Effective as of: 26.03.2019
Introduction and Scope
Innovation Academy SA (“Innovation Academy”, “we”, “us”, “our”) is an non-profit organization that offers innovation trainings for the business owners as well as international entrepreneurship programs for students for the purpose of providing them with the resources, connections, and mentoring necessary to build a successful startup.
- you access and submit your Personal Data directly to us, for example, via our website at https://www.inacademy.eu (“Website”); or
- we receive your Personal Data from your educational institution/employer.
In the context of the activities described in this Policy, the following legal entity acts as a data controller for your Personal Data:
Innovation Academy SA
If you are an individual applying for one of our programs, we may process the following categories of Personal Data about you:
- biographical information, such as your first and last name, age, nationality and gender;
- contact information, such as email and phone number;
- employment and/or education data, such as your educational institution, study field, occupation, place of work;
- certain information about your motivation to enroll in one of our programs, such as your introduction video and motivational letter;
- travel and accommodation information;
- social media usernames (Facebook, LinkedIn, Instagram, Twitter);
- feedback during and after the program; and
- testimonials (see section “Use of Testimonials”).
If you are an employee of one of our corporate clients or a business owner taking part in our Growth Accelerator or Executive Innovation Day, we may collect and process your full name, corporate email address and place of work.
If you are our mentor or an individual applying for a mentor position with us, we may process the following categories of Personal Data about you:
- biographical information, such as your first name, last name and country of residence;
- contact information, such as your email and LinkedIn profile; and
- other useful information which helps us evaluate your suitability for the position, such as mentoring experience in alternative entrepreneurship programs, preferable mentoring field and experience in giving keynote talks.
Job applicant Data
If you are a candidate who has applied for a position with us, we may typically collect the following categories of Personal Data:
- biographical information, such as your name, gender and nationality;
- contact information, such as your email address and phone number;
- motivational letter; and
- any other information which may be included in your CV, such as your work experience, previous job roles and responsibilities, technical and non-technical skills that you possess, data about your educational background including school and university qualifications, certificates, trainings, languages, references and hobbies.
When Innovation Academy SA decides to recruit you, it will retain the necessary Personal Data as required by the employment relationship and applicable laws. Innovation Academy SA must process the candidate’s Personal Data because it is necessary for certain operations to be performed before the employment contract is concluded. Please note that if you do not provide the necessary Personal Data, you may not be able to meet the terms of employment, internship or participation in certain company plans and programs, or prevent Innovation Academy SA from entering into a contractual relationship with you.
Your Personal Data will be processed only by those employees who evaluate your application or who have to process the data when performing recruitment activities. These include, for example, recruiters, HR managers, and other interviewers and individuals who perform administrative or other recruitment related activities.
When you access our Website whether by computer, mobile phone or any other device, we automatically collect certain information about your use of our Website which may include, among other things: geographical location and IDs of the device; bandwidth used; system and connection performance; browser type and version; operating system; referral source; length of visit; page views; IP address or other unique identifier of your device.
Use of Testimonials
We may select and post client testimonials on our Website, which may contain personally identifiable information such as your name, job title and the company you work for. This information may be visible to other visitors of our Website. We will obtain your consent prior to posting any testimonial with your name. If you would like us to remove your name or testimonial from our Website, you may reach us using the “Contact Us” section.
How We Receive Personal Data
We may receive Personal Data:
- directly from you when you access our Website and apply for one of our programs;
- when you apply for a position with us via our Website or otherwise;
- from your educational institution through which you submit an application for our program;
- from our partners who provide our trainings; and
- when you submit to us your feedback about the program via our Facebook chatbot.
Basis of Processing
Within the scope of this Policy, we may rely on one or more of the following legal grounds for processing your Personal Data:
- the need to perform the contractual duties we have in relation to our clients;
- the need to pursue our legitimate interests, such as to review your application and provide the educational services to you;
- your consent;
- any other ground, as required or permitted by law in the specific respective context.
Purposes of Processing
We process your Personal Data for the purposes of:
- providing education services to our clients;
- evaluating candidates’ suitability for a mentor position;
- measuring our clients’ motivation and making a decision on their admission;
- reaching out and following up on the clients regarding the program they applied for;
- improving the services and the product;
- understanding our clients’ skills and competences to form balanced teams for the program;
- arranging travel and accommodation;
- contacting our clients in case of emergency;
- allowing our partners to send you information about job opportunities;
- assessing the suitability of a job applicant for a particular position with us; and
- sending periodic emails regarding our services.
After a participant completes our program, we will typically keep some of his or her Personal Data in order to:
- retain and re-issue the participant’s diplomas and/or certificates;
- contact the participant in case there is a possibility for collaboration in the future;
- add and maintain our alumni network on Facebook.
Sharing Personal Data with Third Parties
We may share your Personal Data with certain third-party providers for the purposes of facilitating the provision of our services. We will require that all these third-party vendors maintain at least the same level of data protection that we maintain for such Personal Data.
Such third party vendors may provide:
- email marketing services;
- web form services;
- business management software services;
- CRM software services;
- online scheduling services; and
- cloud storage services.
When a successful applicant is accepted by Innovation Academy, we provide him or her access to our online platform where the participants are able to interact with each other which also means that some of your Personal Data will be visible to other participants to the program.
Your Personal Data may also be shared with some of our partners who will notify you about their available positions.
Other Disclosure of Your Personal Data
We may disclose your Personal Data:
- to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders;
- in connection with a merger, division, restructuring, or other association change; or
- to our subsidiaries or affiliates only if necessary for operational purposes.
If we must disclose your Personal Data in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your Personal Data will maintain the privacy or security of your Personal Data.
Data Integrity & Security
We use reasonable and diligent efforts to maintain accurate information on our data subjects, and have adopted and implemented reasonable industry standard security procedures to protect any such information collected. Although the Innovation Academy will use reasonable efforts to secure network communications and our Website, we cannot guarantee that the information submitted to, maintained on, or transmitted from our systems will be completely secure.
Data Retention Period
If you are a participant of our program, we will store your Personal Data for three years after the end of the program. After the lapse of this period, we will ask your consent to keep your Personal Data for another twelve months on a yearly basis. If you do not give us your consent, we will promptly remove any Personal Data associated with you.
If you are a candidate and we do not recruit you, your Personal Data will be retained for one year starting from the end of the recruitment process.
Access, Review, Objection to Processing & Portability
If you are a data subject whose Personal Data we store, you may have the right to request access to, and the opportunity to update, correct, port or delete such Personal Data. Under certain circumstances, you may also have the right to restrict or object to the processing of your Personal Data. To submit such requests, please contact us using the information in the Contact Us section of this Policy.
Privacy of Children
Our Website is not directed to collect Personal Data from people under the age of 18. We do not knowingly allow anyone under 16 to submit any Personal Data to our Website. If you believe your child may have provided us with their Personal Data, you can contact us using the information in the Contact Us section of this Policy and we will delete the Personal Data.
Changes to this Policy
If we make any material change to this Policy, we will post the revised Policy to this web page and update the “Effective on” date above to reflect the date on which the new Policy became effective. We will also notify you about these changes via email.
If you have any questions about this Policy or the processing of your Personal Data, please contact us at firstname.lastname@example.org.
Please allow us 7 days to reply.
Supervisory Authority Oversight
If you are a data subject whose Personal Data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Union member states.