Please read this Privacy and Cookies Policy carefully prior to using our website, as this will apply to your use of our website and our Services.
- In general
Sompani UG (haftungsbeschränkt) (“Sompani”, “us”, “we”, or “our”) builds and operates private talent pools for Venture Capital funds, Private Equity funds, Accelerator programs and other institutional investment bodies running under respective web-domains determined on a case-by-case basis ( hereinafter “our website”) that operate as an online platform that offers Services for registered Users that are active in an investment portfolio of the aforementioned institutional bodies.
Sompani is committed to protecting and respecting the privacy of any user of our website in accordance with the Laws of Germany, concerning the protection of the private life in relation to the processing of personal data and complies with the European General Data Protection Regulation (Reg. 2016/679, hereinafter “GDPR”) as of its date of application.
This policy together with our Terms and Conditions and any other documents referred to in it sets out the basis on which any personal data we may collect from you, or that you provide to us, will be processed by us.
- Data controller
For the purpose of the GDPR, the data controller is Sompani UG (haftungsbeschränkt), registered under number HRB 193294 B with registered office in Krügerstrasse 19, c/o Artjom Simon, 10439 Berlin, Germany.
- Information we may collect and use
We may collect and process the following (personal) data of Candidates and Users as explained hereinafter.
3.1. What information might be collected from Candidate (s)?
As a Candidate we may collect and process the following data:
– First and last name; email address; field (e.g. Marketing Manager); current Employers (including company Logo + short description of company); position (e.g. Junior); telephone number; Skype name; education level, language skills, availability date (e.g. when Candidate is available for a new position), work experience, availability of a EU work permit, relation to Referrer, CV of Candidate (this CV might include other (personal) information, e.g. information about previous employers) all the other information you voluntary provide to us;
We need this information in order to:
- allow you to make use of our Services as described in our Terms and Conditions;
- inform you of vacancies and/or to supply you with information about our Services and other activities within the Sompani operations (a. o. marketing campaigns and promotions);
- inform you via direct marketing purposes;
- introduce you to potential employers;
- assess your profile and suitability for a job as a Candidate,
- further improve your personal development and chances of getting hired,
- verify internal checks and corporate security, to perform audits and for auditing purposes;
- allow us to comply with the prevailing legislation and regulations.
3.2. What information might be collected from User-Referrer or User-Recruiter?
As a User-Referrer or User-Recruiter we may collect and process the following data:
– First and last name; email address; description of current occupancy (e.g. Junior Marketing Manager); current Employers (including company Logo + short description of company); vacancy information; all the other information you voluntary provide to us;
We need this information in order to:
- present you with a pool of Candidates and/or to supply you with information about our Services and other activities within the Sompani operations (a. o. marketing campaigns and promotions);
- allow you to access information about Candidates on our platform and to be introduced to candidates on our platform;
- allow us to maintain our business relationship with you;
- allow us to manage the Services of for User-Referrer(s), Candidate(s), and other User- Recruiter(s).
3.3. In general
Furthermore, we process your data to keep you informed of important developments within the framework of our website. In addition, we keep anonymized data to allow us to analyse the use of the website, to enable us to enhance the functionalities and design of the website, to tailor the website to the preferences of users and to help us develop new functionalities and systems.
In conclusion, we might process personal data to prevent the abuse of website and/or criminal offences and to allow us to reply to your e-mails and deal with complaints about matters like the information you post on the website.
We only collect and process your information for a limited period in order to make use of our Services as determined in our Terms and conditions. All the information that is asked from the Users or Candidates at the time of registration and henceforth while using our Services is obligatory and essential if you wish to use our website and our Services. We explicitly wish to abide the data minimization principle in the GDPR. Should your personal data change, we ask you to amend them as quickly as possible so that we are at all times in possession of your correct data in order to use our Services properly.
3.4 Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain Consent for a specific processing purpose. If the processing of Personal Data is necessary for the performance of a contract to which the Data Subject is party, the processing is based on Article 6(1) lit. b GDPR. If the processing of Personal Data is necessary to pursue the Data Controller’s legitimate business interests of answering an enquiry submitted by the Data Subject or providing information to the Data Subject, the processing is based on Article 6(1) lit. f GDPR.
4.1. What are cookies?
A cookie is a piece of text, which asks permission to be placed on your computer’s hard drive. Once you agree, your browser adds that text in a small file. A cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Overall, cookies help to further tailor the website to the wishes and preferences of visitors. Cookies can also be used to give the content of a website or an advertisement on a website a more personal touch. A cookie does not give us access to your computer or any information about you, other than the data you choose to share with us. You may set your web browser to notify you of cookie placement requests or decline cookies completely. A cookie usually contains the name of the server that installed the cookie, an expiry date and a unique numerical code. You can delete the files that contain cookies – those files are stored as part of your Internet browser.
4.2. Cookies that are used by Sompani
Our Sompani website uses several types of cookies:
These cookies are indispensable/essential if you wish to use our website and all its components. Without these cookies, Services we would provide (such as permitting log-in into the Sompani account) cannot be provided. They also perform a secure identity check: when you log on, this cookie will ensure that your identity is checked before the website gives you access to your personal information.
We use performance cookies to collect information about visitors’ use of the website for the purpose of improving, optimising and making the content of our website more efficient.
These cookies help us learn how well our website and services are performing. We use these cookies to analyse data about web page traffic and to understand, improve, and research our services available via our website.
Our website uses advertising cookies. While visiting the website, your browsing behaviour and your demographic and profile data are anonymously processed in an advertising cookie. The website’s advertisers can also install advertising cookies. The information collected via these advertising cookies is used to measure the effectiveness of the ads and to tailor them better to your possible interests.
These cookies improve your experience by enabling personalization (like remembering language and region) as well as enabling certain features like tracking progress on matching and mutually introducing user base.
Each type of browser has its own method of managing cookies. You can find that information on the websites of Internet Explorer, Edge, Chrome, Safari and Firefox. Cookies can be disabled (see the settings of your device). Disabling cookies may affect the proper functioning of the website.
- Disclosure of your (personal) information
Within the framework of the aforesaid objectives, the data collected can be disclosed to other companies, within the Sompani Group being SOMPANI UG (haftungsbeschränkt) and Fandidates UG (haftungsbeschränkt) and to our User-Referrer(s), Candidate(s), and other User-Recruiter(s), as well as third party agents responsible for CV improvements and career development aides. This transfer may also occur from one of the above mentioned entities to Sompani. On request, we will provide you with a list of the companies that form part of the Sompani Group. The personal data can also be passed on to subcontractors providing services on behalf of the Sompani Group or acting under our instructions and authority, government bodies and in any and all cases where we are compelled to do so.
We ask that all people who have access to personal data through their work for us to respect a duty of confidence.
In principle we do not pass on your personal data to any third parties. However, it may be possible that we could provide your information to third parties, in this event we will first ask your prior explicit consent. We pass on your personal data to third parties only if and when required in order to give you access to the functionalities of our website, to give you access to website and in the cases described above. Do bear in mind that, you remain responsible for any data you choose to disclose to another user yourself.
5.1 Social media platforms and widgets
Our Website includes social media features, such as the Facebook, Twitter and LinkedIn button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook, Twitter, and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
5.2 Links to third-party websites
5.3 Use of Google Analytics
This website uses Google Analytics, a web analysis service provided by Google Inc. (‘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 the website will be transmitted to and stored by Google on servers in the United States. IP anonymization is activated on this website, so your IP address will be shortened beforehand by Google within member states of the European Union or in other signatory states of the Treaty on the European Economic Area. The full IP address will be transmitted to a Google Server in the USA and shortened there only on an exceptional basis. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services to website operators relating to website activity and Internet usage. Google will not associate the IP address transmitted under Google Analytics by your browser with other data held by Google. You may prevent the storage of cookies by selecting the appropriate settings on your browser software; however, we must advise you that in this case, you might not be able to use all functions of this website to the full extent. You may prevent Google from recording the data generated by the cookie and pertaining to your use of the website (including your IP address), or processing these data by downloading and installing the following browser plug-in available through the following link http://tools.google.com/dlpage/gaoptout.
- Where we store your personal data
Your personal data will be stored on servers located in Frankfurt and Karlsruhe, Germany and will not be transferred or exported to any third country outside the European Union.
- Your rights
The User has the right to obtain access to his personal data, to correct his personal data and to object to the processing of its data. With regard to direct marketing each User or Candidate has the right to object, without any cost, against our use of your personal data by sending a request by e-mail to firstname.lastname@example.org accompanied by a copy of your identity card or by mail to the following address:
Sompani UG (haftungsbeschränkt)
c/o Artjom Simon
- Logging on via social media channels
In the future, you will also be able to log on to the website via an account with various social media networks, such as LinkedIn. In that case, please note that we can gain access to certain data in your social media account, such as your name, profile photograph and contacts. Furthermore, in that case, your social media username and profile photograph may become automatically visible on the website and information may be published on your social media page.
- Email notifications
In the future, we may also contact you by e-mail and via push notifications. We will for instance send you an email to verify your e-mail address, to introduce you to other User(s) or Candidate (s), and we may send you e-mails/push notifications about important developments such as an amendment to the terms of business or in the event of significant changes or major work to the website.
- Security of your (personal) information
We are aware about legitimate ongoing concerns you may have with regard to security of your (personal) information online and the current challenges on cyber threats and industrial espionage.
We have put an internal information policy framework in place based on our risk-assessment and our technical partners and ourselves have implemented state-of-the-art physical and stringent system security measures to protect your data.
However, threats to data are constant and evolving and therefore we cannot provide you any full guarantee with respect to the security of your (personal) information. Therefore, we commit and strive to take the appropriate technical and organizational measures to protect your personal data against loss, unauthorised access, disclosure and unlawful processing but we cannot assume any liability whatsoever.
- Contact details
In the event of questions about the processing of your personal data or should you wish to check your personal data or to have them corrected or deleted, you can contact us at the following addresses:
Sompani UG (haftungsbeschränkt)
c/o Artjom Simon