Website project-a.com, last amended: May 2018
1. Contact person
The website www.project-a.com is provided by Project A Services GmbH & Co. KG, Julie-Wolfthorn-Straße 1, 10115 Berlin (hereinafter referred to as “Project A” or “we”). Project A is also the controller within the meaning of the EU General Data Protection Regulation (GDPR) for the collection, processing and use of personal data of website visitors (hereinafter referred to as “you”). Should you have any questions or suggestions regarding data protection, 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 firstname.lastname@example.org. Our full contact details are available here.
2. Data processing when you use our website
2.1 Visiting the site. In principal, it is possible to visit our website without providing personal data. Personal data is only collected if this is necessary for technical reasons to use our website or if you use certain functions or services offered on our website, e.g. the application form.
The following access data are automatically recorded every time our website is accessed:
date and time of access
name of the file requested
website from which the file was requested
access status (e.g. file transferred, file not found)
your web browser and your device’s operating system
the IP address of the requesting device
It is necessary to process this data to make it possible to visit the website and to guarantee the long-term functionality, availability and security of our systems. The legal basis for this data processing is Art. 6(1) Sentence 1(b) GDPR.
For the purposes described above, the access data specified is also temporarily stored in internal log files in order to generate statistical data on the use of our website, to further develop our website with regard to the usage habits of our visitors (e.g. if the proportion of mobile devices with which the pages are accessed increases) and for the general administrative maintenance of our website. The legal basis for this data processing is Art. 6(1) Sentence 1(f) GDPR, based on our legitimate interest in appropriately optimising our website.
The information stored in the log files does not allow any conclusions about your person and we only store IP addresses in the log files in shortened, anonymised form.
2.2. Applying to Project A. You have the possibility to use our online application form. Please note the separate privacy notice for the Project A application system.
2.3 Recommending friends. In certain cases, we pay a bonus for successful recommendations that result in someone being employed at Project A or one of the ventures in our portfolio. Please visit our careers page to find out which vacancies are currently offering a bonus. When someone recommends another person, this generates a recommendation code which can be used later on to identify whether the recommendation was successful. This recommendation code will therefore be stored together with the data of the recommended applicant. The recommendation system and bonus payments are handled entirely by the Aklamio service (aklamio GmbH, Hagelberger Str. 11, 10965 Berlin). Please note its privacy notice.
Of course, no content from the application process will be passed on to the person from whom the recommendation originates. We store the recommendation code for a period of 12 months in order to be able to verify a successful recommendation during this period. The legal basis of the processing of data for our friend recommendation scheme is Art. 6(1) Sentence 1(b) GDPR. Where information on the payment of a bonus has to be retained for accounting reasons, it will be retained for a period of six years. The legal basis for this retention is Art. 6(1)(c) GDPR in conjunction with Section 257 of the German Commercial Code (HGB) and Section 147 of the Fiscal Code (AO).
2.4 Project A newsletter and job alerts. You have the opportunity to subscribe to our Project A newsletter, which informs you quarterly about news from Project A and our ventures, new investments, milestones and events, and you can register for our job alert, which keeps you regularly updated about new job vacancies at Project A and the ventures in our portfolio.
When registering for the Project A newsletter and the job alert, we ask you to provide your email address so that we can send you the respective newsletter. In addition, you have the opportunity to tell us your name.
We use the so-called double opt-in procedure, which means that we will only send you information by email if you click on a link in our notification email to confirm that you are the owner of the email address provided. If you confirm your email address, we will store your email address, the time of registration and the IP address assigned to you when registering until you unsubscribe from the newsletter. The sole purpose of storing this information is to send you the newsletters and to be able to prove that you registered. You can unsubscribe from the newsletter at any time. A corresponding unsubscribe link can be found in every email. It is of course also sufficient if you notify us using the contact details provided above or in each email (e.g. by email or letter). The legal basis of the data processing in connection with registering for the Project A newsletter and the job alert is your consent pursuant to Art. 6(1) Sentence 1(a) GDPR.
We use the US provider “MailChimp” for sending and managing our newsletters. MailChimp is provided by The Rocket Science Group, LLC, 512 Means Street, Suite 404 Atlanta, GA 30318 (“MailChimp”). MailChimp offers a well-thought-out and technically convincing software solution and the provider is reliable as a security-conscious and responsible company. It is certified under the EU-US Privacy Shield and is thus committed to complying with European data protection regulations. With regard to the data protection regulations applicable in the USA, which deviate from European requirements, we have concluded an additional agreement with the provider which ensures that the data of our users will only be processed on our behalf and, in particular, will not be passed on to third parties. We will transmit the data concerning your registration for the newsletter to MailChimp, which will store it for as long as you remain registered for the newsletter.
In our newsletters we use market-standard technologies to allow us to measure interactions with the email (e.g. opening of the email, which links are clicked on). We use this data for general statistical evaluations as well as to optimise and further develop our content and customer communication. This is done with the help of small graphics (pixels) embedded in the emails. The data is collected in pseudonymous form only and not linked to your other personal data. The legal basis for this is our aforementioned legitimate interest pursuant to Art. 6(1) Sentence 1(f) GDPR. With our newsletters, our aim is to share content that is as relevant as possible for our users and to better understand what the readers are actually interested in. If you do not want your usage behaviour to be analysed in this way, you can unsubscribe from the newsletter at any time or disable the display of graphics in your email client by default. The data about how you interact with our newsletters is stored in pseudonymous form for 30 days before being completely anonymised.
2.5 YouTube. We have embedded videos on our website that are stored on YouTube and can be played directly on our website. YouTube is a service provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). When you visit subpages on which YouTube videos are embedded, Google receives the information that you have retrieved the corresponding subpage of our website. This happens regardless of whether you are logged in to Google or a YouTube account or not. If you are logged in, the information that you played the video will be directly assigned to your Google and YouTube accounts. If you do not want this to happen, you will need to log out before playing the video. Google stores your data and may use it for purposes of advertising, market research and the demand-oriented design of its own websites. Such an evaluation even occurs for users who are not logged in. You can configure your browser to refuse the storage of cookies as described above, or you can prevent the recording of data generated by cookies and relating to your use of this website and the processing of this data by Google by disabling the “Ads Personalisation” button in Google’s Ads Settings. In this case, Google will then also only display general advertising in connection with YouTube, which has not been selected based on information collected about you.
Insofar as Google also processes your data in the USA, Google offers safeguards in the form of certification under the EU-US Privacy Shield to ensure its compliance with the European data protection principles. The legal basis for integrating YouTube and the associated data processing is Art. 6(1) Sentence 1(f) GDPR, based on our legitimate interest in integrating video and visual content to make our website more attractive.
2.6 Google Maps. On our website we use Google Maps to visually display the address of our premises. Google Maps is a map service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). In order for the Google map information we use to be integrated and displayed in your browser, when you visit our website your browser must connect to a Google server, which may also be located in the USA. In the event that personal data is transferred to the USA, Google has subjected itself to the EU-US Privacy Shield. When the page is visited, Google receives the information that our website has been accessed from the IP address of your device. The legal basis for this data processing is Art. 6(1) Sentence 1(f) GDPR, based on our legitimate interest in integrating a map service when designing our website.
3. 3. Cookies and usage analysis
The primary purpose of our own cookies is rather to make using our service as time-saving and user-friendly as possible.
for load balancing;
to store language settings;
to store form data; and
to note that information placed on our website has been displayed to you, so that it will not be displayed again the next time you visit the website.
We do this to be able to make your use of our website more convenient and personalised. The processing of the respective cookies is based on our aforementioned legitimate interests, meaning the legal basis is Art. 6(1) Sentence 1(f) GDPR.
You can prevent the storage of cookies by adjusting your browser settings to disable the acceptance of cookies via this website. If you do not accept cookies, however, this may in some cases lead to considerable functional restrictions on our website.
The processing of usage data for Google Analytics purposes is based on our legitimate interest in the demand-oriented design and optimisation of our website, and the legal basis in this respect is Art. 6(1) Sentence 1(f) GDPR. You may object to these web analytics activities by Google at any time. There are several ways to do this:
You can configure your browser to block cookies from Google Analytics.
You can adjust your advertising settings on Google
In the browsers Firefox, Internet Explorer and Chrome, you can install the deactivation plug-in provided by Google using the following link (this option does not work on mobile devices): Browser plug-in link
c. Facebook conversion and retargeting tags. For marketing purposes our website uses what are known as conversion and retargeting tags (also called Facebook Pixels) from the social network Facebook, a service of Facebook, Inc., 1601 Willow Road, Menlo Park, California 94025, USA (“Facebook”). We use Facebook Pixels to analyse the general use of our website and to track the effectiveness of Facebook advertising (“conversion”). We may also use Facebook Pixels to show you individualised advertising messages based on your interest in our website and our services (“retargeting”). For this purpose, Facebook processes data that the service collects via cookies and similar technologies on our website. Facebook may transfer the data generated in this context to a server in the USA for evaluation and store it there. In exceptional cases where this involves transferring personal data to the USA, Facebook has also subjected itself to the EU-US Privacy Shield. Facebook has thus committed itself to ensuring the European data protection principles and level of data protection even in the context of data processing performed in the USA.
If you are member of Facebook and have given Facebook the relevant permission in your account’s privacy settings, Facebook may also link the information recorded about your visit to us to your member account and use it to deploy targeted Facebook ads. You can view and change the privacy settings of your Facebook profile at any time. If you are not a member of Facebook, you can prevent Facebook from processing your data by clicking on the deactivation button for the provider “Facebook” on the external TrustArc opt-out website. You can also prevent the data processing by writing a note to email@example.com.
If you disable data processing by Facebook, Facebook will only display general Facebook ads that are not selected based on information recorded about you.
Please refer to Please refer to Facebook’s data policy for further details.
d. Twitter Ads. On our website we use services of the short message service Twitter, Twitter International Company, One Cumberland Place, Fenian Street Dublin 2, D02 AX07 Ireland (“Twitter”). Twitter enables us to use visitor interaction pixels to deploy target group-based advertising, retargeting and conversion measurements for online advertising. This involves deploying offers for certain target groups based on a selection of general criteria, e.g. demographic characteristics, regions or interests. Twitter also allows us to display targeted ads based on a user’s previous page views. For example, ads about our services can be shown to the respective user if that user has previously been interested in certain information or offers on our website. Twitter is certified under the EU-US Privacy Shield and is thus committed to complying with European data protection regulations.
You can prevent this data processing by disabling the storage of cookies in your browser by adjusting the settings as described above. If you are a Twitter user, you can also prevent the aforementioned data processing in your Twitter account by adjusting the “Personalized ads” setting in the “Personalization and Data” area. On mobile devices, the aforementioned data processing can also be prevented using the system settings “Limit Ad Tracking” (iOS) or “Interest-based ads” (Android). For further information, please refer to the Twitter website.
e. LinkedIn conversion tracking. We use the LinkedIn conversion tracking retargeting tool, provided by LinkedIn Ireland, Wilton Plaza, Wilton Place, Dublin 2, Ireland (“LinkedIn”). For this purpose, the LinkedIn Insight Tag is integrated into our website, which enables LinkedIn to collect pseudonymous data about your visit and the use of our website and to provide us with corresponding aggregated statistics on this basis. In addition, this information is used to show you interest-based and relevant offers and recommendations after you have shown an interest in certain information and e.g. job vacancies on our website. This information is assigned via a cookie. You can prevent the storage of cookies by adjusting your browser settings. Alternatively, you can object to this form of data processing by using the following link to place an opt-out cookie, which will remain on your device until you delete the cookie. This option is available to both LinkedIn members and non-members: Information about LinkedIn conversion tracking.
4. 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.
5. Features from social networks
Plug-ins from various social networks are not integrated into our website, but only links are implemented to various social networks that can be recognised by the logos of the individual providers.
6. Disclosure of data
In principal, 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 Project A talent pool);
disclosure is necessary pursuant to Art. 6(1) Sentence 1(f) GDPR in order to assert, exercise or defend legal claims and there is no reason to assume that there is an overriding legitimate interest in not disclosing the data;
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.
In addition, data may be disclosed in connection with official requests, court orders and legal proceedings if this is necessary to pursue or enforce rights.
7. 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 Berlin is: Berlin Commissioner for Data Protection and Freedom of Information, Friedrichstr. 219, 10969 Berlin.
Right of withdrawal and objection
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.
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.