Article 6 (1) (f) GDPR which permit us to analyze the use of our website.
6.1. Google Analytics
We use Google Analytics, a web analytics service provided by Google. In doing so, pseudonymized usage profiles are created and cookies are used. The information generated by the cookie about your use of this website, e.g.
browser type/version operating system used Referrer URL (the previously visited page) hostname of the accessing computer (IP address) time of server request is transmitted to a Google server in the US and stored there. Google complies with the Privacy Policy of the US Privacy Shield and is registered with the U.S. Department of Commerce's US Privacy Shield Program. In addition, we have entered into a data processing agreement for the use of Google Analytics. Under this agreement, Google assures that Google processes data in accordance with the General Data Protection Regulation and ensures the protection of the data subject's rights.
The information is used to evaluate the use of the website, to compile reports on the activity on the website, and to provide other services related to the use of the website and internet usage for the purposes of market research and to customize the design of these websites in line with the needs of users. This information may also be transferred to third parties if required by law or if third parties are contracted to process this data. Under no circumstances will your IP address be combined with any other data from Google. The IP addresses are anonymized, which means that it is not possible to identify specific individuals (“IP masking”).
You can prevent the installation of cookies by setting your browser software accordingly. However, disabling cookies completely may mean that you will not be able to use all the features of our website. You may also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing this browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en ). As an alternative to the browser add-on, especially for browsers on mobile devices, you can prevent the collection by Google Analytics by clicking on this link . An opt-out cookie will be set which prevents the future collection of your data when you visit this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again. For more information regarding data privacy related to Google Analytics, visit the Google Analytics website: https://support.google.com/analytics/answer/6004245?hl=en .
6.2. Google Tag Manager
We use the Google Tag Manager. This Google service allows website tags to be managed through an interface. Only tags are implemented, i.e. no cookies are set and no personal data is collected. The Tag Manager triggers other tags that may themselves collect data. Google Tag Manager does not access this data. If deactivation has been done at the domain or cookie level, it will apply to all tracking tags implemented with Google Tag Manager. More information can be found in the Google Tag Manager use policy: https://www.google.com/intl/de/tagmanager/use-policy.html .
7. Targeting
The targeting measures listed below and used by us are implemented on the basis of Article 6 (1) (f) GDPR. Targeting is used to perform targeted advertising. Through the targeting measures we use, we want to make sure that advertisements which are geared to your interests are displayed on your devices.
7.2. Google AdWords
TruVenturo uses Google's AdWords service, which uses conversion tracking to measure the effectiveness of individual ads, offers and features. For this, a cookie is set as soon as you click on a Google ad. This cookie does not personally identify you, but rather makes it possible to determine whether you return to the page with the specific offer during the 30-day period in which the cookie is valid.
Each AdWords advertiser receives a different cookie. As a result, cookies cannot be tracked via the website of AdWords advertisers. The information obtained using the conversion cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. We track the total number of users who have clicked on an ad and were redirected to the website with a conversion-tracking tag.
You can permanently prevent the storage of the Google conversion cookie by setting your browser software accordingly. Google's privacy policy on conversion tracking can be found here: https://services.google.com/sitestats/en.html .
7.3. Google Dynamic Remarketing
We use the features of Google Dynamic Remarketing with the cross-device features of Google AdWords and Google DoubleClick.
This feature allows us to link the advertising audiences created with Google Dynamic Remarketing to the cross-device features of Google AdWords and Google DoubleClick. In this way, interest-based, personalized advertising messages that have been customized for you based on your past usage and browsing behavior on a device (e.g., smartphone) may also be displayed on another device you use (e.g., tablet or PC).
If you have given the appropriate consent to Google, Google will link your web and app browsing history with your Google Account for this purpose. That way, the same personalized advertising messages can appear on any device you use to sign in to your Google Account.
To support this feature, Google Analytics collects Google-authenticated IDs of users who are temporarily linked to our Google Analytics data to define and create audiences for cross-device ad promotion.
You can permanently opt out of cross-device remarketing/targeting by turning off personalized advertising in your Google Account. To do so, follow this link: https://adssettings.google.com/authenticated?hl .
For more information, as well as the provisions regarding data privacy, please see the Google Privacy Policy at https://policies.google.com/technologies/ads?hl .
8. Contact form
We provide you with a contact form which you can use to ask us questions by entering your name and your email address. The use of the contact form is voluntary, and your data is processed in order to fulfill our contractual service obligations (Article 6 (1) (b) GDPR).
9. LINKS TO OTHER WEBSITES AND ONLINE OFFERS
Our website may contain links to the websites and online offers of other providers not affiliated with us. If you use these links, we naturally no longer have any influence on which data is collected by the respective providers and which data is collected by them. Detailed information on data collection and use can be found in the data protection declaration of the respective provider. As the collection and processing of data by third parties is beyond our control, we cannot assume any responsibility for this.
10. DISCLOSURE OF DATA
A passing on of the data raised by us occurs in principle only if:
you have given your express consent in accordance with Art. 6 Para. 1 S. 1 lit. a DSGVO (e.g. within the framework of the TruVenturo talent pool), the disclosure pursuant to Art. 6 para. 1 sentence 1 lit. f DSGVO is necessary for the assertion, exercise or defence of legal claims and there is no reason to believe that there is an overriding legitimate interest in not disclosing the data, we are legally obliged to pass on data pursuant to Art. 6 para. 1 sentence 1 lit. c DSGVO, or this is legally permissible and required pursuant to Art. 6 para. 1 sentence 1 lit. b DSGVO for the execution of contractual relationships with you or for the implementation of pre-contractual measures which are taken at your request. Some 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 declaration, this may include in particular computer centres that store our website and databases, IT service providers that maintain our systems and consulting companies. If we pass on data to our service providers, they may only use the data to fulfil their tasks. The service providers have been carefully selected and commissioned by us. They are contractually bound to our instructions, have suitable technical and organisational measures at their disposal to protect the rights of the persons concerned, guarantee an appropriate level of data protection and are carefully monitored by us. In addition, the data may be passed on in connection with official enquiries, court orders and court proceedings, if this is necessary for legal prosecution or enforcement.
11. YOUR RIGHTS
You have the right to request information about the processing of your personal data by us at any time. We will explain the data processing to you in the context of the provision of information and provide you with an overview of the data stored about your person. 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 request that your data be deleted. Should deletion not be possible in exceptional cases due to other legal provisions, the data will be blocked so that it is only available for this legal purpose. You can also have the processing of your data restricted, e.g. if you are of the opinion that the data stored by us is not correct. You also have the right to data transfer, i.e. we can send you a digital copy of the personal data you have provided on request. In order to exercise the rights described here, you can contact us at any time using the contact details listed in section 1 above. This also applies if you wish to receive copies of guarantees proving an adequate level of data protection. In addition, you have the right to object to data processing based on Art. 6 para. 1 sentence 1 lit. e or f DSGVO or used for direct advertising. Finally, you have the right to complain to the data protection supervisory authority responsible for us.
12. RIGHT OF REVOCATION AND OBJECTION
In accordance with Article 7 (2) of the DSGVO, you have the right to revoke your consent to us at any time. The consequence of this is that we will no longer continue the data processing based on this consent in the future. The revocation of the consent does not affect the legality of the processing carried out on the basis of the consent up to the revocation.
