Data Protection Statement

We at Firstbird, i.e. firstbird GmbH, Hietzinger Hauptstrasse 34, 1130 Vienna, Austria (“Firstbird”) take our data protection obligations very seriously. Thus, it is important to us to protect your privacy and personal data. We process your personal data in accordance with applicable data protection legislation.

The website “www.firstbird.eu” (the “Website”) is run by firstbird. Below, we should like to explain to you which personal data are collected when you visit our Website by whom and how these data are used. In this context, it is important to note that the Website consists of two different areas: an open area accessible to users without login (see A.) and a closed user area which you have to log in to for access (see B.).

Area A: Open Area on the Website

The open area on the Website, which can be accessed without registration (“Open Area”), contains information and serves to market the products of firstbird.

Area B: Closed User Area of the Website (Recommendation Platform)

As customers (“Customers”) of firstbird, enterprises may create their own recommendation platform on the Website and invite you to register on the platform as a so-called Talent Scout (“Closed User Area”). When you have registered and logged in, you will be using the Customer’s recommendation platform. In this context, firstbird is solely acting as a service provider commissioned by the Customer (doing what is called contract data processing).

Depending on the area, responsibilities differ.

A – Use of the Open Area on the Website

In respect of the open area on the Website, firstbird is the party responsible within the meaning of data protection law. Below, we should like to explain which personal data firstbird will collect during your visit to the open area of the Website and how such data are used by Firstbird. Please note that this Data Protection Statement may not cover any websites of other providers which are linked to this Website.

1. Collection and Processing of Personal Data

“Personal data” are defined as all details about personal or factual circumstances of an identified or identifiable physical person. This includes information such as your name, address or phone number.

Purely statistical/aggregated information which cannot be linked with you, such as the number of site users are not considered to be personal data.

In the open area of the Website firstbird will collect the following personal data:

If you do not register or log on to the Website or otherwise transmit information, firstbird – like every other website – will only collect the data which your browser transmits automatically to enable you to visit the Website. Such so-called usage data are recorded in server logfiles.

1.1 Usage Data Automatically Collected on Website Visits

These data are as follows:

o IP address (Internet Protocol address) of the computer from which you access the Website;

o Internet address of the website which the Website is accessed from (the so-called referrer URL); the name of the service provider through which the platform is accessed;

o the name of the files or information retrieved;

o date and time as well as duration of retrieval;

o data quantity transmitted;

o operating system and information about the Internet browser used on the computer from which the Website is accessed;

o http status code (e.g. “query successful” or “requested file not found”).

IP addresses and/or logfile information of the above type will be stored by firstbird for a limited period of time for reasons of security (e.g. to identify attempted attacks).

1.2 Newsletter

You may register to subscribe to our newsletter by e-mail. In case of registration, we will collect the following data:

o e-mail,

o first name and last name,

o your consent.

The newsletter may be unsubscribed any time via support@firstbird.eu.

1.3 Other Personal Data

Apart from the above usage data, firstbird will collect and process personal data if you make them available to us, e.g. when you contact us through the e-mail or chat function, download e-books or purchase one of our Services. In this context, the personal data collected may include in particular:

o first name, last name,

o (company) address data (street, building number, postal code, place),

o e-mail address,

o the content of your message to us and

o position and enterprise.

2. The Purpose of Using Personal Data

Apart from the purposes described above, firstbird will use your personal data for the following purposes (always only to the extent required):

o the technical administration of the Website;

o the prevention of misuse/fraud;

o customer contact/administration;

o advertising for ourselves and other, to the extent permitted by law; and

o to improve our Internet services.

3. Passing Data on to Third Parties; Involvement of Service Providers

Personal data of Website users who did not log in and customers using our Services will as a matter of principle only be passed on to third parties to the extent that this is necessary for contract management or if express consent was given. All data firstbird collects and stores in the closed area within the recommendation platform are explicitly excluded from transmission (this includes any and all data of customers (enterprises) and users (administrators, recruiters, talent scouts).

Firstbird may, however, use external service providers to collect and process as well as use personal data (such service providers not being third parties within the meaning of data protection legislation). These are contractors which process data only for the purposes determined by firstbird (not for their own, further purposes) and which act on the instructions of firstbird (firstbird has entered into so-called contract data processing agreements with all contractors to ensure this).

In this context, it is important for us to stress that service providers must not pass your data on to third parties (or data processing subcontractors) without the consent of firstbird. Personal data will only be transmitted to authorities or other governmental institutions to the extent that this is permitted under data protection legislation and required by mandatory provisions of national law.

4. Cookies and Similar Technologies

4. 1 General Information about Cookies

The Website uses so-called cookies to make website use as convenient as possible for you. Cookies are text files which are transmitted via the Internet browser while the service is accessed. Cookies are automatically stored into your terminal device. Cookies help us to make our Internet service more user-friendly. It is possible for you to disable cookies in the settings of your Internet browser; this may however result in functional impairment when using our Internet service. Therefore, we recommend permitting our cookies. You can always delete cookies already stored via your Internet browser.

For further information about cookies, please visit: http://www.allaboutcookies.org/ge/. By going to www.youronlinechoices.eu you can find out more about online advertising and data protection.

By using our Website you consent to our use of cookies as described above.

4. 2 Google Analytics

To be specific, our Website uses the so-called “Google Analytics” cookie. Google Analytics is a web analyse service of Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA, referred to as “Google” below). Google Analytics uses cookies which are stored on your terminal device and make it possible to analyse the way in which you use our Website.

Google will use this information on the instruction of firstbird to analyse your use of the platform, draw up reports about Website activities and render other services regarding Website use and Internet use to firstbird. The IP address transmitted to Google Analytics through your Internet browser is not combined with other data by Google, it is anonymised by shortening it (on this Website, Google Analytics was extended by the code “gat._anonymizeIp()” to ensure that IP addresses are anonymised when they are collected (this is called “IP masking”). The data collected through Google Analytics are not used for the personal identification of visitors to this Website by firstbird, nor are these data combined with personal data. It is possible for you to disable cookies in the settings of your Internet browser; this may however result in functional impairment when using our Internet service (see also clause 4.1 above).

You can also prevent the transmission of your platform use data as generated by the cookie and the processing of these data by Google downloading and installing an add-on for your current Internet browser; please click on: https://tools.google.com/dlpage/gaoptout?hl=de.

If you are using different Internet browsers (e.g. Internet Explorer and Mozilla Firefox) on your terminal devices, you should download the add-on for each Internet browser you use to visit the Website.

For general information about Google Analytics and data protection in Google, please visit this Google website by clicking on the link: http://www.google.com/intl/de/analytics/privacyoverview.html.

5. Consent

If we collect and process your data on the basis of your consent, we will inform you outside this Data Protection Statement and obtain your consent independently thereof (e.g. in the context of direct marketing/newsletter). You may revoke your consent to the storage and processing of your personal data any time. For this purpose, please send an e-mail to our customer support team: support@firstbird.eu.

B – Use of the Recommendation Programme (Closed Area)

As regards use of the closed area on this Website, the so-called recommendation programme (“Firstbird Recommendation Platform”), the relevant content provider/customer (e.g. your employer) who gives you access to the Firstbird Recommendation Platform (“Provider” or “Customer”) acts as the party responsible within the meaning of data protection legislation. In this context, firstbird is merely a service provider, collecting and processing data on behalf of the content provider, based on the latter’s requirements and instructions under a contract data processing agreement. Below, we should like to explain in greater detail which personal data are collected as the Talent

Scout platform is accessed and how these data are used. Please note that this Data Protection Statement may not cover any websites of other providers which are linked to this Website.

For further information, please turn to the content provider who invited you to join the recommendation programme you (wish to) use.

1. Collection and Processing of Personal Data

In particular, the following personal data will be collected when you use the Talent Scout platform:

a) Applicants:

If you are an applicant, a job vacancy was indicated to you by a logged-in user of the respective Firstbird Recommendation Platform. Once you decide to apply for the job via the Firstbird Recommendation Platform, the following data pertaining to you will be collected and processed:

First name

Last name

E-mail address

Phone number

CV

Application photo

Approach and visibility: If an applicant applies for a job, the data collected will bemade available to the enterprise responsible for the job advertisement. The data are visible for all Recruiters and Company Administrators. Moreover, part of the data (first name, last name and application photo are exclusively visible to the Talent Scout who shared the advertisement for the job applied for by e-mail, link oder or social network.

b) Talents Scouts:

If you are a Talent Scout, you have been invited by an enterprise (the relevant content provider on the Firstbird Recommendation Platform) to disseminate information about the job vacancies in the enterprise and to recommend potential applicants. The following data pertaining to you will be collected via registration and your personal settings:

First name

Last name

E-mail address

Profile photo

Location

Special field

Social networks you are a member of

(If you are a member of a social network and provided that you give your consent, a job vacancy can be shared via the Firstbird Recommendation Platform and the newsfeed of the network under your name. No further information regarding your social network account will be transmitted.)

Approach and visibility: The data will be made available to all registered users within one account. The data are visible for the Recruiters responsible and all registered Talent Scouts of the enterprise. Moreover, part of the data (first name, last name, profile photo) is visible for potential applicants who click on a job advertisement shared earlier by the Talent Scout via e-mail, link or social network.

c) Recruiters & Company Administrators:

If you are a Recruiter and Company Administrator (content provider), you are responsible for managing the Firstbird Recommendation Programme. You will invite Talent Scouts, prepare job advertisements and manage the recommendations. The following data pertaining to you will be collected via registration and your personal settings:

First name

Last name

E-mail address

Profile photo

Location

Special field

Approach and visibility: The data will be made available to all users within this account. The data are visible for the users of the Recommendation programme (other Recruiters, Company Administrators and Talent Scouts) as well as the recipients of job advertisements in which you are mentioned as a contact.

d) Recommendation and Assessment Data

Recommendation and assessment data are data which are collected from applicants by Talent Scouts during the recommendation process and by Recruiters from applicants during the assessment process.

aa) Applicant’s Recommendation Data:

Type of recommendation (positive, neutral, negative), connection between applicant and Talent Scout, reason for recommendation.

Approach and visibility: The recommendation data pertaining to an applicant are exclusively made available to Recruiters and Company Administrators of the enterprise so that they can process the application.

bb) Applicant’s Assessment Data:

Assessment by Recruiter (*, **, ***), hiring of applicant or negative reply to applicant, stating reason why negative reply was given.

Approach and visibility: The assessment data of an applicant will be made available to Recruiters and Company Administrators of an enterprise for the purpose of tracking the applicant’s history. Moreover, the Talent Scout responsible for the applicant’s job application is informed about the applicant’s assessment and application status.

e) Individual Usage Data and Success Statistics

Individual usage and success statistics are defined as data which the Talent Scout collects during the dissemination and recommendation process. Activities pursued and success rates are stored and become visible for users.

aa) Usage Data:

Talent Scout shares job advertisement via social network

Talent Scout generates application

Talent Scout recommends applicant

Talent Scout gets a three-star rating for a recommendation

Talent Scout follows other Talent Scout

Approach and visibility: These actions are visible to all Talent Scouts following one particular Talent Scout in the Activity Stream. At the same time, these actions are visible to all Recruiters and Company Administrators assigned to the job vacancy on hand.

Talent Scout registers on Firstbird Recommendation Platform.

Applicant of a Talent Scout is hired.

Approach and visibility: These actions are visible to all registered users within this Account.

bb) Success Statistics:

Number of Talent Scouts followed by a Talent Scout

Number of Talent Scouts following a Talent Scout

Total number of points in the Recommendation Programme

Level resulting from total number of points

Ranking based on total number of points in comparison with all other Talent Scouts registered within this Account

Approach and visibility: These success statistics are visible to all registered users within one Account.

Number of job advertisements and social networks used for sharing

Number of applications generated

Number of recommendations given

Number of recommendations given a three-star rating

Number of applicants hired

Approach and visibility: These success statistics are only visible to each Talent Scout on his/her personal dashboard.

f) General Usage Data and Success Statistics

General usage and success statistics are data which are collected to reflect the recommendation and dissemination activities within a business account. These data help the enterprise obtain an overview of the success of its Recommendation Programme and to further optimise its use.

Percentage of job advertisements shared and breakdown according to social networks

Total number of applications generated

Total number of recommendations given

Total number of the applications rated *, ** and ***

Total number of applications received and applicants hired

Total number of users invited and registered

Total value of bonuses paid

Total number of Talent Scouts per location and department

Approach and visibility: General usage and success statistics are visible to Recruiters and Company Administrators within one business account.

g) General Information about the Use of External Social Networks:

Talent Scouts/Recruiters who are invited to the respective Firstbird Platform by an enterprise can create links to social networks via the Firstbird settings. For this purpose, they are rerouted to the website of the respective social network, where they have to consent to the release of rights to the relevant provider. The data and access authorisations assigned are shown to the customer in the consent query. These interactions are always subject to the privacy settings of the users for the respective social network.

B. Miscellaneous

1. Data Safety and Security

firstbird is taking various technical and organisational measures (“Safety and Security Measures”) to protect your data from loss, destruction, access, tampering and unauthorised access by third parties. Our Safety and Security Measures conform to market standards and are continuously improved in accordance with technical developments.

2. Data Protection Questions/Contact

If you have any questions regarding the processing of your personal data and if the above area A (open area), which firstbird is responsible for, is concerned, please contact the following e-mail address: support@firstbird.eu.

If the data concerned are within the responsibility of the content provider (i.e. data collected and processed in the context of the Firstbird Recommendation Programme, see Area B – closed area), please contact the content provider for the Recommendation Platform (e.g. your employer).

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