Privacy Policy

Version: 1.3, updated on January 26, 2024

Privacy Policy

I. Who are we?

FocusIn Ventures UG is an IT recruitment and software development company. This privacy policy will help you to understand how we collect and use your personal data on this website and during the course of our business.

Responsible for the processing of your data is: FocusIn Venture UG, Fregestr. 38 A, 12161 Berlin, Germany, e-mail: focusinventures@gmail.com.

II. Data Processing on our website and for our business

1. Visiting our Website

Each time you visit our website, we process data that your browser automatically transmits to enable you to open up the website. This includes the so-called http header information, in particular: IP address of the requesting device; date and time; address of the requested website and path of the requested file; if applicable, the previously accessed website/file; information about the browser and operating system used; request information such as language, type of content, encoding of content, character sets.

The processing of this data is necessary to enable the visit of the website, to ensure the permanent operability and security of our systems as well as for the general administrative maintenance of our website. The data is stored in internal log files for the purposes described above, temporarily and limited to the most necessary content, in order, for example, to find the cause of repeated or criminal calls that endanger the stability and security of our website and to take action against them.

The legal basis for this processing is Art. 6 (1) lit. b GDPR, insofar as the page view occurs in the course of the initiation or execution of a contractual relationship with us, and otherwise Art. 6 (1) lit. f GDPR due to our legitimate interest in enabling website access and permanent functionality and security of our systems.

2. Contacting Us

You have various options for contacting us. These include the contact form, live chat, email, phone or on our social media platforms. In this context, we process your data exclusively for the purpose of communicating with you.

The legal basis for this processing is Art. 6 (1) lit. b GDPR, insofar as your information is required to answer your enquiry or to initiate or execute a contract, and otherwise Art. 6 (1) lit. f GDPR due to our legitimate interest in you contacting us and us being able to answer your enquiry.

3. Newsletter

You have the possibility to subscribe to our newsletter, in which we will inform you regularly about news regarding our products, services and promotions.

To subscribe to our newsletter, we use the so-called double opt-in, meaning we will send you newsletters by email if you confirm in our notification email by clicking on a link that you are the owner of the email address provided. If you confirm your email address, we will store your email address, the time of registration and the IP address used for registration until you unsubscribe from the newsletter. The storage serves the sole purpose of sending you the newsletters and to be able to prove your registration. In addition, we measure whether our newsletter can be delivered at all.

The legal basis for the processing is your consent pursuant to Art. 6 (1) lit. a GDPR. You can revoke this at any time with effect for the future by unsubscribing from the newsletter. A corresponding unsubscribe-link can be found in each newsletter. A message to the contact details provided above or in the newsletter (e.g., by e-mail or letter) is of course also sufficient for this purpose.

4. Business Contacts

When you reach out to us regarding any of our business-to-business services or based on publicly accessible information we generate and contact leads, we collect your personal information such as name, title, contact information and use it to manage related requests and contracts and communicate with the company you work for based on our legitimate interests or where necessary based on your consent to administer our business relationships.

Your name and contact information are kept as long as required for the purposes described above and deleted on request for erasure or changed on new contacts update.

5. Job Applications

You can apply for open positions at FocusIn Ventures through our website as well as by email or LinkedIn message. The purpose of the data collection is the selection of applicants for the possible establishment of an employment relationship. For this purpose we process the following personal data: contact details (name, email, telephone number); details of your qualifications (skills, certifications, experience, employment history); information about your expectations and eligibility to work in the relevant country. Some information may be collected from other sources including: publicly available profile data (job agencies and dedicated sites like LinkedIn); contact details, information about qualifications, skills, experience, employment history from people who are reference for you.

The legal basis for the processing of your application data is Art. 6 (1) lit. b and Art. 88 (1) GDPR in conjunction with applicable EU member state law.

If we accept your application and a contractual relationship is established, we store your application data for as long as it is necessary for the contractual relationship and to the extent that legal regulations require us to retain it. If we reject your application, we will store your application data for a maximum of six months after rejecting your application, unless you give us your consent to store it longer.

With your consent we will store your data submitted as part of the application in our pool of applicants for a further sixty months after the end of the application process in order to identify any further positions that may be of interest to you and, if necessary, to approach you again. You can withdraw this consent at any time with effect for the future.  Withdrawing the consent does not affect any possible ongoing application processes.

III. Sharing data

Sometimes we need to share your data with:

  • our business clients to the extent and only whereas it is necessary to services to them;
  • our vendors and suppliers that we use to operate our business and provide services such as providers of software and IT systems, security, storage, legal, advisory, audit and insurance services;
  • law enforcement or other government and regulatory agencies or other third parties, where we are required by law to do so.

 

Data collected by us will only shared, if there is a legal basis for this under data protection law in the specific case, in particular if:

  • you have given your express consent to this;
  • the disclosure is necessary for the assertion, exercise or defense of legal claims and there is no reason to assume that you have an overriding legitimate interest,
  • we are legally obliged to disclose your data, in particular if this is necessary for legal prosecution or enforcement due to official requests and legal proceedings, or
  • this is legally permissible and necessary the processing of contractual relationships with you or for the implementation of pre-contractual measures, which take place upon your request.

 

Part of the data processing may be carried out by our service providers. In addition to the service providers mentioned in this policy, this may include data centers that store our website and databases, software providers, IT service providers that maintain our systems, agencies, market research companies, group companies and consulting companies. Currently, this website is hosted by a third-party service provider Bluehost – Endurance International Group (“Bluehost”), 10 Corporate Drive, Suite #300 Burlington, MA 01803, (“hoster”). If we share data with our service providers, they may only use the data to perform their tasks. The service providers have been carefully selected and commissioned by us. They are contractually bound to our instructions, have suitable technical and organizational measures in place to protect the rights of the data subjects, and are regularly monitored by us.

If we use services providers that are based in countries outside the EU or the EEA or process personal data there, i.e. countries whose level of data protection does not correspond to that of the EU. Where this is the case and the European Commission has not issued an adequacy decision (Art.  45 GDPR) for these countries, we have taken appropriate precautions to ensure an adequate level of data protection for any data transfers. These include, among others, the standard contractual clauses or binding corporate rules. Where this is not possible, we base the transfer of data on exceptions to Art. 49  GDPR in particular your express consent or the necessity of the transfer for the performance of the contract or for the implementation of pre-contractual measures.

If a third country transfer is provided for and no adequacy decision or appropriate safeguards are in place, it is possible and there is a risk that authorities in the respective third country (e.g. intelligence services) may gain access to the transferred data in order to collect and analyze it, and that enforceability of your data subject rights cannot be guaranteed. When obtaining your consent via the consent banner, you will also be informed of this.

IV. Use of Cookies and other tools

We also use optional tools to improve the user experience on our website and to offer you more functions (“functional tools”). While these are not strictly necessary for the basic functions of the website, they can bring significant benefits to visitors, particularly in terms of user-friendliness and the provision of additional communication, display or payment channels. This may include, in particular, the integration of external content such as maps and videos as well as the login via an existing account from social networks. For Detailed information please refer to our Cookie Policy.

V. Social Media

We maintain online presences in social media in order to communicate there with customers and interested parties, among others, and to provide information about our products and services. As part of the operation of our online presences, it is possible that we may access information such as statistics on the use of our online presences provided by the social networks. Please see the list below for details and links to the social network data that we, as operators of the Online Presence, can access. The collection and use of these statistics is generally subject to joint responsibility. Where this applies, the relevant agreement is listed below.

The legal basis for data processing is Art. 6 (1) lit. f GDPR, based on our legitimate interest in effective information and communication with users, and Art. 6 (1) lit. b GDPR, in order to stay in contact with and inform our customers and to carry out pre-contractual measures with interested parties.

For the legal basis of the data processing carried out by the social networks under their own responsibility, please refer to the data protection notices of the respective social network. The links below also provide you with further information on the respective data processing and the options to object.

 

VI. How long do we keep your personal data?

In principle, we store personal data only as long as necessary to fulfill the purposes for which we collected the data.  The data will be deleted after the purpose has been fulfilled, unless we still need the data until the expiry of the statutory limitation period for evidence purposes for claims under civil law, due to statutory retention obligations or there is another legal basis under data protection law for the further processing of your data in the specific individual case.

For evidentiary purposes, we must retain contractual data in particular for three years from the end of the year in which the business relationship with you ends. Any claims become statute-barred at this point at the earliest in accordance with the standard statutory limitation period. Even after this, we still have to store some of your data for accounting reasons. We are obliged to do so because of legal documentation obligations that may arise from the German Commercial Code, the German Fiscal Code, the German Banking Act, the German Money Laundering Act and the German Securities Trading Act. The periods specified there for the retention of documents are two to ten years.

VII. Your data protection rights

You have certain rights with respect to data processing at FocusIn Ventures. Please bear in mind that this is a general overview intended to aid your understanding, and that the exact scope of your rights is of course based on the legal provisions of Art. 15 to 22 GDPR: Right to information about which of your data we process (Art. 15 GDPR); Right to have your data rectified (Art. 16 GDPR); Right of erasure (Art. 17 GDPR); Right to restriction of the processing of your data (Art. 18 GDPR); Right to data portability (Art. 20 GDPR).

If your data is processed by us on the basis of Art. 6 (1)(f) GDPR (legitimate interests), you have the right to object on grounds relating to your particular situation. In addition, you have the right to object to the promotional use (direct marketing) of your data at any time. In this case, your personal data will no longer be processed for these purposes. Also, you have the right to revoke your consent – if you have given consent in certain cases – to the processing of your data at any time (Article 7 (3) GDPR). The revocation does not affect the lawfulness of the processing carried out until the revocation of consent.

You also have a right to lodge a complaint to any data protection supervisory authority. The data protection authority responsible for FocusIn Ventures is “Berliner Beauftragte für Datenschutz und Informationsfreiheit”, Alt-Moabit 59-61, 10555 Berlin

VIII. Updates to this Policy

We occasionally update this privacy statement, for example, when we adapt our website or when legal or regulatory requirements change.

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