The protection of your privacy is of particular importance to us.
New Work SE, Am Strandkai 1, 20457 Hamburg, Germany, e-mail: firstname.lastname@example.org, hereinafter "We", as operator of the
website "www.honeypot.io" is the controller for the use of the personal data of
users of the website pursuant to Art. 4 (7) of the EU General Data Protection
Regulation (“GDPR”). You can contact our data protection officer Christian Schmidt via email@example.com or our postal address with reference to "Data protection
Furthermore, it is important to us that you know, at any point, when we store
your personal data and how we use it.
We will collect, process, and use your personal data in compliance with
applicable European and German data protection law.
about when and how we collect personal data relating to you during your use of
the websites and service operated by New Work under the domain ”honeypot.io”
(“Service”) and how we use such data. We inform you about the kind of personal
data, the scope of personal data, and the purposes that such collection and use
of personal data is performed for. We, therefore, ask you to read the following
cross-references ("links") to other websites of third-party providers. Our
users should carefully read privacy policies of third party websites collecting
your personal data.
use of your personal data in compliance with the laws applicable to the
protection of personal data and the following provisions.
What is personal data?
Personal data is any information relating to an identified or identifiable
natural person. A person is identifiable, if the person can be identified,
directly or indirectly, in particular by reference to an identification number
or to one or more factors specific to his physical, physiological, mental,
economic, cultural or social identity. This may include data such as e.g. name,
email address, telephone number and mailing address. We process your data in the
context of our service only when you have given us your consent to do so, the
data is necessary for the performance of the contract or where it is permissible
You may withdraw your consent to the processing of personal data at any time. A
revocation has direct influence on the admissibility of the processing of your
personal data as soon as directed to us.
If the processing of your personal data is based on legitimate interests, you
have the right to object to processing the personal data. If you exercise your
right of objection, we kindly ask you to explain the reasons why we should not
process your personal data. If your objection is justified, we will review the
facts and adjust or modify the processing of data or inform you about imperative
legitimate grounds for the processing.
We will delete your personal data as soon as the data is no longer necessary for
the respective purpose. It may occur that personal data is kept for the time
during which possible claims may be asserted against us (for example statutory
limitation period of three or in some cases, thirty years). Furthermore, we are
required by law to store certain data due to the duties of proof and retention,
inter alia from the German Commercial Code, the German Tax Code or the Money
Laundering Act. The storage periods can be up to ten years.
What kind of personal data does New Work collect?
With every access of our Service data related to this event is being saved to a
protocol file or database on the server of our hosting service provider. This
also applies to data you enter in order to use the Service or contact us.
We collect the following information:
- File name of the content retrieved (respectively, information submitted by you
in the course of using our service);
- Date and time of the request;
- Amount of data transferred, access status (content transmitted, content not
- Operating system, browser and device type;
- Screen resolution, language and time zone settings;
- Referrer-URL, i.e. internet address of the website visited previous to
accessing our offering;
- IP address and name of your internet service provider.
The IP address is stored for the period of use only and will be deleted or
anonymized afterwards immediately.
We collect the aforementioned data as this is technically necessary for us to be
able to display our website and to ensure the stability and security of the
website. The legal basis of this processing is Art. 6 (1) sentence 1 lit. f)
How does New Work use my personal data?
New Work uses the data for the following purposes:
- Providing the services you requested, e.g. matching you with other members of
- Making certain that you have the best possible user experience, e.g. edit your
profile and manage your privacy settings.
- Honoring our contractual obligations to you, e.g. inform you about possible
connections (Interview Invites) via the platform, email or phone.
- Enabling you to participate in our interactive service as far as you like.
- To inform you about changes to our service, relevant content releases, community events, and marketing initatives.
On our website you can set up an account to use our services in form of an
online job marketplace platform. In case you sign up as a candidate (“Talent”),
you are required to enter your personal data such as name and e-mail,. In
addition, you need to add languages and other skills, employment and education
history as well as location to create an account. You can also sign up with your
LinkedIn or Github account (for further information please see provisions about
social media plug-ins below). In this case, further information may be required,
such as name, photo, current position, etc. New Work can contact the Talent to
determine further information required and update the profile accordingly.
Signing up as an employer requires to enter the company name, hiring location,
number of employees, contact person and contact e-mail. The information required
for the implementation of the contract relationship will be processed for this
purpose only. In most cases, companies access the profiles of Talents by
themselves on the platform after searching for certain skills and contact the
Talent directly. Furthermore, however, New Work can contact the Talent or the
employer via phone, email or messaging service and suggest companies which fit
the Talent´s profile or suggest Talents which fit the company´s profile. The
legal basis of this processing is Art. 6 (1) sentence 1 lit. b) GDPR. A storage
of data can be revoked at any time.
The specified data and your entire user account can always be deleted in the
customer area. You agree to treat personal access data confidentially and not to
make such data available to unauthorized third parties. We do not assume
liability for misused passwords unless we are responsible for the abuse. You
should notify us immediately if you are concerned about a third party having
knowledge of your password, if the password is used unauthorized or this seems
to be likely. You are responsible for ensuring that your information is accurate
and complete and that you notify us of any changes to the information provided.
You can review and update the information provided and your account settings
section of our website. After completing communication with New Work you should
log out and close the browser window, especially if you share the computer with
Due to commercial and tax regulations, we may be obliged to store part of the
personal data transferred (e.g. payment data) for a period of 10 years. After a
period of [e.g. 2 years] we restrict the use of specific data and, as a
consequence, the data may be used to comply with legal obligations only.
Does New Work transfer data to third parties?
We transmit your personal data to third parties only if you have consented to
the transfer, if the transfer is necessary for the performance of the contract,
or we are enforced to do so by law.
Companies we cooperate with to mediate the Talent and try to match the right
person with the right job have access to profiles of the Talents and therefore
personal data of Talents are transmitted to the companies as a result. The
companies are only allowed to process these personal data within the framework
of the application process (especially save the data in their applicant tracking
system) and to contact the Talent in case there are interested. The legal basis
of this processing is Art. 6 (1) sentence 1 lit. b) and f) GDPR.
We sometimes use external service providers to process your personal data and to
provide our services. They are carefully chosen and instructed by us. They are
bound by our instructions and are regularly inspected. The data provided to our
service providers may be used by them to fulfill their tasks only.
In particular, New Work transfers personal data to service providers to be able
to create and publish Talent profiles on the platform, to proof the Talent´s
qualification, to invite Talents to online interviews with companies or with
New Work, to ensure communication between Talents and companies and between
Talents and New Work and to help Talents and companies with the Visa process.
In order to improve the services of New Work and to assess whether a contract
between Talent and Company will take place soon. New Work is able to access the
communication between Talent and Company on the platform.
If we transfer personal data outside the European Economic Area (EEA), we will
do so only if the EU Commission has decided that the third country ensures an
an adequate level of data protection or other appropriate safeguards exist (e.g. EU
standard contractual clauses or binding corporate rules) or a person has given
its consent to do so.
In addition to the aforementioned usage data, cookies are stored on your
computer when you use our website. These are small text files that are stored on
your device and through which New Work receives certain information. However,
to configure a visit to our website more attractive and to enable the use of
We use transient and persistent cookies on our website. If you close your
browser, transient cookies are automatically deleted. These cookies include, in
particular, session cookies. This will allow us to recognize your computer when
you return to our website. Session cookies are deleted as soon as you close the
browser or log out.
In contrast, persistent cookies are automatically deleted after a specified
period of time. These cookies can be deleted at any time in the security
settings of your browser.
Generally, you can configure your browser settings in accordance with your
personal demands and, for example, decline all cookies. However, non-acceptance
of cookies may limit the functionality of our website.
Does New Work use analytics tools?
New Work uses Google Analytics, a web analytics service provided by Google Inc.
("Google"). Google Analytics uses so-called "cookies", text files that are saved
on your computer and that allow an analysis of your use of our website. The
information generated by the cookie about your use of our website is usually
transmitted to and stored on a Google server in the USA. However, in the event
of the activation of IP anonymization on our website, your IP address will be
truncated previously by Google within member states of the European Union or in
other contracting states of the Agreement on the European Economic Area. Only in
exceptional cases, the full IP address will be sent to a Google server in the US
and truncated there. On behalf of New Work, Google will use this information to
evaluate your use of our website, compile reports on website activity, and
provide other services related to website activity and internet usage to
The IP address transmitted by your browser as part of Google Analytics will not
be combined with other Google data.
You can prevent the storage of cookies by an appropriate setting of your browser
software; however, please note that in this case, you may not be able to use the
full range of all functions of our website. You may also prevent the collection
of the data generated by the cookie and relating to your use of our website
(including your IP address) as well as the processing of this data by Google by
downloading and installing the browser plug-in available under the following
New Work uses Google Analytics with the extension "\_anonymizeIp ()".
Accordingly, IP addresses are truncated, and, thus, a reference to persons can be
ruled out. If the data collected about you have a personal reference, this
reference is immediately excluded, and the personal data is deleted immediately.
We use Google Analytics to analyze and regularly improve the use of our website.
With the statistics, we can improve our offer and make it more interesting for
you as a user. For the exceptional cases in which personal data is transferred
to the US, Google is part of the EU-US Privacy Shield,
https://www.privacyshield.gov/EU-US-Framework. The legal basis of this
processing is Art. 6 (1) sentence 1 lit. f) GDPR.
Information of third-party providers: Google Dublin, Google Ireland Ltd., Gordon
House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. User
conditions: http://www.google.com/analytics/terms/de.html, Overview of data
protection: http://www.google.com/intl/de/analytics/learn/privacy.html, and
Does New Work use Google Adwords?
New Work uses Google Adwords to draw attention to our offers by using
advertising materials (so-called Google Adwords) on external websites. In
relation to the data of the advertising campaigns, we can determine how
successful the individual advertising measures are. We are interested in showing
you advertisements that are of interest to you, to make our website more
interesting to you and to achieve a fair calculation of advertising costs.
These advertising materials are supplied by Google via so-called "ad servers".
Therefore, we use ad server cookies, which measure certain performance metrics
such as ads or user clicks. If you access our website through a Google ad,
Google Adwords will store a cookie on your PC. These cookies usually lose their
validity after 30 days and are not intended to identify you personally.
Typically, the unique cookie ID, number of ad impressions per placement
(frequency), last impression (relevant to post-view conversions), and opt-out
information (mark that the user does not like to be addressed) will be saved.
These cookies allow Google to recognize your internet browser. If a user visits
certain pages of an Adwords customer's website and the cookie stored on their
computer has not expired, Google and the customer will be able to detect that
the user clicked on the ad and was redirected to that page. Each Adwords
customer is assigned a different cookie. Cookies cannot be tracked via the
websites of Adwords customers. New Work does not collect and process any
personal data in the aforementioned advertising measures. We receive only
statistical evaluations by Google. On the basis of these evaluations, we can
identify which of the advertising measures used are effective. We do not receive
any further data from the use of the advertising material, in particular, we
cannot identify the users on the basis of this information.
Due to the marketing tools used, your browser automatically establishes a direct
connection to the Google server. We have no control over the extent and the
further use of the data, which are raised by the appliance of this tool by
Google. Therefore we inform you according to our knowledge level: By the
incorporation of AdWords conversion, Google receives the information that you
entered the appropriate part of our internet appearance or click on an ad from
us. If you are registered with a service provided by Google, Google may
associate the visit with your account. Even if you are not registered with
Google or have not logged in, there is a chance that the provider will find and
store your IP address.
You can prevent participation in this tracking process in several ways: a) by
adjusting your browser software accordingly, in particular, suppression of
third-party cookies will prevent you from receiving any third party
advertisements; b) by deactivating the cookies for conversion tracking by
setting your browser to block cookies from the domain "www.googleadservices.com"
under https://www.google.de/settings/ads. However, this setting will be deleted
when you delete your cookies; c) by deactivating the interest-based ads of
providers that are part of the self-regulation "About Ads" campaign via the link
http://www.aboutads.info/ choices, however, this setting will be deleted
when you delete your cookies; d) by permanent deactivation in your browser
(Firefox, Internet Explorer, or Google Chrome) under the link
http://www.google.com/settings/ads/plugin. We point out that, in this case you
may not be able to use all the features of our offer.
The legal basis for the processing of your data is Art. 6 (1) sentence 1 lit. f)
GDPR. More information about privacy at Google can be found here:
https://services.google.com/sitestats/de.html. Alternatively, you can visit the
website of the Network Advertising Initiative (NAI) at
http://www.networkadvertising.org. Google is part of the EU-US Privacy Shield,
Does New Work use Social-Media-Plug-ins?
New Work currently uses the following social media plug-ins on our website:
Facebook, Twitter, LinkedIn, and GitHub.
New Work uses the so-called two-click solution. This means that, by visiting our
website, no personal data is initially passed on to providers of such plug-ins.
The provider of the plug-in can be identified on our website by the
corresponding logo via the respective button. We provide the opportunity to
communicate directly with the provider of the plug-in. The plug-in provider only
receives the information that you have accessed its website via our online
service if you click on the designated field and activate it. Furthermore, the
In Germany, according to the information of the respective provider, when using
Facebook plug-ins, the IP address will be anonymized immediately after
Please note that through activation of the plug-in, personal data will be
transferred about you to the respective plug-in provider (in the case of US
providers to the USA). Data collection is mainly done by plug-in providers via
cookies. So we recommend deleting all cookies on the security settings of your
browser before clicking on the button.
We have no influence on the collected data and the data processing operations.
We are also not aware of the full scope of the data collection, the purpose of
the processing, and the storage periods. In addition, we have no information on
the deletion of the data collected by the plug-in provider.
The respective plug-in provider stores the data collected about you in profiles
and uses them for marketing, market research, and/or tailored design of its
website. Such an evaluation is carried out in particular (also for non-logged-in
users) for the presentation of tailor-made advertising and to inform other users
of the social network about your activities on our website. You have a right to
object to the creation of such user profiles. To exercise, you need to
contact the respective plug-in provider. The plug-ins allow us to interact with
social networks and other users so that we can improve our offer and make it
more interesting for you. The legal basis for the use of the plug-ins is Art. 6
(1) sentence 1 lit. f) GDPR.
A transfer of data takes place regardless of whether you have an account with
the plug-in provider and are logged in. However, if you are logged in to the
plug-in provider, your data collected from us will be assigned directly to your
user account. If you activate the social media button and, for example, link the
page, the plug-in provider also stores this information in your user account and
shares it publicly with your contacts. For this reason, we recommend logging out
regularly after using a social network, but especially before activating the
button, as this will prevent you from being assigned to your profile with the
For more information on the purpose and scope of the data collection and its
processing by the plug-in provider, please refer to the privacy statements of
the relevant provider, which are provided below. You will also get further
information about your rights and settings options to protect your privacy.
Addresses of respective plug-in provider and URL with privacy policies:
Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA;
http://www.facebook.com/policy.php; further information on the collection of
http://www.facebook.com/about/privacy/your-info#everyoneinfo. Facebook is part
of the EU-US-Privacy-Shield, https://www.privacyshield.gov/EU-US-Framework.
Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA;
https://twitter.com/privacy. Twitter is part of EU-US-Privacy-Shield,
LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA;
http://www.linkedin.com/legal/privacy-policy. LinkedIn is part of the
Github Inc., 88 Colin P Kelly Jr St, San Francisco, CA 94107, USA;
https://enterprise.github.com/privacy. Github is part of the
Does New Work use Retargeting-Services?
New Work currently uses retargeting functions of Google, LinkedIn, Twitter, and Facebook. This service makes it possible to reach users who previously visited or register on our website to show targeted advertisements and offers of New Work based on the collected information. In the case of Facebook, we are using the Facebook Pixel, which is implemented on our website.
Addresses and URL with privacy policies:
- Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
- Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
- LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland
- Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0
- Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland)
- Twitter (Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland)
Does New Work save my data in case of me making a request?
In case you direct an inquiry to New Work, New Work saves the communication
history with you as well as information and data submitted in the course of this
communication (e.g. email address), in order to optimally answer your request
and any further follow-ups. New Work will delete the relevant data after the
storage is no longer required or restrict the processing if statutory retention
Is my data secure?
New Work takes all appropriate technical and organizational security measures to
protect your data against manipulation, loss, destruction, or unauthorized access
by third parties. Our systems are secured against unauthorized access. However,
we have to point out that the Internet does not allow for absolute data security
despite all technical measures. We are not liable for actions of third parties.
What are my rights in relation to New Work?
You have the right of access, rectification or erasure, restriction of
processing, to object, and to data portability with respect to your personal
New Work is available for corresponding requests or messages at the specified
Please note that the deletion of data is only possible if there are no
precluding legal regulations. Information concerning your requests or messages
is transmitted in electronic form (by e-mail). Should you use this option of
providing information via e-mail, the specified e-mail address (both sender and
recipient) will not be used for any purpose other than the provision of
information and its documentation. You also have the right to lodge a complaint
concerning the processing of your personal data by us with a supervisory
If we are legally required to disclose data to local, state, national or
international authorities, we will comply with this obligation.
We will also disclose information to third parties when required by applicable
laws and regulations.
In addition, we may disclose information to investigate, prevent, or initiate
countermeasures against illegal activities or suspected fraud, or to apply or
enforce any of our contracts and licensing rights.
New Work will always observe the applicable statutes concerning data protection.
An up-to-date version is available on our website. New Work recommends that
How do I contact Honeypot in regard to data privacy aspects?
We look forward to your contact in case you might have requests, questions, or
suggestions relating to data privacy. Please direct written requests to:
New Work SE
Am Strandkai 1
20457 Hamburg, Germany