24.05.2018

Data protection is a matter of trust and your trust is important to us and we respect your sphere of privacy. Therefore, the protection and legally compliant collection, processing and use of your personal data is an important concern for us. To ensure your safety and wellbeing when visiting our websites and using our services, we strictly observe all legal regulations concerning data protection when collecting, processing and using your personal information. Furthermore, we would now like to inform you about our data collection and data use.

Index

Responsible body
Collection, processing, and use of personal data
Passing on your personal data to third parties
Data security
Data storage and deletion periods
Rights of data subjects
Cookies and retargeting
Google Analytics
Use of the Google +1 button
Use of social plugins
Amendment of the Data Protection Directive
Contact

1. Responsible body

Within the meaning of the Federal Data Protection Act (BDSG),Team2Venture GmbH (twago), Friedrichstr. 224, 10969 Berlin, is responsible for the collection, processing, and use of your personal data when using the services offered by twago.

2. Collection, processing, and use of personal data

2.1 Personal data and use

Personal data is information about the factual or personal circumstances of a specific or identifiable natural person. twago collects the following categories of data (individuals may also fall into several of these categories).

Service provider

Name, age, gender, email address, telephone number, address, emergency contact, photo, ID data (when using twago safePay), tax numbers, registration number, nationality, residence status, work permit, education, skills, CV, career, payment information (e.g. credit card number, PayPal ID), billing address, other contact information (e.g. Skype ID, LinkedIn ID), user name, password, communication data via the Platform and/or other data provided to us by the Service Provider itself or by Service Recipients as part of execution of the contract (in particular ratings, number of projects and project volumes)

The personal data provided for the creation and completion of the user account and the public profile on twago is based on the concluded user contract and is used exclusively for contract processing. The user himself or herself decides to what extent he wants to provide data for publication. Excluded are the username, password, name, address, email address, telephone number, tax number and payment information, which are absolutely necessary for contract processing (e.g. making contact, invoicing) and therefore must be provided.

Exceptions are also evaluations, number of projects and project volume, which are always collected and are visible in the user's profile. The collection and transmission of this data is based on a legitimate interest of twago within the meaning of Art. 6 para. 1 letter f) GDPR and serves statistical purposes as well as the assessment of the seriousness of users and the prevention of fraud cases.

For using twago safePay, it is also mandatory to provide the I.D. data including photo and address, as the opening of an electronic money account with the service provider MangoPay S.A. requires identification of the account holder to combat money laundering and terrorist financing.

If separate consent has been given, the email address will also be used to inform the user by email about twago or current promotions or participation in surveys for market research purposes or for quality assurance purposes.

Clients or Service Recipients

name, gender, email address, telephone number, address, identification data (when using twago SafePay), tax numbers, registration number, payment information (e.g. credit card number, PayPal ID), billing address, other contact information (e.g. Skype ID, LinkedIn ID, Fieldglass-ID), user name, password, data of communication via the platform and/or other data provided to us by the Service Recipient itself or by Service Providers as part of the execution of the contract (in particular evaluations).

The information of personal data for the creation and completion of the user account and the public project tenders on twago is based on the concluded user contract and is used exclusively for contract processing. The user decides the extent of the data they provide for publication. Excluded are the username, password, name, address, email address, telephone number, tax number, and payment information, which are absolutely necessary for contract processing (e.g. making contact, invoicing) and must be provided.

Exceptions are also evaluations, number of projects and project volume, which are always collected and are visible in the user's profile. The collection and transmission of this data is based on a legitimate interest of twago within the meaning of Art. 6 para. 1 letter f) GDPR and serves statistical purposes as well as the assessment of the seriousness of users and the prevention of fraud cases.

In the case of voluntary use of twago safePay, it is also mandatory to provide the I.D. data including photo and address, as the opening of an electronic money account with the service provider MangoPay S.A. requires identification of the account holder to combat money laundering and terrorist financing.

If separate consent has been given, the email address will also be used to inform the user by email about twago or current promotions or participation in surveys for market research purposes or for quality assurance purposes.

Suppliers

Name, email address, telephone number, address, tax numbers, registration number, payment information (e.g. credit card number, PayPal ID), billing address and/or other contact information (e.g. Skype ID, LinkedIn ID, Fieldglass-ID).

The personal data is provided on the basis of the concluded supplier contract and is used exclusively for contract processing. The user himself decides to what extent he wants to provide data for publication. Excluded are the username, password, name, address, email address, telephone number, tax number, and payment information, which are absolutely necessary for contract processing and must be provided.

Website Visitors

IP address of the requesting computer, date and time of access, name and URL of the file accessed, the website from which accessed, computer operating system, browser used and other technical data, name of the Internet access provider, language settings, and geographical origin.

These data are collected and processed for the purpose of enabling the use of the website (connection establishment), permanently guaranteeing system security and stability, enabling technical administration of the network infrastructure and optimization of the Internet offering (e.g. understanding user needs, personalization) and for internal statistical purposes. The IP address is only evaluated for attacks on twago's network infrastructure and for statistical purposes.

Applicants

Name, age, gender, email address, telephone number, address, photo, nationality, residence status, work permit, education, skills, resume, career, other contact information (e.g. Skype ID, LinkedIn ID), and/or other data provided to us by the applicant himself or herself.

This data is collected and used to process recruitment procedures, for active recruitment measures, to monitor equal opportunities and to assert or defend against legal claims.

3. Passing on of personal data to third parties

Personal data will be passed on to third parties under the following conditions:

Affiliated companies of twago

Data is passed on to companies affiliated with twago within the Randstad Group in accordance with Randstad's worldwide brand and marketing strategy.

The transmission is based on a legitimate interest of twago within the meaning of Art. 6 para. 1 letter f) GDPR and serves the analysis of data traffic, trends and use of the website as well as internal statistical purposes.

Collection companies, Credit agencies, Creditreform

Personal data will only be passed on to debt collection agencies or law firms if required by law, for credit or address checks, for the transmission of information to credit agencies (e.g. in the event of termination due to default in payment) and to the extent necessary to enforce our rights, in particular to enforce claims arising from the contractual relationship.

Among others, twago uses Creditreform Boniversum GmbH, Hellersbergstr. 11, 41460 Neuss as debt collection service provider and to provide information on creditworthiness. Further information on the scope of use and the rights of the user can be found here.

Website visitors

Personal data will only be passed on to other users or website visitors inside or outside the European Union or is made accessible to third parties to the extent that users have permitted this within the settings of their profile, if this is indispensable for the conclusion/processing of service contracts or if it is separately highlighted that the data can be viewed by third parties. The information that can be viewed by third parties includes in particular information on the projects advertised or completed via twago and the assessments submitted or received.

IT service provider, Web analysis tools, Storage services

twago also uses third parties for IT services, web analytics, storage services, database and website management outside the European Union. The respective service providers may have access to personal data, as far as this is necessary for the provision of the respective service to twago.

The use of third party providers is based on a legitimate interest of twago within the meaning of Art. 6 para. 1 letter f) GDPR and serves the avoidance and correction of technical errors on the website, the analysis of data traffic, trends and use of the website as well as internal statistical purposes.

Data is only passed on to third parties outside the European Union if this is permitted under data protection law and if measures to ensure an appropriate level of protection (e.g. standard contractual clauses, EU-US Privacy Shield, etc.) are in place.

4. Data security

We use appropriate technical and organizational security measures to protect your personal data stored by us against manipulation, partial or complete loss and against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

5. Data storage and deletion periods

Deletion periods for data of registered users

Data of service providers, service recipients, and suppliers will be stored for the duration of the existing contract with twago (e.g. existing user account, supplier contract, etc.). After termination of the contract, the data will be deleted or made irretrievably anonymous within three months. Data from projects and submitted ratings on the website that are visible in the profiles of other users are anonymized.

This does not apply to data collected from website visitors. See deletion deadlines for website visitor data.

Data which is subject to retention obligations under tax or commercial law (invoices, commercial letters, etc.) are stored for the respective legal retention period. The legal retention period is currently 10 years for tax purposes and 6 years for commercial purposes.

Deletion periods for website visitor data

Data of website visitors will be made irretrievably anonymous after three months.

Deletion periods for applicant data

Applicant data will be deleted after completion of the respective recruitment measure, but no later than one year after the data collection. If the applicant expressly consents that his or her data can be stored even after completion of the recruitment process, this data will be deleted three years after the last contact.

6. Rights of data subjects

Persons whose data are stored at twago have the following rights:

Right to information about stored personal data

Upon request, twago will provide information on data processing and its purpose at appropriate intervals.

Right to correct inaccurate data

If data is incorrect, twago will correct it upon request and after checking, only if the user is not able to make the change in his or her user account himself or herself,

Right of objection against unlawful data processing

If there are doubts, an objection can be filed against data processing. This applies in particular if twago has no legitimate interest in the processing or if the data is used for direct advertising.

Right to limitation of processing

If an objection has been filed or the accuracy of data is being checked, a restriction of the processing of the data may be requested for the duration of the examination. If data has been processed unlawfully or is no longer required, the data subject may request the restriction of the data instead of deletion.

Right to cancellation

The data shall be deleted if it is no longer needed and if there is no legal basis for the processing. This applies in particular if no consent of the person or no legitimate interest in the processing exists.

Right to data transferability

twago will make the data available on request in a machine-readable format or, as far as possible, transfer it to another responsible party.

Right of appeal to a supervisory authority

Persons have the right to file a complaint with the competent local supervisory authority. The responsible supervisory authority for twago is:

Berlin Commissioner for Data Protection and Freedom of Information

Friedrichstr. 219

Visitors entrance: Puttkamerstr. 16 - 18 (5th floor)

10969 Berlin, Germany

Phone: 030 13889-0

Fax: 030 2155050

Email: mailbox@datenschutz-berlin.de

In order to assert the rights, a message must be sent to twago under the contact details stated under item 12. In order to prevent unauthorized persons from taking advantage of this, twago can demand that the person invoking a right proves his identity.

7. Cookies and retargeting

7.1 Cookies

Cookies are small files which are stored on your data carrier and which store certain settings and data for exchange with our system via your browser. Basically, there are two different types of cookies, so-called session cookies, which are deleted when you close your browser and temporary/permanent cookies which are stored on your data carrier for a longer period or indefinitely. The storage helps us to design our website and our offers according to your needs and to facilitate the use, for example by storing certain entries by you in such a way that you do not have to repeat them constantly.

In this respect, cookies help to make your visit on twago easier, more pleasant and more meaningful under many aspects. Cookies are alphanumeric information files that your web browser automatically stores on your computer's hard drive when you visit our website.

For example, we use cookies to identify you as a user without requiring you to log in separately. The usage does not provide us with new personal data about you as an online visitor. Most Internet browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or a message appears whenever you receive a new cookie.

However, you can set your browser to accept cookies only if you agree to this. Usually, the help function in the menu bar of your web browser shows you how you can reject new cookies and deactivate cookies already received.

We would like to point out that deactivating cookies may prevent you from using all twago functions.

7.2 Retargeting

The twago online platform uses cookie technology to collect data. The aim is to optimize the range of products and advertising. The data is being anonymized and is not used to identify you personally. Your data will never be combined with the personal data stored by us. With the help of the anonymized data we can make our online offer more attractive for you and present you with offers, services and advertising that correspond to your areas of interest.

twago uses so-called retargeting technologies. These techniques enable users who have already visited the twago portal to be addressed with advertising on the websites of our partners. We are convinced that the insertion of personalized advertising is generally more interesting for the user than advertising without a personal reference. twago uses cookie technology and an analysis of the previous usage behaviour to display the advertising material. The data used is anonymized and never combined with personal data. Personal data is never stored at any time.

By using the twago portal, the user consents to the use of so-called cookies and thus to the anonymous collection, storage and use of usage data. The user also agrees that their data can be stored in cookies even after the end of the browser session and can be retrieved, for example, at the next visit. The user can revoke this consent at any time with effect for the future by refusing to accept cookies in the browser settings.

8. Google Analytics

In order to constantly improve and optimize our offer, we use so-called tracking technologies. For this, we use the services of Google Analytics.

This website uses Google Analytics, a web analysis service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is generally transmitted to and stored by Google on servers in the United States. However, we have set up an IP anonymization tool on our website to protect your data, so that your IP address is previously reduced by Google within Member States of the European Union and in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website and Internet use. According to Google, the IP address transmitted by your browser in the context of Google Analytics is not merged with other data by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available under the following link[http://tools.google.com/dlpage/gaoptout?hl=en]. For more information, please visit http://www.google.com/intl/de/analytics/privacyoverview.html.

9. Use of the Google +1 button

Our website uses the "+1" button of the social network Google Plus, which is operated by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States ("Google"). The button can be recognized by the "+1" character on a white or coloured background.

When you visit a website of our internet presence that contains such a button, your browser establishes a direct connection to Google's servers. The content of the "+1" button is transmitted by Google directly to your browser and integrated into the website. We, therefore, have no influence on the amount of data Google collects with the button. According to Google, no personal data is collected without a click on the button. Such data, including the IP address, is only collected and processed for members who are logged in.

For the purpose and scope of data collection and the further processing and use of the data by Google as well as your rights and setting options for the protection of your privacy, please refer to Google's data protection information on the "+1" button: http://www.google.com/intl/de/+/policy/+1button.html and the FAQ: http://bit.ly/r3Qmer.

If you are a Google Plus member and do not want Google to collect data about you via our website and link it to your membership data stored on Google, you must log out of Google Plus before visiting our website.

10. Use of social plugins

Our website uses social plugins ("plugins") of the social network facebook.com, which is operated by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). The plugins can be recognized by one of the Facebook logos or they are marked with the addition "Facebook Social Plugin".

When you visit a website on 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 website. We, therefore, have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore inform you according to our level of knowledge:

By integrating the plugins, Facebook receives the information that you have called up the corresponding page of our website. If you are logged in to Facebook, Facebook can assign your visit to your Facebook account. If you interact with the plugins, for example by pressing the like button or making a comment, the corresponding information is transmitted directly from your browser to Facebook and stored there. If you are not a member of Facebook, it is still possible for Facebook to obtain and store your IP address.

For the purpose and scope of data collection and the further processing and use of the data by Facebook as well as your rights and setting options for the protection of your privacy, please refer to the Facebook data protection information: http://www.facebook.com/policy.php.

If you are a Facebook member and do not want Facebook to collect data about you via our website and link it to your membership data stored on Facebook, you must log out of Facebook before visiting our website.

11. Amendment of the Data Protection Directive

This Privacy Policy may change from time to time. Please check our website regularly for the latest version.

12. Contact

Please send your request by email or by post to the following address, clearly identifying yourself:

Team2Venture GmbH

Managing Director: Thomas Jajeh, Arco Elsman

Friedrichstr. 224

10969 Berlin, Germany

privacy@twago.com

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