I. Name and address of the person responsible
The person responsible within the meaning of the Basic Data Protection Regulation and other national data protection laws of the member states as well as other provisions of data protection law is the Data Protection Officer:
KI growth GmbH
80331 Munich, Germany
II. General information on data processing
We process the personal data of our users only to the extent necessary to provide a functioning website as well as our content and services. The processing of personal data of our users takes place regularly only with the consent of the user. An exception applies in those cases in which it is not possible to obtain prior consent for actual reasons and the processing of the data is permitted by statutory provisions.
Insofar as we obtain the consent of the data subject for processing personal data, Art. 6 Para. 1 lit. a EU Data Protection Basic Regulation (DSGVO) serves as the legal basis.
Art. 6 para. 1 lit. b DSGVO serves as the legal basis for the processing of personal data required for the performance of a contract to which the data subject is a party. This also applies to processing operations that are necessary for the implementation of pre-contractual measures.
Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c DSGVO serves as the legal basis.
Art. 6 para. 1 lit. d DSGVO serves as a legal basis in the event that vital interests of the data subject or another natural person necessitate the processing of personal data.
If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and fundamental freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f DSGVO serves as the legal basis for the processing.
The personal data of the person concerned will be deleted or blocked as soon as the purpose of storage no longer applies. In addition, the data may be stored if the European or national legislator has provided for this in Union regulations, laws or other provisions to which the person responsible is subject. The data shall also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless it is necessary for further storage of the data for the conclusion or performance of a contract.
III. Provision of the website and creation of log files
Each time you access our website, our system automatically collects data and information from the computer system of the accessing computer.
The following data is collected:
The data is also stored in the log files of our system. These data are not stored together with other personal data of the user.
The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f DSGVO.
The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the IP address of the user must remain stored for the duration of the session.
The data is stored in log files to ensure the functionality of the website. The data is also used to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
These purposes also include our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f DSGVO.
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of the collection of data to provide the website, this is the case when the session in question has ended.
If the data is stored in log files, this is the case after seven days at the latest. A storage going beyond this is possible. In this case the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.
The collection of data for the provision of the website and the storage of data in log files is mandatory for the operation of the website. Consequently, there is no possibility for the user to object.
We also use the analysis software tools described below on our website, which set cookies to enable an analysis of the surfing behaviour of users.
– Facebook Plugins
So-called social plug-ins (“plug-ins”) of the social network Facebook, which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (hereinafter “Facebook”), are used on our website. The plugins are marked with a Facebook logo or the addition “Social Plug-in from Facebook” or “Facebook Social Plugin”. You can find an overview of the Facebook plug-ins and their appearance here: https://developers.facebook.com/docs/plugins
If you call up a page of our website that contains such a plugin, your browser establishes a direct connection to the Facebook servers. The content of the plugin is transmitted directly from Facebook to your browser and integrated into the page. Through this integration, Facebook receives the information that your browser has called up the corresponding page of our website, even if you do not have a Facebook profile or are not logged on to Facebook. This information (including your IP address) is transmitted directly from your browser to a Facebook server in the USA and stored there.
If you are logged in to Facebook, Facebook can assign your visit to our website directly to your Facebook profile. If you interact with the plugins, for example by clicking the “Like” button or commenting, this information is also transmitted directly to a Facebook server and stored there. The information is also published on your Facebook profile and displayed to your Facebook friends.
The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as your rights in this regard and setting options to protect your privacy can be found in Facebook’s data protection information: http://www.facebook.com/policy.php
If you do not want Facebook to associate the data collected through our website directly with your Facebook profile, you must log out of Facebook before visiting our website. You can also completely prevent the loading of Facebook plugins with add-ons for your browser.
– Google Analytics
Our website uses Google Analytics, a web analysis service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, United States, hereinafter “Google”). Google processes the data for website use on our behalf and is contractually obligated to take measures to ensure the confidentiality of the processed data.
The following data will be recorded during your visit to our website:
– Google Tag Manager
We use Google Tag Manager, a Google web service to manage website tags. The Google Tag Manager tool itself (which implements the tags) is a cookie-free domain and does not collect personally identifiable information. The tool triggers other tags that may themselves collect information. Google Tag Manager does not access this data. If deactivation has been made at the domain or cookie level, it will persist for all tracking tags implemented with Google Tag Manager. Tags are code snippets integrated into the website, such as tracking codes, which are used by Google Analytics for analysis.
Our website uses Hotjar, an analysis software of Hotjar Ltd. (“Hotjar”) (http://www.hotjar.com, Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta, Europe).
Hotjar’s tracking code collects the following information: Device-dependent data
The following information can be recorded by your device and browser:
The following data is automatically generated by our servers when Hotjar is used:
The cookies that Hotjar uses have a different “lifetime”; some last up to 365 days, some only last during the current visit.
You can prevent Hotjar from collecting this information by clicking the following link and following its instructions: Hotjar Opt-out (https://www.hotjar.com/opt-out)
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f DSGVO.
The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 lit. a DSGVO if the user has given his consent.
The analysis cookies are used for the purpose of improving the quality of our website and its content. The analysis cookies tell us how the website is used and enable us to constantly optimise our services.
With Hotjar it is possible to measure and evaluate the user behaviour (clicks, mouse movements, scroll heights, etc.) on our website. The information generated by the tracking code and cookie about your visit to our website is transmitted to and stored on the Hotjar servers in Ireland. Hotjar will use this information for the purpose of evaluating your use of our website, compiling usage reports and providing other services relating to website usage and internet evaluation of the website. Hotjar also uses third-party services such as Google Analytics and Optimizely to provide services. These third party companies may store information that your browser sends when you visit the website, such as cookies or IP requests. For more information on how Google Analytics and Optimizely store and use data, please refer to their respective privacy statements.
We use Google Analytics to analyze website usage. The resulting data is used to optimise our website and advertising measures.
V. Contact form and e-mail contact
A contact form is available on our website, which can be used for electronic contact. If a user makes use of this possibility, the data entered in the input mask will be transmitted to us and stored. These data are:
At the time the message is sent, the following data will also be stored:
Your consent will be obtained for the processing of the data as part of the sending process and reference will be made to this data protection declaration.
Alternatively, you can contact us via the e-mail address provided. In this case the personal data of the user transmitted with the e-mail will be stored.
The data will not be passed on to third parties in this context. The data will be used exclusively for the processing of the conversation.
The legal basis for the processing of the data is Art. 6 para. 1 lit. a DSGVO if the user has given his consent.
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f DSGVO. If the purpose of the e-mail contact is to conclude a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b DSGVO.
3. Purpose of data processing
The processing of the personal data from the input mask serves us exclusively for the processing of the establishment of contact. If you contact us by e-mail, this is also the necessary legitimate interest in the processing of the data.
The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is terminated when it can be inferred from the circumstances that the relevant facts have been conclusively clarified.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
The user has the possibility to revoke his consent to the processing of personal data at any time by e-mail contact. If the user contacts us by e-mail, he can revoke his consent to the storage of his personal data at any time.
In such a case, the conversation cannot be continued.
In this case, all personal data stored in the course of establishing contact will be deleted.
VI. Rights of the data subject
If personal data is processed by you, you are the data subject within the meaning of the DSGVO and you are entitled to the following rights vis-à-vis the person responsible:
You can request confirmation from the person responsible as to whether personal data relating to you will be processed by us.
In the event of such processing, you may request the following information from the data controller:
You have the right to request information as to whether the personal data concerning you will be transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 DSGVO in connection with the transfer.
You have the right to have your personal data corrected and/or completed by the data controller if the personal data processed concerning you is inaccurate or incomplete. The data controller must carry out the rectification immediately.
Under the following conditions, you may request that the processing of your personal data be restricted:
If the processing of personal data concerning you has been restricted, such data – apart from their storage – may only be processed with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the Union or a Member State.
If the processing restriction has been limited in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
You may request the data controller to delete the personal data concerning you immediately and the data controller is obliged to delete this data immediately if one of the following reasons applies:
The personal data relating to you have been collected in relation to information society services offered pursuant to Art. 8 para. 1 DSGVO.
If the person responsible has made the personal data concerning you public and is obliged to delete them in accordance with Art. 17 (1) DSGVO, he shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform the persons responsible for data processing who process the personal data that you, as the person concerned, have requested them to delete all links to this personal data or copies or replications of this personal data.
The right to deletion does not exist if the processing is necessary.
If you have exercised your right to rectify, cancel or limit the processing of your personal data against the controller, the latter is obliged to notify all recipients to whom the personal data concerning you have been disclosed of such rectification, cancellation or limitation, unless this proves impossible or involves a disproportionate effort.
You have the right to be informed of such recipients by the data controller.
You have the right to receive the personal data concerning you that you have provided to the responsible person in a structured, common and machine-readable format. In addition, you have the right to communicate these data to another data controller without being hindered by the controller to whom the personal data was provided, provided that
In exercising this right, you also have the right to request that the personal data concerning you be transferred directly from one responsible person to another responsible person, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.
The right to data transfer does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data on the basis of Art. 6 para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions.
The person responsible will no longer process the personal data concerning you unless he can prove compelling grounds for processing worthy of protection which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
If the personal data concerning you are processed for the purpose of direct advertising, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling to the extent that it is connected with such direct advertising.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes.
You have the possibility to exercise your right of objection through automated procedures using technical specifications in connection with the use of Information Society services, notwithstanding Directive 2002/58/EC.
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of your consent does not affect the legality of the processing carried out on the basis of your consent until you revoke it.
8. Automated decision in individual cases including profiling
You have the right not to be subject to any decision based solely on automated processing, including profiling, that has any legal effect on you or similarly significantly affects you. This does not apply if the decision
However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 DSGVO, unless Art. 9 para. 2 lit. a or g DSGVO applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.
With regard to the cases referred to in (1) and (3), the person responsible shall take appropriate measures to protect the rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person on the part of the person responsible, to state his own position and to challenge the decision.
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of presumed infringement, if you consider that the processing of your personal data is in breach of the DSGVO.
The supervisory authority with which the complaint was lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 DSGVO.
VII. Data protection for applications and in the application procedure
If you apply to us electronically, i.e. by e-mail or via our web form, we collect and process your personal data for the purpose of processing the application procedure and implementing pre-contractual measures.
For our application administration we use the services of Greenhouse Software Inc., 455 Broadway, New York NY, 10013 USA (“Greenhouse”). For this purpose, your data will be stored and processed on Greenhouse servers in the USA.
By applying on our recruiting page, you express your interest in joining our company. In this context, you provide us with personal data which we use and store exclusively for your job search / application.
In particular, the following data is collected:
You also have the opportunity to upload relevant documents such as a cover letter, your CV and certificates. This may include other personal information such as date of birth, address, etc.
Only authorized employees who are involved in the application process have access to your data.
Personal data is stored exclusively for the purpose of filling the vacancy you have addressed.
Your data will be stored for another 180 days upon completion of the application process. This is usually done to fulfil legal obligations or to ward off claims arising from legal regulations. We are then obliged to delete your data or make it anonymous. In this case, the data is only available to us as so-called metadata without direct personal reference for statistical evaluations (e.g. proportion of applications from women or men, number of applications per period, etc.).
If you receive and accept a job offer from us as part of the application process, we will store the personal data collected during the application process for at least the duration of the employment relationship.