Privacy policy

Introduction

At alphaheads AG (“alphaheads”, “We”, “Our”, or ”Us”), We take the protection of Your personal data very seriously. Personal data refers to any information relating to an identified or identifiable natural person, including name, address, email addresses, IP address and user behavior. The applicable data protection law depends on various factors, including the country in which the affected data subject is based. As the European General Data Protection Regulation (“GDPR”) is one of the most comprehensive sets of regulations, We took GDPR as a basis for this Privacy Policy.

This Privacy Policy applies to the processing of personal data by alphaheads. Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

We provide a service called “My Headhunter”, which connects headhunters, consultancies, candidates and companies (“My Headhunter Platform”). Please refer to Our general terms of use for the My Headhunter Platform (“Terms of Use”) for detailed information on the scope of this service. Any processing of Your data within the scope of the My Headhunter Platform as well as the provision of Our website https://www.my-headhunter.com/ (the “Services”) is carried out exclusively in accordance with the following Privacy Policy.

We act as controller

We act as the controller for the processing of personal data for which We determine the purpose and means of processing. Our contact details are Gubelstrasse 19, CH-6300 Zug, contact@my-headhunter.com.

Data Protection Officer

If You have any questions about data protection or the processing of Your personal data, or if You wish to exercise Your rights as a data subject, You can contact Our Data Protection Officer at any time using the following details:

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Collecting and processing data

How We collect and process Your personal data while visiting Our website

As with most technology services delivered over the internet, Our servers automatically collect information when You access or use the My Headhunter Platform and store this information temporarily in so-called log files (“Technical Data”). Technical Data include especially the IP-address and name of the access provider, the address of the web page that You visited before accessing the My Headhunter Platform, the operating system, the browser type and settings, information about browser configuration and plugins and language preferences. This data is processed by Us to ensure a smooth connection and a comfortable use of the My Headhunter Platform, to analyse the security and stability of the My Headhunter Platform and for other administrative and statistical purposes.

The legal basis for processing Technical Data is Our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR) resulting from the need to provide a convenient and user-friendly Services. The collected data will in no case be used to draw any conclusion to Your identity. The data is deleted when it is not required for the mentioned purposes anymore and no other legal grounds for processing the data apply.

How We collect and process Your Account Data

When You register with and use the My Headhunter Platform, We have to collect and process certain personal data as Your login details and certain contact and billing information (“Account Data”). Account Data include especially first and last name, e-mail address, password, basis profile information (e.g, role as client/candidate /consultant/consultancy, company name, optional: billing information (e.g., billing period, tax numbers, preferred currency and payment details (e.g., credit card information).

When You register with and use the My Headhunter Platform, We will process the Account Data in order to conclude and perform a contract with You (Art. 6 para. 1 sentence 1 lit. b GDPR). Please refer to Our Terms of Use or any separate agreement that You may have concluded with Us for more information.

During the contractual relationship, We may also process Your personal data (e.g. email address, address, products purchased by You, etc.) in order to send You contract-related information.

If You select a fee-based Service, We process Your payment details such as credit card and bank details for the purpose of payment processing and invoicing in accordance with the method of payment You choose. Your payment details will be transferred, to the extent needed, along with other required data for processing the transaction, including invoicing and debt collection, where applicable, to providers such as credit card issuers, payment providers and debt collection providers, and processed there, or the data will be collected directly by these providers. In order to process payments, We cooperate with Our authorized payment service provider Payrexx AG. We concluded a data processing agreement with Payrexx AG which allows Payrexx AG to process the data solely in accordance with Our instructions and not for its own purposes.

We will delete Your Account Data when the purpose for processing it no longer applies. This may be the case when the contract is terminated. Even after termination of Your contract with Us, however, it may be necessary to continue to store personal data for as long as is necessary to fulfil contractual or legal obligations. The corresponding data will be deleted as soon as the contractual or legal obligation no longer exists.

How We process further Data You provide to Us

As part of the features of the MyHeadhunter Platform You may provide Us with additional personal data that We will process to fulfil Our contract with You based on the Terms of Use. This processing may include personal data contained in Your CV, any certificates, references, letters, salary details and other information that You provide (“Application Data”).

The processing of Application Data is required for the performance of the contract with You (Art. 6 para. 1 sentence 1 lit. b GDPR). Please refer to Our Terms of Use or any separate agreement that You may have concluded with Us for more information.

Additionally, We may also process this Application Data based on Our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR) in efficiently supporting You in the application process. Your data will be deleted when it is no longer needed for the purposes mentioned above and there is no other legal basis for processing the data.

How We collect and process Your Data, if You access the Talent Pool

When You register with the My Headhunter Platform as a candidate or apply for a position, You can actively opt in to having Your profile included in Our searchable talent pool (“Talent Pool”). We collect and process Your personal data for inclusion in the Talent Pool only if You have provided Your separate and explicit consent (Art. 6 para. 1 sentence 1 lit. a GDPR). Your consent is voluntary and You can withdraw Your consent at any time with effect for the future by sending an email to [XXX].

If You consent to being included in the Talent Pool, the following categories of data will be processed for the purpose of candidate search by approved headhunters and consultancies: name, basic profile data, skills, experience, uploaded documents (e.g. CV), and other information You provide in Your profile. Only headhunters and consultancies will be granted access, and they may use Your data to approach You with suitable opportunities.

You may withdraw Your consent to being included in the Talent Pool at any time. Upon withdrawal, Your profile will be immediately removed from the searchable Talent Pool and will no longer be visible to headhunters and consultancies. Withdrawal will not affect Your continued use of other Services on the My Headhunter Platform. Your Talent Pool data will also be deleted if Your My Headhunter account is deleted.

How We collect and process Your Data, if You contact Us

When You contact Us via Our contact forms (contact form or shortlist request) or by email, We process Your personal data to the extent necessary to respond to Your contact request and to carry out the actions requested. This processing includes Your contact details, messages and communication data (e.g. request times). We process this data to assist You and to respond to Your request.

The legal basis is Our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR) in efficiently processing Your requests. Your data will be deleted when it is no longer needed for the purposes mentioned above and there is no other legal basis for processing the data. This will normally be the case when Your enquiries have been fully dealt with and the matter in question does not require further retention of the data.

Tracking

When You access and use Our Services, We utilise mechanisms for collecting, processing and storing certain data which We outline in the following paragraphs.

Matomo

We use the web analytics software Matomo to analyze user behavior in connection with Our Services. Matomo is hosted on Our own servers; no usage data is transferred to third parties. Matomo enables Us to evaluate anonymized usage statistics in order to optimize Our Services, and user experience. We operate Matomo in a privacy-friendly configuration that does not use cookies and does not store complete IP addresses. The legal basis for this data processing is Our legitimate interest in user analysis and continuous improvement of Our Services (Art. 6 para. 1 sentence 1 lit. f GDPR). No personally identifiable information will be used to create individual profiles, and We do not merge usage data with other personal data.

Sentry

We use the error monitoring tool Sentry to ensure the stability and security of Our Services. Sentry is operated on Our own servers. Sentry helps Us to identify and analyse errors or technical interruptions, so that We can respond quickly and efficiently to any disruptions and continuously improve Our Services. All data collected by Sentry is limited to technical information (such as timestamps, error messages, browser and device type, operating system, and, where applicable, anonymized IP addresses) and is solely used for troubleshooting and safeguarding the My Headhunter Platform’s functionality. We do not use Sentry to create individual user profiles or to track user behavior. The legal basis for this data processing is Our legitimate interest in ensuring the technical security and reliability of Our Services (Art. 6 para. 1 sentence 1 lit. f GDPR).

How We process Your data when You use the Social Login

In order to make the My Headhunter Platform easy to use, We use a so-called social login feature as descried in Our Terms of Use (“Social Login”). This enables You to log in to Our My Headhunter Platform with the login data of a single sign-on provider and thus not have to maintain any further login data. The use of a Social Login requires that You have already created an existing user account with the single sign-on provider, for example a social network. In order to log in with the Social Login, You must click on the Social Login button on the My Headhunter Platform login screen and, when redirected to the login screen of the single sign-on provider, enter Your login data of the Social Login.

To perform the authentication, We receive certain personal data about You. Among other things, this includes a user ID together with information that You are registered with the ID with the respective single sign-on provider. We receive this ID exclusively for the purpose of authentication, i.e. any processing on Our part that goes beyond authentication is not permitted. Whether additional data is transmitted to Us, and if so, which, depends on the single sign-on provider used, Your account settings made with this provider, and any data releases selected as part of the authentication process. Which data We receive from the respective single sign-on providers can vary. As a rule, however, it is the email address and the user name.

The legal basis for processing the above-mentioned data is Our legitimate interest that follows from the need to provide You with an uncomplicated login to use the My Headhunter Platform (Art. 6 para. 1 sentence 1 lit. f GDPR). The data is deleted when it is not required for the mentioned purposes anymore or other legal grounds for processing the data apply.

Your obligation to provide data

In principle, You are not obliged to provide Us with data. However, failure to provide some personal data (e.g. contact details) would mean that the contract with You could not be concluded. Furthermore, certain information is collected automatically when using the Services (e.g. Technical Data).

We transfer personal data

We transfer personal data to and from Switzerland. Where the GDPR applies, this is considered a transfer to a third country. However, Switzerland has a level of data protection comparable to that of the European Union, based on the European Commission's adequacy decision.

When We disclose Your data to third parties

Your personal data will not be transferred or disclosed to third parties for purposes other than the ones mentioned in this Privacy Policy.

Your personal data will only be disclosed to third parties in case You expressly consented to the disclosure, or the disclosure is necessary for compliance with a legal obligation that We are subject to. We can also disclose Your personal data if the processing of the personal data is legally admissible and necessary for the performance of a contract with You. Moreover, We disclose Your personal data if it is required for the establishment, exercise or defence of legal claims or this is required for legal representation while there is no indication to assume that You have a prevailing legitimate interest for the non-disclosure of Your personal data.

Your rights

Right to object

You may object at any time, on grounds relating to Your particular situation, to the processing of Your personal data based on the legitimate interests pursued by Us or a third party. The processing of Your personal data will then be discontinued unless We can demonstrate compelling legitimate grounds for the processing that override Your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.

Your rights You have as a data subject

In all cases where We process Your personal data, You have the following rights:

You have the right to request information about the processing of Your personal data (right to information).
You can request access to Your personal data and a copy of Your personal data (right to access).
You may request that We supplement, correct, or delete Your personal data (right to rectification, and right to erasure); the right to rectification also includes the right to have incomplete personal data completed, including by means of a supplementary statement.
You can request that We restrict the processing of Your personal data (right to restriction of processing).
You may request to receive Your personal data that You have provided to Us in a structured, commonly used and machine-readable format and to transmit it to another controller without hindrance or to have it transmitted to another controller (right to data portability).
You have the right to lodge a complaint with a supervisory authority regarding the processing of Your personal data. You have the right to lodge a complaint in the (EU member) state of Your residence, Your place of work, and/or the place of the alleged infringement. In other words, You can choose the supervisory authority to which You wish to submit Your complaint from the above-mentioned locations. The supervisory authority to which You lodge Your complaint will inform You of its status and results, including the possibility of a judicial remedy.
You have the right to withdraw Your consent to the processing of Your personal data at any time. The exercise of the right of withdrawal does not affect the lawfulness of the processing in the past.

Changes to this Privacy Policy

We reserve the right to update this Privacy Policy from time to time to reflect changes in Our processing activities.

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