Luvent Consulting GmbH (also referred to as “Luvent”, “we” and “us”) places great importance on the privacy of experts, individuals from organisations (e.g. donors, beneficiaries, consultancy organisations, suppliers, etc) and other individuals with whom we are in contact with (e.g. website visitors, prospective clients, potential experts, etc). The processing of personal data therefore always takes place under the applicable data protection regulations (including but not limited to the General Data Protection Regulation (the “GDPR”).
2. What kind of personal information do we collect?
Depending on the relevant circumstances we may collect some or all of the information listed below.
2.1. Data from experts
- Age/date of birth
- Marital status
- Contact details
- Education details
- Employment history
- Emergency contacts and details of any dependants
- Referee details
- Nationality/citizenship/place of birth
- A copy of your passport/identity card
- Financial information (where we need to carry out financial background checks)
- Social security number (or equivalent in your country) and any other tax-related information
- Details of any criminal convictions if this is required for a role that you are interested in applying for
- Details about your current remuneration, pensions and benefits arrangements
- Information on your interests and needs regarding future employment, both collected directly and inferred
- Extra information that you choose to tell us
- Extra information that your referees choose to tell us about you
- Extra information that our clients may tell us about you, or that we find from other third-party sources such as job sites
Please note that the above list of categories of personal data we may collect is not exhaustive.
2.2. Data from individuals working in organisations (donors, beneficiaries, consultancy organisations, suppliers)
- Telephone number
- Email address
- Contact history
2.3. Data from website visitors
We collect a limited amount of data from our website visitors which we use to help us to improve your experience when using our website and to help us manage the services we provide. This includes information such as how you use our website, the frequency with which you access our website, your browser type, the location you view our website from, the language you choose to view it in and the times that our website is most popular.
Please review our cookies policy, section 11 (“Cookies policy”), to learn more. If you contact us via the website, for example by using the contact form, we will collect all information that you provide to us, for example, your name and contact details.
2.4. Data from prospective clients and potential experts
- Telephone number
- Email address
3. How do we collect your personal data?
We collect expert personal data in three primary ways:
3.1. Personal data that experts provide to us
These may include:
- Entering your details on the Luvent website or via an application form, as part of the registration process;
- Leaving a hard copy CV at Luvent’s office
- Emailing your CV to a Luvent consultant or being interviewed by them
- Applying for jobs through a job aggregator, which then redirects you to Luvent’s website
3.2. Personal data that we receive from other sources
We also receive personal data about experts from other sources. Depending on the relevant circumstances and applicable local laws and requirements, these may include personal data received in the following situations:
- Your referees may disclose personal information about you
- Our clients may share personal information about you with us
- We may obtain information about you from searching for potential experts from third-party sources, such as LinkedIn and other job sites
- If you ‘like’ our page on LinkedIn or ‘follow’ us we will receive your personal information from those sites
3.3. Personal data that we collect automatically
To the extent that you access our website we may also collect your data automatically or through you providing it to us. For more information please review section 2.3 (“Data from website visitors”).
Data may be provided by clients and experts directly, however, we may also collect it via third-party platforms such as LinkedIn or Developmentaid.org. Client and expert must provide written consent to any further data collected by Luvent before it can make any use of it.
When you visit our website there is certain information that we may automatically collect, whether or not you decide to use our services. This includes your IP address (anonymous), the date and the times and frequency with which you access the website and the way you browse its content. We will also collect data from you when you contact us via the website, for example by using the contact form.
You have the choice to opt out of your data being stored when using the contact form, however, the reason we store data is to keep track of contact requests. Moreover, emails are not always 100% reliable as there are multiple points at which an email could be blocked or at which delivery fails.
We collect your data automatically via cookies, in line with cookie settings in your browser. If you are also a candidate or client of Luvent, we may use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies, including how we use them and what choices are available to you, please review section 11. (“Cookies Policy”).
4. Why and how do we use the data collected?
4.1. Data from experts
We generally use data from experts in four ways:
a) Recruitment Activities
Our intention is to find relevant experts to be proposed and contracted on tenders or awarded projects, always with the expert’s prior consent. We’ve listed below various ways in which we may use and process your personal data for this purpose. Please note that this list is not exhaustive.
- Collecting your data from you and other sources, such as LinkedIn;
- Storing your details (and updating them when necessary) on our database, so that we can contact you in relation to recruitment;
- Providing you with our recruitment services and to facilitate the recruitment process;
- Assessing data about you against vacancies which we think may be suitable for you;
- Sending your information to clients, in order to apply for projects or to assess your eligibility for job opportunities;
- Enabling you to submit your CV and apply online for jobs or to subscribe to alerts about projects we think may be of interest to you;
- Carrying out our obligations arising from any contracts entered into between us;
- Carrying out our obligations arising from any contracts entered into between Luvent and third parties in relation to your recruitment;
- Facilitating our payroll and invoicing processes;
- Carrying out satisfaction surveys;
- Verifying details you have provided, using third party resources, or to request information (such as references, qualifications and potentially any criminal convictions, to the extent that this is appropriate and in accordance with local laws);
- Complying with our legal obligations in connection with the detection of crime or the collection of taxes or duties; and
- Processing your data to enable us to send you targeted, relevant marketing materials or other communications which we think are likely to be of interest to you.
We may use your personal data for the above purposes if we deem it necessary to do so for our legitimate interests. If you want to know more about what this means, please review section 12.1 (“Legitimate interests”). If you do not agree to this, in certain circumstances you have the right to object and can find out more about how and when to do this in section 8.1 (“Right to object”)
b) Marketing activities
We may periodically send you information that we think you may find interesting, or to ask for your help with connecting other candidates with jobs. In particular, we may wish to use your data for the purposes listed below, where appropriate and in accordance with any local laws and requirements. Please note that this list is not exhaustive.
- to enable us to develop and market other products and services;
- to display promotional excerpts from your details on Luvent’s website(s) as a success story (only where we have obtained your express consent to do so).
We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the collection of data via cookies, and the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in or soft-opt-in.
Soft opt-in consent is a specific type of consent which applies where you have previously engaged with us (for example by submitting a job application or CV, or registering a vacancy to be filled), and we are marketing other recruitment-related services. Under ‘soft opt-in’ consent, we will take your consent as given unless or until you opt out. For most people, this is beneficial as it allows us to suggest other jobs to you alongside the specific one you applied for, significantly increasing the likelihood of us finding you a new position.
If you do not agree with our marketing approach, you have the right to withdraw your consent at any time and can find out more about how to do so in section 8.2 (“Right to withdraw consent”). We want to let you know that even if you have opted out from our marketing communications through our preference centre, it is possible that your details may be recaptured through public sources in an unconnected marketing campaign. We will try to make sure this doesn’t happen, but if it does, we’re sorry. We’d just ask that in those circumstances you opt out again.
c) To help us to establish, exercise or defend legal claims
In more unusual circumstances, we may use your personal data to help us to establish, exercise or defend legal claims.
Although at present all our recruitment activities involve human-decision making during the process, we may in the future use fully automated technologies such as expert systems or machine learning to complete a candidate selection process from end-to-end, where appropriate and in accordance with any local laws and requirements.
Where appropriate, we will seek your consent to carry out some or all of these activities. If you do not provide consent to profiling, your application will continue to be reviewed manually for opportunities you apply for, but your profile will not be automatically considered for alternative roles.
You have the right to withdraw that consent at any time and can find out more about how to do so in section 8.2 (“Right to withdraw consent”).
4.2. People whose data we receive from experts and staff, such as referees and emergency contacts
We will only use the information that our expert gives us about you for the following purposes:
- If our experts or staff members put you down on our form as an emergency contact, we’ll contact you in the case of an accident or emergency affecting them; or
- If you were put down by our experts or a prospective member of staff as a referee, we will contact you in order to take up a reference. This is an important part of our experts’ quality assurance process and could be the difference between the individual getting a job or not.
- If you were put down by our experts or a prospective member of staff as a referee, we may sometimes use your details to contact you in relation to recruitment activities that we think may be of interest to you, in which case we will use your data for the same purposes for which we use the data of clients.
We may use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to find out more about what this means, please review section 12.1 (“Legitimate interests”).
4.3. Data of individuals that work in organisations
We use your data for the purpose of contacting you for cooperation opportunities or running projects.
4.4. Website visitors
We use your data to help us to improve your experience of using our website. If you would like to find out more about cookies, including how we use them and what choices are available to you, please review section 11 (“Cookies policy”).
5. Who do we share your personal data with?
Where appropriate, we may share your personal data, in various ways and for various reasons, with the following categories of people:
- Any of our group companies;
- Individuals and organisations who hold information related to your reference or application to work with us, such as current, past or prospective employers, educators and examining bodies and employment and recruitment agencies;
- Tax, audit, or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation);
- Third party service providers who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, technical support functions and IT consultants carrying out testing and development work on our business technology systems);
- Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
- In the case of experts: potential clients, and other recruitment agencies/organisations to increase your chances of finding employment opportunity; consortium partners for specific projects and third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws;
- If Luvent merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company.
The information you provide may be transferred outside your country to another country that does not have similar data protection legislation and may provide a lower level of protection for your information. By providing us with your information you consent such transfers.
If you do not agree and would like to withdraw consent, please review section 8.2 (“Right to withdraw consent”).
6. How do we protect your personal data?
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. We use HTTP Secure (HTTPS) for secure communication on our website. In HTTPS the communication protocol is encrypted using Transport Layer Security (TLS).
If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Details of how to contact us can be found in section 15. (“Reasons and how to contact us”).
7. How long do we keep your personal data for?
Luvent does not keep personal data for longer than is necessary for the purposes for which it was collected and processed.You are able to request deletion of all your data at any time, review section 15 (“Reasons and how to contact us”) to gain information on how best to contact us.
8. How can you access, amend or take back the personal data that you have given to us?
One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.
To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
8.1. Right to object
This right enables you to object to us processing your personal data where we do so for one of the following four reasons: (i) our legitimate interests; (ii) to enable us to perform a task in the public interest or exercise official authority; (iii) to send you direct marketing materials; and (iv) for scientific, historical, research, or statistical purposes.
The “legitimate interests” and “direct marketing” categories above are the ones most likely to apply to our experts, website users, clients and other individuals in contact with us. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless:
- we can show that we have compelling legitimate grounds for processing which overrides your interests; or
- we are processing your data for the establishment, exercise or defence of a legal claim.
If your objection relates to direct marketing, we must act on your objection by ceasing this activity.
8.2. Right to withdraw consent
Where we have obtained your consent to process your personal data for certain activities, you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.
8.3. Data Subject Access Requests (DSAR)
You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is “manifestly unfounded or excessive”. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
8.4. Right to erasure
You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:
- the data are no longer necessary for the purpose for which we originally collected and/or processed them;
- where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;
- the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);
- it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or
- if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
We would only be entitled to refuse to comply with your request for one of the following reasons:
- to exercise the right of freedom of expression and information;
- to comply with legal obligations or for the performance of a public interest task or exercise of official authority;
- for public health reasons in the public interest;
- for archival, research or statistical purposes; or
- to exercise or defend a legal claim.
When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
8.5. Right to restrict processing
You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.
The circumstances in which you are entitled to request that we restrict the processing of your personal data are:
- where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;
- where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;
- where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and
- where we have no further need to process your personal data but you require the data to establish, exercise or defend legal claims.
If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves a disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.
8.6. Right to rectification
You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves a disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
8.7. Right to lodge a complaint with a supervisory authority
You also have the right to lodge a complaint with your local supervisory authority. If you would like to exercise any of these rights or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found in section 15. (“Reasons and how to contact us”). Please note that we may keep a record of your communications to help us resolve any issues which you raise. You may ask to unsubscribe from job alerts at any time. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.
9. Who is responsible for processing your personal data on Luvent’s website?
Our Berlin office is responsible for processing your personal data:
Luvent Consulting GmbH
Alexander von Brühl-Pohl
10. How do we store and transfer your data internationally?
- between and within Luvent entities;
- to overseas clients;
- to clients within your country who may, in turn, transfer your data internationally;
- to a cloud-based storage provider; and
- to other third parties, as referred to in section 5. (“Who do we share your personal data with?”)
We want to make sure that your data are stored and transferred in a way which is secure.
To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.
11. Cookies policy
It is possible that additional cookies may be placed by various other providers whose additional services are offered on our website. We have no influence on these providers and do not make use of their cookies for our own purposes.
By default, all cookies are accepted by any Internet browser. You can instruct the browser, however, to not accept cookies or to delete them automatically after each Internet session. Please refer to the appropriate instructions on the support pages of your browser manufacturer. You can also deactivate cookies of different advertising providers via the following website: YourOnlineChoices (http://www.youronlinechoices.com/uk/your-ad-choices)
11.5. Google Analytics
The website of Luvent Consulting GmbH uses Google Analytics for web analyses. By the use of this analysis service, cookies are stored on your computer as well.
The information generated, including the IP addresses of visitors, is sent to a server in the US and stored there. Luvent Consulting GmbH uses the function “_anonymizeIP()” for privacy reasons so that the transmitted IP addresses are processed only in abbreviated form and exclude a direct reference to individuals.
Google will possibly pass this information on to third parties where this is required by law or where third parties process the data on behalf of Google. More information about Google Analytics can be found online at http://www.google.com/analytics/terms/gb.html.
Luvent Consulting GmbH uses the functions of Google Analytics to analyse site usage, e.g. in the form of anonymous evaluations and graphics on page views and visits, as well as for remarketing, reports on impressions in the Google Display Network, integration of DoubleClick Campaign Manager and Google Analytics reports on performance according to demographics and interests.
By using this site you consent to the processing of data gathered about you by Google in the manner and for the aforementioned purposes described above.
You can completely stop the tracking by Google Analytics by clicking here: Disallow Google Analytics to track me. For this objection to be undertaken permanently, your browser must accept cookies. Alternatively, you can object to the data collected through the use of a Google Browser-Plugin (https://tools.google.com/dlpage/gaoptout?hl=en-GB)
12. Our legal bases for processing your data
12.1. Legitimate interests
Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal data.”
We don’t think that any of the following activities prejudice individuals in any way – in fact, they help us to offer you a more tailored, efficient service. However, you have the right to object to us processing your personal data on this basis. If you would like to know more about how to do so, please review section 8.1. (“Right to object”).
12.2. Expert Data
We think it’s reasonable to expect that if you are looking for employment or have posted your professional CV information on a job board or professional networking site, you agree that we collect and use your personal data to offer or provide our recruitment services to you, share that information with prospective clients and assess your skills against our vacancies. Once it’s looking like you may get the job, your prospective employer may also want to double check any information you’ve given us or to confirm your references, qualifications and criminal record, to the extent that this is appropriate and in accordance with local laws. We need to do these things so that we can function as a profit-making business, and to help you and other candidates get the employment opportunities.
We want to provide you with tailored job recommendations to help you in finding new job opportunities. We, therefore, think it’s reasonable for us to process your data to make sure that we send you the most appropriate content.
We also need to use your data for our internal administrative activities, like payroll and invoicing where relevant.
We have our own obligations under the law, which it is a legitimate interest of ours. If we believe in good faith that it is necessary, we may, therefore, share your data in connection with crime detection, tax collection or actual or anticipated litigation.
12.3. People whose data we receive from candidates and staff, such as referees and emergency contacts
If you have been put down by a candidate as one of their referees, we use your personal data in order to contact you for a reference. This is a part of our quality assurance procedure and so we deem this to be necessary for our legitimate interests as an organisation offering job opportunities for experts.
If a candidate has given us your details as an emergency contact, we will use these details to contact you in the case of an accident or emergency. We are sure you will agree that this is a vital element of our people-orientated organisation, and so is necessary for our legitimate interests.
In certain circumstances, we are required to obtain your consent to the processing of your personal data in relation to certain activities. Depending on exactly what we are doing with your information, this consent will be opt-in consent or soft opt-in consent.
Article 4(11) of the GDPR states that (opt-in) consent is “any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.” This means that:
- you have to give us your consent freely, without us putting you under any type of pressure;
- you have to know what you are consenting to – so we’ll make sure we give you enough information;
- you should have control over which processing activities you consent to and which you don’t. We provide these finer controls within our privacy preference centre; and
- you need to take positive and affirmative action in giving us your consent – we provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.
We will keep records of the consents that you have given in this way.
As we have mentioned, you have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found in section 8.2.
14. Establishing, exercising or defending legal claims
Sometimes it may be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. Article 9(2)(f) of the GDPR allows this where the processing “is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity”.
This may arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.
15. Reasons and how to contact us
Luvent Consulting GmbH
10405 Berlin, Germany
Alternatively, you can send an email to email@example.com