Privacy Policy of Honeypot

The protection of your privacy is of particular importance to us.

Honeypot GmbH, Schlesische Straße 26, 10997 Berlin, Germany, e-mail: [email protected] (see imprint),hereinafter "Honeypot", 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 via [email protected] or our postal address with reference to "Data protection officer".

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.

What is this Privacy Policy about?

The details provided in this Privacy Policy shall provide you with information about when and how we collect personal data relating to you during your use of the websites and service operated by Honeypot 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 explanations carefully.

This Privacy Policy is only valid for this website. The website might contain cross-references ("links") to other websites of third-party providers. Our Privacy Policy does not apply to websites of third parties. For this reason, users should carefully read privacy policies of third party websites collecting your personal data.

By agreeing to our Privacy Policy you agree to the collection, processing and 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 by law.

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 Honeypot 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 found, etc.);
  • 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) GDPR.

How does Honeypot use my personal data?

Honeypot uses the data for the following purposes:

  • Providing the services you requested, e.g. matching you with other members of our service.
  • 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.

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. Honeypot 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, Honeypot 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 Honeypot you should log out and close the browser window, especially if you share the computer with other people.

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 Honeypot 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, Honeypot 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 Honeypot, to ensure communication between Talents and companies and between Talents and Honeypot and to help Talents and companies with the Visa process.

In order to improve the services of Honeypot and to assess on whether a contract between Talent and Company will take place soon, Honeypot 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 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.

Does Honeypot use Cookies?

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 Honeypot receives certain information. However, cookies cannot run programs or transmit viruses to your computer. We use cookies to configure a visit to our website more attractive and to enable the use of certain functions.

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 Honeypot use analytics tools?

Honeypot 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 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 Honeypot, Google will use this information to evaluate your use of our website, to compile reports on website activity, and to provide other services related to website activity and internet usage to Honeypot.

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 link: http://tools.google.com/dlpage/gaoptout?hl=de.

Honeypot 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 provider: 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 privacy policy: http://www.google.de/intl/de/policies/privacy.

Does Honeypot use Google Adwords?

Honeypot 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. Honeypot 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: 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: http://www.google.com/intl/de/policies/privacy and https://services.google.com/sitestats/de.html. Alternatively you can visit the website of Network Advertising Initiative (NAI) under http://www.networkadvertising.org. Google is part of the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

Does Honeypot use Social-Media-Plug-ins?

Honeypot currently uses the following social media plug-ins on our website: Facebook, Twitter, LinkedIn, Github.

Honeypot 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 information according to access and cookies of this Privacy Policy will be transmitted.

In Germany, according to the information of the respective provider when using Facebook plug-ins the IP address will be anonymized immediately after collection.

Please note that through activation of the plug-in personal data will be transferred about you to the respective plug-in provider (in case of US providers to the USA). Data collection is mainly done by plug-in providers via cookies. So we recommend to delete 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 against the creation of such usage 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 to log 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 plug-in provider.

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 und URL with privacy policies:

Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA; http://www.facebook.com/policy.php; further information to the collection of data: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications and 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, https://www.privacyshield.gov/EU-US-Framework.

LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA; http://www.linkedin.com/legal/privacy-policy. LinkedIn is part of the EU-US-Privacy-Shield, https://www.privacyshield.gov/EU-US-Framework.

Github Inc., 88 Colin P Kelly Jr St, San Francisco, CA 94107, USA; https://enterprise.github.com/privacy. Github is part of the EU-US-Privacy-Shield, https://www.privacyshield.gov/EU-US-Framework.

Does Honeypot save my data in case of me making a request?

In case you direct an inquiry to Honeypot, Honeypot 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. Honeypot will delete the relevant data after the storage is no longer required or restrict the processing if statutory retention periods exist.

Is my data secure?

Honeypot 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 Honeypot?

You have the right of access, rectification or erasure, restriction of processing, to object and to data portability with respect to your personal data.

Honeypot is available for corresponding requests or messages at the specified address below.

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 authority.

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.

Is an amendment of the Privacy Policy possible?

Honeypot reserves the right to amend this Privacy Policy at any time, but Honeypot will always observe the applicable statutes concerning data protection. An up-to-date version is available at our website. Honeypot recommends that users regularly review our Privacy Policy in order to be informed about our current Privacy Policy.

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:

Honeypot GmbH
Schlesische Straße 26
10997 Berlin, Germany

or

[email protected]