Privacy notice for the Project A application system
Website project-a.com, last amended: July 2022
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 Person
The application system 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 applicants who participate in our online 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 team by sending an email to firstname.lastname@example.org. In addition, you always have the possibility to contact our data protection officer by post at the above address (keyword: "data protection officer"). Also, you can always contact our Talent Team (+49 30 340 606 340 / email@example.com).
2. Data processing in the context of the application process
2.1. Online application form
You can apply to us for advertised vacancies using our online form. The purpose of data collection here is the selection of applicants for potential employment at Project A or one of the ventures in our portfolio. 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 (curriculum vitae and cover letter). You may also voluntarily provide us with additional information that you may want us to consider when you apply (e.g. your salary expectations, availability or additional documents).
We will check your application and contact you if necessary, in particular to make appointments or to clarify any questions.
If you apply for a position at Project A, in principle we will not pass on your applicant data to third parties. If you apply for a position at one of the ventures in our portfolio, we will check the application and forward it to the relevant contact person at the respective company. If you have any questions regarding data protection in the application process (e.g. with regard to your rights under data protection law), please contact us at firstname.lastname@example.org or get in touch with our data protection officer directly at email@example.com. This overview may change at any time but will always show the current portfolio companies whenever it is accessed.
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 (Project A talent pool). The data will be deleted automatically after this period.
2.2. Project A talent pool
Through your application you can become part of our talent pool. The Talent Pool membership requires an additional confirmation from you. Once the application process is complete, we will store the data you submitted for your application in our Project A talent pool for a further 24 months. This will allow us to identify any further jobs at Project A 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 week, we will then send you information about vacant positions at Project A and/or the ventures in our portfolio which may be suitable for you. After this period, the data will be deleted unless you have given a new consent separately. You can withdraw your consent at any time with future effect by emailing us at firstname.lastname@example.org.
We receive applications from partners that provide us with candidates they deem suitable for a position at Project A or one of our portfolio companies. We process this data in the same way as other applicants’ data and store such applications in our talent pool only if you have given your consent. You can withdraw your consent at any time by writing an e-mail to email@example.com.
2.3. Application statistics
We want to measure the effectiveness of our internal recruiting processes and the matching of applicants to the Ventures. For this purpose, we process the information on your application and, if applicable, on the completion of your probationary period in a venture beyond the actual application process. We process this information in pseudonymized form and for statistical purposes only. The statistics also help us to track which channels applicants use to apply. The legal basis for the processing of your applicant data for statistical purposes is Art. 6(1) Sentence 1(f) based on our legitimate interest in appropriately optimizing our application process.
2.4. Data processing by our service provider Greenhouse
We use the external service provider Greenhouse (Greenhouse Software, Inc., 18 West 18th St., 11th Floor, New York, NY 10011 USA) for our application system. We have concluded a data processing agreement with Greenhouse, pursuant to Art. 28 GDPR, to ensure that Greenhouse processes the data in accordance with our instructions and the European data protection principles. If Greenhouse transfers data to companies outside Europe (e.g. to the USA), Greenhouse has taken contractual precautions to ensure compliance with the European data protection principles. However, when personal data is processed outside Europe, it may in individual cases be the case that the rights of EU citizens cannot or cannot fully be enforced. You can revoke consent and withdraw your application at any time.
2.5. Data processing by our service provider Talentwall
We use the external service provider Talentwall (TalentWall, Inc., 5430 S University Ave #2, Chicago, IL 60615 USA) for our application system. We have concluded a data processing agreement with Talentwall, pursuant to Art. 28 GDPR, to ensure that Talentwall processes the data in accordance with our instructions and the European data protection principles. If Talentwall transfers data to companies outside Europe (e.g. to the USA), Talentwall has taken contractual precautions to ensure compliance with the European data protection principles. However, when personal data is processed outside Europe, it may in individual cases be the case that the rights of EU citizens cannot or cannot fully be enforced. You can revoke consent and withdraw your application at any time.
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) lit. a GDPR (e.g. in connection with the Project A talent pool);
disclosure is necessary pursuant to Art. 6(1) lit. 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) lit. c GDPR; or
this is permitted by law and is required under Art. 6(1) lit. b GDPR for the processing of contractual relationships with you or for taking steps at your request prior to entering into a contract. (e.g. as part of the application for a position with a venture).
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.
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 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.