Talentese Privacy Policy

 

Effective as of: 01.06.2020

 

The Talentese team thanks you for the interest shown in our enterprise. Your data is your explicit right, and we value the privacy of your personal information. The use of the Internet pages of Talentese GmbH is possible without any indication of data; however, in cases in which a Data Subject wants to use certain services rendered by Talentese GmbH, some personal data may be necessary.

This document will inform you about: (a) our practices when processing your personal data, (b) our compliance in relation to privacy statutes, and (c) your specific rights as a data subject.

This document shall apply in cases in which Talentese GmbH is a controller of the data. We have implemented numerous technical and organizational measures to ensure the best possible protection of personal data that are processed on the Talentese website. Because no method is 100% secure, you may provide your personal data to us in person, by post, or by telephone number. Processing of this data will occur in the same manner as included herein.

 

  1. ABOUT US

We are Talentese GmbH, located at Kurfürstendamm 179, 10707 Berlin, Germany. You may contact us by e-mail on info[at]talentese.com, by phone on +49(0)15159837243, or directly on our website at: talentese.com. Our full details will be available at the Contact section on our website.

We work as a facilitator between talented young individuals we call Talents and exciting employers called Companies. We use some personal data in relation to specific Talents and certain controllers of Companies to match these two groups together through our software channels.

This Privacy Policy will inform you on (a) our personal data processing practices, (b) our compliance obligations from applicable privacy statutes and (c) your specific rights as a data subject.

For the purposes of this Privacy Policy, a Data Subject is a natural person that is the owner of certain Personal Data. Personal data means any data that may identify the Data Subject. For the purposes of this Privacy Policy, processing may mean any set of operations with the Data Subject’s Personal Data based on some of the legal grounds we set forth below.

At the end of this Privacy Policy, you will find a list of all third-party services with whom we may share some Personal Data, while providing services to you.

 

  1. COLLECTION OF DATA

Talentese collects certain personal data when a data subject or automated system interacts with the Website. The Data is stored in server log files. Collection of data may occur in several manners:

      • Collection of Data directly from you (for example: in cases when you are asked to fill out certain forms that may include information about your name, e-mail address, telephone number, date of birth, address or country of residence, profile picture or other personally-identifiable data).
      • Maintaining your Talent or Company profile, available to certain groups of users (Talent or Company Accounts) on our website.
      • Collection of Data that comes from your device used to access Talentese (device type, type of browser, resolution or aspect ratio of your display, or location, if such is enabled)
      • Collection of Data that comes from third-party services (for example, if you wish to create a profile via a third-party social media service like Facebook or LinkedIn, with your prior consent, in order to fill out your User Profile with available data from your respective social media profile, or, in cases in which you consent to cookie use for analytics purposes)
      • Collection of Data from correspondence with Talentese (for example, in cases when you ask our customer support service to resolve an issue of concern to you)
      • Collection of some Data from your requests made from your User Account (in cases in which you provide us with some information to process your request)
      • Collection of Data from publication (for example, in cases in which you have filled up certain information made public from your User Profile or in cases in which you have posted certain data for publication on Talentese)
      • Collection of Data from your User Profile (for example, in cases in which we analyze published data from your User Profile to improve your chances of getting Connected to Companies)
      • Collection of Contract-related data from Companies (in instances in which you agree to be Recruited from a Company using Talentese)

We collect the aforementioned data to:

        • Maintain and update your Talent or Company Account
        • To provide you with the services rendered by Talentese, match your preferences to a potential Recruiting Company, or to display you with potential Recruiters
        • To provide you with customer service in cases in which you might be in need of our assistance
        • To collect our due compensation from the Companies in cases in which a Talent has been successfully Recruited with our help
        • To improve our UI/UX, design elements and optimize the work of our website, and to determine focal points that will improve the Talentese Website

Please do not provide us with information about third parties, unless expressly authorized to do so. We may delete this information upon objection of the party, whose data has been shared without a prior authorization. 

 

  1. USAGE OF DATA

We process your data in cases in which it is necessary to provide service(s) of Talentese to you. This includes maintenance of your User Account, providing you with potential Recruitment matches based on your expectations or preferences, and provide you with newsletters and notifications that you have agreed to receive via e-mail. You may opt-out of any e-mail marketing notifications from us at any time. From the moment of opting out, we will contact you only in relation to User Account activity.

We further process the following type of data:

      • Device data (for us to optimize your user experience on Talentese Website. This data is gathered through cookies that let us know about your device’s resolution and aspect ratio, in order for us to provide you with an optimized version of our website that will work best with the device from which you are accessing our Website)
      • Third-party service data (in cases in which you authorized us to do so, for example third-party social networks. In that case, based on your authorization, we will automatically fill up your User Profile compulsory data. When you sign up to a third-party social network to Talentese, we may require some further compulsory information from you in order to create your User Profile.)
      • User Sign-up Application data (in cases in which you opt to sign-up to Talentese for a special User Account. The processing will be carried our electronically, except when controlled manually by us in order to determine your expectations from Talentese)
      • Correspondence data (in cases in which you have requested our customer service to provide you with support. In case you contact us via e-mail or a contact form, the personal data transmitted to us will be automatically stored. You hereby authorize us to process this data. We do not transfer this data to third parties for any purposes whatsoever)
      • Publication data (from your active Talent Account or from Blog or Comment sections available on Talentese). You may choose to remove certain non-compulsory information from your Talent account, or delete the Blog post or Comment section at any time. This information will be immediately deleted from our servers.
      • Notification data (in cases in which you have confirmed your opt-in to a certain subscription to a Blog or Comment section available on Talentese. You may opt-out from the Blog or Comment section notifications at any time. It’s further possible to unsubscribe from a Blog or Comment directly from your User Account on Talentese)
      • Newsletter notification data (in cases in which you have confirmed your opt-in to subscribe to our newsletters. You may opt-out from the Newsletter at any time by following the “Unsubscribe” options available in every Newsletter e-mail. You will be removed from our mailing list and will not receive further Newsletters. It’s further possible to unsubscribe from our newsletter directly from your User Account on Talentese)

The data we process from you will be based on:

  • Your valid consent for a specific processing purpose as explained above
  • Performance of our contract or pre-contractual measures with you, which can be found here: https://www.talentese.com/terms/
  • Performance of pre-contractual measures as prior contact of our customer support service at info[at]talentese.com
  • In cases in which certain data may be necessary to be processed to protect the vital interest(s) of the Data Subject or another natural person.
  • In cases in which our processing would be necessary for the purposes of pursuing the legitimate interests of Talentese, in cases in which consent has not been provided by you. Our legitimate interest is to carry out business in favor of the well-being of our employees and shareholders. Our further legitimate interest is improving of the performance of Talentese for its User base. Our legitimate interest is also reasonable protection of any User using the Talentese platform to Recruit Talents, or get Recruited from an appropriate Company.

 

  1. NECESSARY DATA

Some personal data may be required by law (for example: tax regulations) or result from contractual provisions (for example: information on a specific Talent or Company). Sometimes a data subject may conclude a contract with a natural person and provide it to Talentese with your consent to usage terms found here: https://www.talentese.com/terms/. In that case, we will collect and process data in relation to a Talent’s recruitment. Some of this data is necessary to conclude and perform our contractual obligations with you. Therefore, failure to provide certain necessary data (either marked as compulsory when signing up for a Talentese User Account, or derived from your notification obligations from the Talentese Terms of Service), may result in the impossibility for us to conclude this agreement under the set terms. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

 

  1. STORAGE OF DATA

We store data on our servers for the period necessary to fulfill our contractual obligations with you. The retention period shall not exceed 24 months as of the date of retention. After the expiration of that period, the data is routinely deleted; so long they are not necessary for fulfilling our contractual obligation with Talents or Companies. Data retained for the purpose of maintaining our contract with you (for example: maintenance of your User profile) will be retained until termination of your contract with us.

 

  1. NEWSLETTER TRACKING

Newsletters contain so-called tracking pixels. These are graphics embedded in e-mails that are sent in an HTML format. They enable us to have recording and analysis of log files, which allows us to have a statistical analysis of the success or failure of online marketing campaigns, namely to track if users have followed an embedded link directly from the newsletter sent to them. This personal data is used for analytics purposes only and shall not be shared with third-parties. You may opt-out from newsletter tracking at any time. Talentese shall immediately delete all stored data from its servers.

 

  1. COOKIE POLICY

Cookies are small pieces of data that are stored on your static or mobile device’s website browser, or that may be stored locally on your device when you visit our Website. A cookie file contains an identifier, which is a string of letters and numbers that are sent back each time a browser requests a page from the server. Cookies are divided into session cookies (which expire at the end of the user session – i.e. at the time of closure of your device’s website browser), or persistent cookies (which expire at their designated expiry date, unless deleted prior to such date). Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

We may use cookies in order to authenticate you, determine if you are logged into our website, maintain the state of your shopping cart as you navigate through Talentese, personalize your user experience when logged in our Talentese, to help us display relevant advertisements to you, analyze certain behaviors on our website, store your preferences in relations to the use of cookies, and finally use cookies as an element of security, in order to protect your user account from misuse.

You can manage your cookie preferences manually, or by sending us a request on our customer Support e-mail. Most browsers that are used by Users allow for User to refuse or accept cookie usage, or to delete the cookies from the browser memory.

When blocking cookies from your device’s Website browser, or deleting clearing your cookies from your device may limit certain services that we provide – for example: if you delete or block the usage of your authentication cookies, you may have to sign in to your User Account manually every time you visit our Website.

 

  1. LICENSE TERMS AND USER SUBMISSIONS

Some features on Talentese, such as inclusion of your own Bio, description, working with our Blog or Comment threads, sharing of ratings and reviews, editing your User Profile, including a User Profile Picture, including an online Resume etc. may be shared with users having access to the Talentese platform upon publishing. All text, photos, videos, multimedia files, ratings and comments will be treated as “User Submissions”. You retain all your ownership and proprietary rights to the User Submission, but grant us a license to use, copy, reproduce, process, adapt modify, create derivative works from, publish, transit, display and distribute this content to the reasonable audience based on your publication options. This license is given until this information is manually removed by you.

Please note that some User Submissions may have differing potential audiences. For example, your User Profile may be accessed by anyone that is a User on Talentese. Some comments or reviews may be accessed by anyone that uses a web browser and has access to the internet. 

In principal, we do not pre-authorize User Submissions before publishing. For your own safety, we advise to not share personal data on Talentese Comment or Blog threads that may be accessible to Talentese Users or the general public.  Upon request, we will take down this submission. Also note that the Terms of Service apply in cases of User Submissions breaching the User Conduct rules, available here: https://www.talentese.com/terms/. We reserve the right to delete or remove any submission that may be in breach of our Terms of Service, User Conduct rules, or generally accepted standards of internet behaviour, at sole discretion.

 

  1. YOUR OPTIONS

In addition to your legal rights from applicable law provisions, you may manually choose to limit the collection or use of your personal data. This section will guide you through some practices you can employ in cases you want to manage your Personal data online. When filling out your User Profile that is meant to be shared with the general public some details in your User Profile may not be compulsory. This means you may opt to not fill them.  At any time, you may choose to opt out of any Marketing Messages that are sent to you by clicking the “Unsubscribe” button on any Marketing Message sent to your e-mail. Please note that in some instances, we might send you a message requesting you to confirm your opt-out from direct Marketing and Advertising.

You may manually select and limit any usage of Cookies. For more information on opting out from cookies, please see Section 7 of this Privacy Policy.

You may manually opt out from targeted advertising and analytics platforms, such as Google AdWords, Google AdSense or Google Analytics, by using the following links: https://tools.google.com/dlpage/gaoptout; https://adssettings.google.com/authenticated. If you are opting out from your mobile device, please see your individual mobile device model’s instruction on certain opt-outs. If you want to stop sharing any analytics or diagnosis data from your mobile device, please change your mobile device’s privacy settings.

If you want to restrict our access to your location information, you may choose to deny access to your location on your browser on your static computer device, or turn of location services on your mobile device(s)

You may opt to close your account at any time, at which time all data will be deleted from our Servers under our data retention and processing rules. Please note that some data may be further stored until gradually deleted under the maximal retention time and exceptions thereof.

 

  1. YOUR RIGHTS

Right to information – You have the right to check our legal bases for processing any of the aforementioned data and get acquainted with our Privacy Practices at any time by contacting our Customer Support e-mail info[at]talentese.com. For your convenience, we have prepared a concise list of our third party services in section 12 of this Privacy Policy.

Right to Access – You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information (which includes details of the purpose of processing, categories of personal data concerned and the recipients of the personal data). Where there is no legal constraint, we will supply to you a copy of your personal data. The first copy will be provided free of charge, with the additional copies being subject to a reasonable fee.

Right to Rectification- You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

Right to Erasure – In certain cases, you have the right to erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

Right of Processing Restriction – In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

Right to Object Processing – You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Right to Data Portability – To the extent that the legal basis for our processing of your Data is: – consent; – necessary for the performance of a contract to which you are the party, or to take steps at your request prior to entering into contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format, provided that there are no legal restrictions as foreseen by privacy regulations.

Right to a Complaint to a Supervisory Authority – If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

Right to Withdraw Consent at any Time – In cases in which the legal basis for our processing of your Data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

 

  1. THIRD-PARTY SERVICES WE USE

Below is a list of Third-Party services that may act as integrated parts of Talentese. In the list you may find:

      • Social networks (places for social meetings on the Internet, doubling as online communities allowing for communication between individual Users)
      • Advertising platforms and Analytics platforms (Advertisement services are used to generate and display advertisements to specific Website users, Web analytics is the process of collection, gathering, and analysis of data about the behavior of visitors to websites)
      • Optimization tools (tools that help us optimize displaying certain content on our Website)

The Third-Party services are as follows: 

11.1.    LinkedIn (Linkedin.com)

Company name: LinkedIn, Inc.

Place of business: U.S.

Type: Social Network

Legal Basis:             

          • Your Consent: when we use certain contact information from your LinkedIn User Account when signing up for your Talentese User Account
          • Legitimate Interest: to improve your user experience on Talentese and provide you with a Social Widget provided by LinkedIn on Talentese
          • Privacy notice: LinkedIn Privacy Policy, available at: linkedin.com/legal/privacy-policy 

11.2     Facebook (Facebook.com)

Company name: Facebook, Inc. – processor for U.S. Residents. Facebook Ireland Ltd. – processor for EU/EEA Residents

Place of business: U.S.

Type: Social Network

Legal Basis:             

          • Your Consent: when we use certain contact information from your Facebook User Account when signing up for your Talentese User Account
          • Legitimate Interest: to improve your user experience on Talentese and provide you with a Social Widget provided by Facebook on Talentese
          • Privacy notice: Facebook Privacy Policy, available at: facebook.com/legal/FB_Work_Privacy

11.3     Instagram (Instagram.com)

Company name: Facebook, Inc. – processor for U.S. Residents. Facebook Ireland Ltd. – processor for EU/EEA Residents

Place of business: U.S.

Type: Social Network

Legal Basis:             

        • Your Consent: when we use certain contact information from your Instagram User Account when signing up for your Talentese User Account
        • Legitimate Interest: to improve your user experience on Talentese and provide you with a Social Widget provided by Instagram on Talentese
        • Privacy notice: Instagram Data Policy, available at: https://help.instagram.com/519522125107875

11.4.    Twitter (Twitter.com)

Company name: Twitter, Inc.

Place of business: U.S.

Type: Social Network

Legal Basis:             

        • Your Consent: when we use certain contact information from your Twitter User Account when signing up for your Talentese User Account
        • Legitimate Interest: to improve your user experience on Talentese and provide you with a Social Widget provided by Twitter on Talentese
        • Privacy notice: Twitter Privacy Policy, available at: https://twitter.com/en/privacy

11.5.    Google AdSense (Google.com)

Company name: Alphabet, Inc.

Place of business: U.S.

Type: Analytics and Optimization Tool

Legal Basis:             

        • Legitimate Interest: to improve your user experience and integrate advertisements on Talentese. The Service works by placing cookies on user’s devices for analytic purposes. Opt-out from this type of targeted advertisement is possible as described in section 9 directly from your device, or by following the opt-out link below.
        • Privacy notice: Google Privacy Policy, available at: https://www.google.com/intl/en/adsense/start/
        • Opt-out link: https://tools.google.com/dlpage/gaoptout

11.6.    Google Analytics (Google.com)

Company name: Alphabet, Inc.

Place of business: U.S.

Type: Analytics and Optimization Tool

Legal Basis:             

        • Legitimate Interest: collection, gathering and analysis of data about the behavior of Users of Talentese for our own UI/UX improvement. When working with EU/EEA Residents, such data is gathered in anonymised form. Opt-out or cookie blockage directly from your device possible as explained in Section 9, or by following the provided opt-out link below.
        • Privacy notice: Google Privacy Policy, available at: https://www.google.com/intl/en/adsense/start/
        • Opt-out link: https://adssettings.google.com/authenticated

11.7.    Google AdWords and Google Remarketing (Google.com)

Company name: Alphabet, Inc.

Place of business: U.S.

Type: Analytics and Optimization Tool

Legal Basis:             

        • Legitimate Interest: AdWords creates user-based advertising and thus shows relevant advertisements to interested Internet users. Google Remarketing is a feature of Google AdWords that creates user-based advertising and thus shows relevant advertisements to interested internet users. Opting out or blocking Google AdWords cookies will automatically block Google Remarketing. Opt-out or cookie blockage directly from your browser possible as explained in Section 9, or by following the opt-out link below.
        • Privacy notice: Google Privacy Policy, available at: https://www.google.com/intl/en/policies/privacy/
        • Opt-out link: https://adssettings.google.com/authenticated

11.8.    YouTube (Youtube.com)

Company name: Alphabet, Inc.

Place of business: U.S.

Type: Social Network

Legal Basis:             

11.9.    Pinterest (Pinterest.com)

Company name: Pinterest, Inc.

Place of business: U.S.

Type: Social Network

Legal Basis:             

11.10. PayPal (Paypal.com)

Company name: PayPal (Europe)

Place of business: Luxembourg

Type: Payment Processor

Legal Basis:             

        • Performance of Contract: Processing of information that is usually the User’s first name, last name, address, e-mail, IP address, telephone number, mobile number, or other required data necessary for payment processing. Processing of purchases done by PayPal for the purposes of performance of contract between Talentese and Company User Profiles.
        • Privacy notice: PayPal Privacy Policy, available at: https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

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