We at Headline ("Headline", "we") take the protection of your personal data very seriously. We shall therefore handle your personal data with due care, conscientiously and in accordance with the applicable laws. The purpose of this document is to provide you with information about the data we collect and process when you use our website.

Section 1: Information on the collection of personal data

1. Personal data means any information relating to you personally, e.g. name, address, email addresses, user behaviour.
2. The data controller within the meaning of Article 4 (7) of the EU General Data Protection Regulation (“GDPR”) is
   
   Headline Management GmbH
   Friedrichstrasse 206
   10969 Berlin
   Germany
   Email: privacy@headline.com
   Website: www.headline.com
   
3. When you contact us by email, we store and process the data you provide (e.g. email address, name and any telephone number, contents of your message, etc.) in order to be able to respond to your inquiry. Data processing for purposes of contacting us is done in accordance with Article 6 (1) (1) point (a) of the GDPR, based on the consent you have given voluntarily. We shall erase the data we collected on this basis when it is no longer required, e.g. because we have answered your query.
4. You have the possibility to search for job offers on the website. We process the data that you enter in the corresponding search form (job title, company, location etc.). The legal basis for this is Article 6 (1) (1) point (a) of the GDPR.
5. To prevent unauthorised access by third parties to your personal data and in particular, financial data, the ordering process is encrypted using SSL (Secure Socket Layer). We also take reasonable physical, technical and administrative security measures to protect your personal data from loss, misuse, unauthorised access, disclosure and alteration. These security measures include firewalls, data encryption, physical access restrictions to our data centres, and access authorisation controls.

Section 2: Collection of personal data when visiting our website

1. If you use the website for information purposes only, we only collect the personal data that your browser transmits to our server. This information is temporarily stored in a so called log file. If you would like to visit our website, we shall collect the following data:
   • IP address
   • Date and time of the request
   • Time zone difference to Greenwich Mean Time (GMT)
   • Content of the request (specific page)
   • Access status/ HTTP status code
   • Amount of data transferred
   • The referring website
   • Browser
   • Operating system and its interface
   • Language and version of the browser software
   
   We process this data for the following purposes:
   • To ensure smooth connectivity of the website,
   • to ensure that our website is user-friendly,
   • to evaluate the security and stability of the system, and
   • for other administrative purposes.
   
   The information stored in the log files does not allow any conclusions about your person and we only store IP addresses in the log files in shortened, pseudonymised form. We delete this data when the aforementioned purposes have been achieved or no later than 26 months after you visited our website.
   
2. On various pages of our website, we use cookies to make our website more user-friendly and to enable the use of certain functions and features to display needs-based products or for market research purposes. Cookies are small text files that are automatically stored on your device.
   
   Use of cookies
   a) This website uses the following types of cookies, the scope and functionality of which will be explained below:
   • Transient cookies
   • Persistent cookies.
   b) Transient cookies are automatically deleted when you close your browser. These include, in particular, session cookies. They save a so-called session ID which is used to assign different requests from your browser to the common session. This allows your computer to be recognised when you return to our website. Session cookies are deleted when you log out or close the browser.
   c) Persistent cookies are automatically deleted after a specified period, which may differ, depending on the cookie. You can delete cookies at any time in the security settings of your browser.
   d) You may configure your browser settings according to your preferences and, for example, block the acceptance of third-party cookies or all cookies. Please note that if you do this, you may not be able to use all the functions and features of this website.
   e) For information about the length of storage, please refer to the overview in the cookie settings of your browser.
   
3. The legal basis for aforementioned data processing is Article 6 (1) (1) point (f) of the GDPR. The purposes of data processing named above constitute our legitimate interests.

Section 4: Third parties with whom personal information may be shared

1. Google LLC
   Google Data Protection Office
   1600 Amphitheatre Parkway
   Mountain View, California 94043, U.S.
   Purpose: Storage and backup
   Privacy-Shield: yes
2. The Rocket Science Group LLC
   675 Ponce De Leon Ave NE, Suite 5000
   Atlanta, Georgia 30308
   Purpose: Email service, customer support
   Privacy-Shield: yes
3. Rewardly, Inc.
   160 Pine St
   San Francisco, CA 94111, U.S.
   Purpose: Email service, customer support
4. Cloudflare, Inc.
   101 Townsend Street
   San Francisco, CA 94107, U.S.
   Purpose: Storage and backup
   Privacy-Shield: yes
5. Getro Inc.
   4845 Pearl East Cir Ste 118 #66053 Boulder,
   Colorado 80301-6112, U.S.
   Purpose: Processing and storing subscription or application data to a job through the job board

Section 3: Newsletter

1. If you subscribe to our newsletter, we will regularly send you an email to inform you about news from Headline and our ventures, investment trends, events, among other things. Subscription to our newsletter is voluntary.
2. The only information we need from you for sending the newsletter is your email address. We store your email address for the purpose of sending you the newsletter. The legal basis for this is Article 6 (1) (1) point (a) of the GDPR.
3. We use the so-called double opt-in process for subscriptions to our newsletter. This means that once you have subscribed to our newsletter, we will send you an email to the email address you have provided, in which we ask you to confirm that you wish to receive the newsletter.
4. You can withdraw your consent and unsubscribe from the newsletter at any time. To unsubscribe, you can use our contact details specified above to send us a message, or the unsubscribe link in our newsletters or you can send us an email to privacy@headline.com.
5. The newsletter of Headline contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Headline may see if and when an email was opened by you, and which links in the email were called up by you. Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by us in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of you. For more information please visit: https://mailchimp.com/help/aboutopen-tracking/. The legal basis for aforementioned data processing is Article 6 (1) (1) point (f) of the GDPR. The purposes of data processing named above constitute our legitimate interests.
6. After unsubscribing, we will delete your email address and the aforementioned data that we have received in the scope of the newsletter tracking unless you have consented to further or other use of these data.

Section 5: Google Analytics

1. The website uses functions from the web analytics service Google Analytics. Provider is Google Ireland Ltd. („Google“). Google Analytics uses so called „cookies". They are text files that are being saved on your PC and that enable analytic of the use of the website by you. The information created by the cookies about your use of the website is usually transmitted to a Google server in the USA and saved there. If the IP anonymization is activated on this website, Google will shortened your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website and Internet use.
2. The IP address transmitted by your browser within the scope of Google Analytics will not be merged with other data from Google.
3. You can prevent the saving of the cookies by choosing the respective setting; however we point out that you cannot use all functions of the website fully if you do so. You can furthermore prohibit the registration of the of you use of the website related data created by the cookie (including your IP-address) to Google as well as the processing of this data by Google by downloading and installing the browser plugin provided by this link: https://tools.google.com/dlpage/gaoptout.
4. The website uses Google Analytics with the extension „_anonymizeIp()“. As a result, IP addresses are further processed in a shortened form, so that direct reference to persons can be ruled out. As far as the data collected about you is personal, it will be excluded immediately and the personal data will be deleted immediately.
5. We use Google Analytics to analyze and be able to regularly improve the use of our website. With the gained statistics we can improve our offer and make it more interesting for you as a user. The legal basis for the use of Google Analytics is Article 6 para. 1 S. 1 lit. f GDPR. Our legitimate interest results from the aforementioned improvement of the offer.
6. Contact information Europe: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Privacy declaration: http://www.google.com/intl/de/analytics/learn/privacy.html; http://www.google.de/intl/de/policies/privacy.
7. After our purpose of the use of Google Analytics has ceased and the use has ended, the data collected in this context will be deleted.

Section 6: Google Tag Manager

1. Our website uses Google Tag Manager, a service, which is offered for users from the European Economic Area, Switzerland and Liechtenstein by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") and for all other users by Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA.
2. The Google Tag Manager is used to manage tracking tools and other services, so-called website tags. A tag is an element that is stored in the source code of our website, for example, to record predefined usage data.
3. The Google Tag Manager works without the use of cookies. The Google Tag Manager ensures that the usage data required by our partners (cf. the data processing procedures described above) is forwarded to them.
4. The Google Tag Manager itself does not collect any personal data itself. The tool ensures that other tags are triggered, which in turn may collect data and which are further explained in this privacy notice.
5. If no consent is given to the use of the analysis and marketing cookies, no data will be processed in connection with the Tag Manager. You can also read more about the Tag Manager in Google's Tag Manager information. The use of the Tag Manager is technically necessary.

Section 7: Your rights

1. You have the following rights with respect to personal data concerning you:
   • Right to information (Article 15 of the GDPR)
   • Right to rectification of data (Article 16 of the GDPR)
   • Right to erasure of data (Article 17 of the GDPR)
   • Right to restriction of processing (Article 18 of the GDPR)
   • Right to data portability (Article 20 of the GDPR)
2. In addition, you have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data infringes against this regulation (Article 77 of the GDPR). One of the supervisory authorities responsible for us among others is:
   Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit
   Ludwig-Erhard-Str. 22, 7.OG 20459 Hamburg, Germany
   Phone: 040/428 54 4040
   Fax: 040/428 54 4000
   Email: mailbox@datenschutz.hamburg.de
   Homepage: https://www.datenschutz.hamburg.de
3. You have the right to withdraw the consent you once gave to us with regard to data processing any time (Legal basis: Article 6 (1) (1) point (a) of the GDPR). As a result, we shall no longer be allowed to process data based on this consent going forward. The withdrawal of consent shall not affect the legality of the processing done on the basis of this consent before its withdrawal.
4. Right to object to processing (Article 21 of the GDPR)

1. You have the right, for reasons arising from your particular situation, to object to the processing of your personal data which is based on Article 6 (1) point (f) of the GDPR (Data collection for purposes of safeguarding legitimate interests), any time; this includes profiling based on those provisions. If you make use of this right to object, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or unless the processing is for purposes of asserting, exercising or defending legal claims.
2. Where we process your personal data for direct advertising purposes, you will have the right to object at any time to the processing of your personal data for such advertising purposes; this also includes profiling to the extent that it is related to such direct advertising. The existence of a special situation, as in (a), is therefore, not necessary for an effective objection to direct advertising. If you object to processing for direct advertising purposes, your personal data will no longer be processed for such purposes.